BloxKey Privacy Policy

1. INTRODUCTION

BloxKey ("BloxKey," "we," "us," or "our"), respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website bloxkey.com (the "Site") or subscribe to our early access newsletter.

Important: BloxKey is currently in development and no wallet services are available. We currently only collect email addresses for our early access newsletter.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

Email Newsletter Subscription:

• Email address (required for newsletter signup)
• Subscription preferences
• Date and time of subscription

Contact Communications:

• Email address and message content when you contact us
• Any additional information you choose to provide

2.2 Information Collected Automatically

Technical Information:

• IP address
• Browser type and version
• Device information (type, operating system)
• Referring website
• Pages visited and time spent on Site
• Date and time of visits

Cookies and Similar Technologies:

• Essential cookies for website functionality
• Session identifiers
• We do not currently use analytics or advertising cookies

2.3 Information We Do NOT Collect

We do not currently collect:

• Names or personal identifiers (beyond email)
• Financial information
• Cryptocurrency addresses or wallet information
• Location data (beyond general location from IP address)
• Social media information

3. HOW WE USE YOUR INFORMATION

3.1 Primary Uses

Newsletter Communications:

• Send early access updates and development news
• Notify subscribers about service launches
• Provide information about BloxKey features and developments

Website Operations:

• Ensure proper website functionality
• Improve user experience
• Maintain website security

Legal and Compliance:

• Comply with applicable laws and regulations
• Respond to legal requests
• Protect our rights and interests

3.2 Future Service Preparation

We may use collected information to:

• Gauge interest in planned features
• Plan service capacity and geographic availability
• Improve our development roadmap

3.3 Marketing and Communications

• Send promotional content about BloxKey services
• Conduct surveys or gather feedback (with your consent)
• Provide customer support

You can opt out of marketing communications at any time using the unsubscribe link in our emails.

4. HOW WE SHARE YOUR INFORMATION

4.1 Third-Party Service Providers

Email Service Provider (Brevo):

• We use Brevo (formerly Sendinblue) to manage our email newsletter
• Brevo processes your email address and subscription preferences
• Brevo is located in Europe and complies with GDPR
• View Brevo's privacy policy at: https://www.brevo.com/privacy-policy/

Website Hosting:

• Our website hosting provider processes technical information
• This includes IP addresses, browser information, and usage data

4.2 Legal Disclosures

We may disclose your information when required by law or to:

• Comply with legal obligations or court orders
• Protect our rights, property, or safety
• Protect the rights, property, or safety of others
• Investigate fraud or security issues

4.3 Business Transfers

If BloxKey is involved in a merger, acquisition, or asset sale, your information may be transferred to the new entity.

4.4 What We DON'T Do

We do not:

• Sell your personal information to third parties
• Share your information for third-party marketing
• Use your information for advertising tracking
• Share your information with data brokers

5. INTERNATIONAL DATA TRANSFERS

5.1 Cross-Border Processing

Your information may be transferred to and processed in:

• United States (our planned headquarters)
• European Union (Brevo servers)
• Other countries where our service providers operate

5.2 Transfer Safeguards

We ensure appropriate safeguards for international transfers through:

• Adequacy decisions by relevant authorities
• Standard contractual clauses
• Service provider privacy certifications
• Other legally recognized transfer mechanisms

6. DATA SECURITY

6.1 Security Measures

We implement appropriate technical and organizational security measures:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Incident response procedures

6.2 Data Breach Notification

In case of a data breach that poses risks to your rights:

• We will notify relevant authorities within 72 hours (where required)
• We will notify affected users without undue delay
• We will provide information about the breach and steps taken

6.3 Limitation of Security

While we strive to protect your information, no method of transmission or storage is 100% secure. You provide information at your own risk.

7. YOUR PRIVACY RIGHTS

7.1 General Rights

All Users:

• Unsubscribe from emails at any time
• Contact us with privacy questions
• Request information about our data practices

Email Management:

• Update your email preferences
• Unsubscribe using the link in any email
• Contact us to remove your email: [email protected]

7.2 Rights for EU/UK Residents (GDPR)

If you are in the European Union or United Kingdom, you have additional rights:

Access: Request a copy of your personal data we hold Rectification: Correct inaccurate or incomplete data Erasure: Request deletion of your personal data Restriction: Limit how we process your data Portability: Receive your data in a portable format Objection: Object to processing based on legitimate interests Complaint: Lodge a complaint with your data protection authority

Legal Basis for Processing:

• Consent (newsletter subscription)
• Legitimate interests (website functionality, security)

7.3 Rights for California Residents (CCPA)

If you are a California resident, you have these rights:

Know: What personal information we collect and how we use it Delete: Request deletion of your personal information Opt-Out: Opt out of sale (we don't sell personal information) Non-Discrimination: We won't discriminate for exercising your rights

Categories of Information Collected:

• Identifiers (email address, IP address)
• Internet activity (website usage data)

7.4 Rights for Canadian Residents (PIPEDA)

If you are a Canadian resident:

• Access your personal information we hold
• Request correction of inaccurate information
• Withdraw consent for marketing communications
• File complaints with the Privacy Commissioner of Canada

7.5 Exercising Your Rights

To exercise any privacy rights:

• Email: [email protected]
• Subject line: "Privacy Rights Request"
• Include: Your email address and specific request

We will respond to valid requests within:

• 30 days (GDPR/UK GDPR)
• 45 days (CCPA)
• 30 days (PIPEDA)

8. DATA RETENTION

8.1 Retention Periods

Newsletter Subscriptions:

• Retained until you unsubscribe
• Retained for up to 30 days after unsubscribe for processing
• May be retained longer if required by law

Website Data:

• Technical logs retained for up to 12 months
• Contact communications retained for up to 3 years
• Security incident data retained as required by law

Legal Hold:

• Data may be retained longer if subject to legal obligations
• Data involved in disputes retained until resolution

8.2 Deletion Process

When data is deleted:

• Removed from active systems within 30 days
• Removed from backup systems within 90 days
• Some data may remain in encrypted backups for technical reasons

9. COOKIES AND TRACKING

9.1 Current Cookie Use

Essential Cookies Only:

• Session management
• Security features
• Basic website functionality

We Do NOT Currently Use:

• Analytics cookies (Google Analytics, etc.)
• Advertising cookies
• Social media tracking
• Cross-site tracking

9.2 Future Cookie Use

As we develop our services, we may implement:

• Analytics cookies (with consent)
• Performance monitoring cookies
• Marketing cookies (with consent)

Any additional cookies will require your consent and will be disclosed in an updated Cookie Policy.

9.3 Managing Cookies

You can control cookies through your browser settings:

• Block all cookies (may affect website functionality)
• Delete existing cookies
• Receive notifications before cookies are set

10. CHILDREN'S PRIVACY

10.1 Age Restrictions

Our Site is not intended for children under 18. We do not knowingly collect personal information from children under 18.

10.2 Discovery of Children's Data

If we discover we have collected information from a child under 18:

• We will delete the information immediately
• We will not use the information for any purpose
• We will notify parents if contact information is available

11. FUTURE SERVICES PRIVACY

11.1 Service Development

As we develop our cryptocurrency wallet services, we may collect additional types of information:

• Wallet addresses (but not private keys)
• Transaction preferences
• Usage analytics
• Customer support interactions

11.2 Self-Custody Philosophy

Our planned wallet services are designed for self-custody, meaning:

• You control your private keys
• We will NOT have access to your private keys
• We will NOT store your cryptocurrency
• We will NOT have access to your wallet balances

11.3 Privacy by Design

Our future services will be designed with privacy principles:

• Data minimization (collect only what's necessary)
• Purpose limitation (use data only for stated purposes)
• Transparency (clear explanations of data use)
• User control (easy privacy settings)

11.4 Updated Privacy Notice

We will update this Privacy Policy before launching new services that collect additional information types.

12. CHANGES TO THIS PRIVACY POLICY

12.1 Modification Rights

We may update this Privacy Policy to reflect:

• Changes in our data practices
• New features or services
• Legal or regulatory requirements
• Industry best practices

12.2 Notification of Changes

Material Changes:

• Email notification to newsletter subscribers
• Prominent notice on our website
• Updated "Effective Date" at the top of this policy

Minor Changes:

• Updated "Effective Date"
• Notice on website

12.3 Continued Use

Your continued use of our Site after changes constitutes acceptance of the updated Privacy Policy.

13. CONTACT INFORMATION

13.1 Privacy Questions

For privacy-related questions or concerns:

• Data Protection Officer: [email protected]
• General Legal: [email protected]

13.2 Privacy Rights Requests

To exercise your privacy rights:

• Email: [email protected]
• Subject: "Privacy Rights Request"
• Include: Your email address and specific request type

13.3 Supervisory Authorities

EU/UK Residents: You have the right to lodge a complaint with your local data protection authority

California Residents: You may file a complaint with the California Attorney General

Canadian Residents: You may file a complaint with the Privacy Commissioner of Canada

14. EFFECTIVE DATE AND VERSION

This Privacy Policy is effective as of August 5, 2025 and supersedes all previous versions.

Version History:

• Version 1.0: August 5, 2025 - Initial policy