Privacy Policy

1. Introduction

Bold Labs Inc. (“Company,” “our,” “we”) understands the importance of privacy, especially when it comes to your Personal Information. This Privacy Policy applies to:

• Users of swap.fyi (the “Website”), which is a cross-chain DEX aggregator comparison tool;
• Users of any APIs or developer services we may offer (“API Services”); and
• All visitors to our Website.

In this Privacy Policy, we explain what information we collect from you when you use our services, how we will use this information, and the ways in which we may share your information. This Privacy Policy describes your rights under applicable Data Protection Laws, including the EU General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”).

Undefined terms shall have the same meaning as they have within the Terms of Service.

2. Information We Collect About You

For the purposes of this Privacy Policy, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer/resident or household.

We collect different types of information depending on how you use our services:

Website Visitors

• Browser information (type, version)
• IP address
• Device information and screen resolution
• Analytics data about website usage (pages visited, time on site, interactions)
• Referral source

Swap/Bridge Query Data

• Source and destination chain selections
• Token selections and amounts queried
• Quote results and aggregator responses

Information We Do NOT Collect

• Wallet addresses or private keys
• Transaction signatures or execution data
• Any “Special Categories of Personal Information” (race, ethnicity, religious beliefs, sexual orientation, political opinions, health data, biometric data)
• Information about criminal convictions and offenses

Personal Information does not include:

• Publicly available blockchain information
• De-identified or aggregated data
• Information covered by certain sector-specific privacy laws

3. How We Collect Information From You

We collect information from you in two ways:

• Directly from you: When you interact with the Website, such as entering swap parameters or contacting us.
• Automatically: As you navigate through the Website, we collect generic usage information such as usage details, IP addresses, web browser preferences, and information collected through cookies and other tracking technologies (such as Google Analytics).

4. Why We Need Your Data

We use information that we collect about you or that you provide to us for the following purposes:

• To provide and maintain our comparison Services
• To improve the Website’s performance and user experience
• To understand usage patterns and optimize our quote aggregation
• To detect and prevent abuse or unauthorized access
• To meet legal and regulatory requirements
• To communicate important updates and changes to our Services
• To analyze and improve our Services

5. Our Legal Basis for Processing Your Data

To the extent applicable, we process your Personal Information under the Data Protection Laws on the following lawful bases:

• You have consented to the processing of your Personal Information;
• To perform a contract with you, i.e., to provide you the Services;
• In our legitimate interest (which interest is not overridden by your rights), such as for safety and security, research and development, and to protect our legal rights and interests; or
• To comply with legal or regulatory obligations.

6. California Privacy Rights

The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of Personal Information, as well as rights to access, delete, and restrict the sale of certain Personal Information we collect about them.

If you are a California resident, you may be entitled to the following rights:

• Right to Know: You may have the right to access the Personal Information collected about you and the sources from which it was obtained.
• Deletion: You may have the right to request that we delete any of the Personal Information we have collected about you.
• Correction: You may have the right to correct inaccuracies in your Personal Information.
• Opt-out: You may have a right to opt-out of the “sale” and “sharing” of your Personal Information.
• Non-Discrimination: You have the right to not be discriminated against for exercising your privacy rights.

Sale and sharing of Personal Information: We do not “sell” or “share” your Personal Information and have not “sold” or “shared” your Personal Information in the preceding 12 months.

We will respond to your request within forty-five (45) days after receipt of a Verifiable Consumer Request. You may send us an email at [email protected] to exercise your rights.

7. Disclosure of Your Information with Third Parties

Any Personal Information you provide will be held securely and processed in accordance with data protection and other relevant legislation. We may share your Personal Information with our business partners and service providers, but only to the extent necessary to provide our Services. This includes:

• Our contractors, employees, service providers, and other third parties that we use to support our business (e.g., analytics providers, hosting services);
• To a buyer or other successor in the event of a merger or reorganization;
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Website, our users, or others.

We will not sell, rent, or lease your data to third parties.

8. Marketing

Where we have not received consent from you, we will not use your Personal Information for marketing purposes.

9. Your Data Protection Rights

To the extent applicable under Data Protection Laws, you may be entitled to the following rights:

• Right of access: You can request a copy of your Personal Information and other information related to our processing.
• Right to rectification: You have a right to request that we correct any information you believe is inaccurate.
• Right to erasure: You have the right to ask us to delete or remove your Personal Information.
• Right to restrict processing: You have the right to request that we cease the processing of your Personal Information, under certain conditions.
• Right to object: You have the right to object to the processing of your Personal Information where it is used for direct marketing.
• Right to withdraw consent: You have the right to withdraw your consent where our processing is based upon your consent.
• Right to data portability: You have the right to request your Personal Information be transferred to another organization.
• Right to complain: You have the right to complain to the relevant supervisory authority if you believe we are processing your Personal Information in breach of applicable law.

You may send us an email at [email protected] to request access to, correct, or delete any Personal Information that you have provided to us. We will process your request within 30 days after receipt.

10. Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and unauthorized access. Information is encrypted through the Website with Transport Layer Security (TLS).

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Website. Any transmission of Personal Information is at your own risk.

11. How Long Do We Keep Your Data?

We may retain your Personal Information for as long as:

• It is needed for the purposes set out in this Privacy Policy;
• Required by applicable law or regulation;
• Necessary for us to pursue legitimate business interests, conduct audits, comply with legal obligations, resolve disputes, and enforce our agreements.

12. Cookies

Cookies are small text files that collect standard Internet log information and visitor behavior information. When you visit our Website, we may collect information from you automatically through cookies or similar technology.

Our Website uses the following types of cookies:

• Strictly Necessary Cookies: These cookies are necessary for the Website to function and cannot be switched off.
• Performance and Analytics Cookies: These cookies allow us to count visits and traffic sources to measure and improve our Website’s reliability and performance (e.g., Google Analytics).

If you wish to disable cookies, you can do so through your browser settings. If you do choose to disable cookies, your ability to use or access certain parts of our Website may be affected.

13. Users Under Age 18

The Website is only intended for adults eighteen (18) years of age and older. You are not allowed to use the Website or provide information on it if you are under eighteen (18) years of age.

14. Do Not Track Settings

We do not track, plant cookies, or use advertising when a Do Not Track (DNT) browser mechanism is in place.

15. Third-Party Links

Our Website may contain links that lead to third-party websites and aggregator platforms, and we are not responsible for the privacy practices, content, and/or activities of these linked services. Please review the privacy statements of any such third parties for further information about their privacy practices.

16. Changes to Our Privacy Policy

We will post any changes we make to our Privacy Policy on this page. If your consent is required for any such changes, we will obtain your consent before such changes are applied to you.

17. Contact Information

Please direct any privacy-related questions and concerns to us at [email protected].