Privacy Policy

Last updated: 1 September 2024

1. Introduction

Millicent Labs Limited ("Millicent", "we", "us", or "our"), a company registered in England and Wales with its registered office at 20-22 Wenlock Road, London, N1 7GU, is committed to protecting and respecting your privacy. This policy explains how we handle your personal data when you use the Millicent One blockchain platform and related services (collectively, the "Services") accessible through the website at https://millicent.io (the "Site").

This policy complies with the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and the Data Protection Act 2018.

Millicent Labs Limited is currently responsible for hosting and maintaining this website on behalf of Millicent One. We anticipate transferring these responsibilities to a separate entity at an appropriate future date.

2. Data Controller

For the purposes of applicable data protection laws, the data controller is:

Millicent Labs Limited 20-22 Wenlock Road London, N1 7GU United Kingdom

Email: info [at] millicent.io

3. Information We Collect

We collect and process the following categories of personal data:

3.1 Information you provide to us

Public wallet address
Name and email address (if you subscribe to our communications or participate in surveys)
Any other information you choose to provide when contacting us or using our Services

3.2 Information we collect automatically

Technical data: IP address, device and browser information, operating system
Usage data: Pages visited, interactions with the Site, time spent on the Site
Blockchain data: Publicly available data related to transactions on our platform

3.3 Information from third parties

We may receive information about you from other sources, including publicly available blockchain data and our business partners.

4. How We Use Your Information

We use your personal data for the following purposes:

To provide and maintain our Services
To process transactions and communicate with you about them
To improve and personalize our Services
To send you updates, newsletters, and marketing communications (where you have consented)
To comply with legal obligations and enforce our terms
To detect and prevent fraud and other prohibited activities

Our legal bases for processing your data include:

Performance of a contract
Compliance with legal obligations
Our legitimate interests (such as improving our Services and preventing fraud)
Your consent (for marketing communications)

5. Cookies and Similar Technologies

We use session cookies and similar technologies to enhance your experience on our Site. These are small text files stored on your device that help us recognize you and remember your preferences.

You can manage your cookie preferences through your browser settings. However, disabling cookies may limit your ability to use some features of our Site.

We may share your personal data with:

Service providers and business partners who help us deliver our Services
Legal and regulatory authorities, when required by law
Potential buyers or investors, in the event of a business transaction like a merger or acquisition

Given the global nature of blockchain technology, your data may be transferred to, and stored in, countries outside the UK and European Economic Area (EEA). We ensure that such transfers comply with applicable data protection laws, including by using standard contractual clauses or relying on adequacy decisions where available.

7. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes we collected it for, including for legal, accounting, or reporting requirements. The specific retention period depends on the nature of the data and our legal obligations.

8. Your Rights

Depending on your location, you may have the following rights regarding your personal data:

Access: Request a copy of your personal data
Rectification: Correct inaccurate or incomplete data
Erasure: Request deletion of your data in certain circumstances
Restriction: Limit how we use your data
Portability: Receive your data in a structured, machine-readable format
Objection: Object to our processing of your data
Withdraw consent: Where processing is based on consent

To exercise these rights, please contact us at info@millicent.io. We will respond to your request within one month, unless the request is complex or numerous, in which case the period may be extended by two further months.

You also have the right to lodge a complaint with a supervisory authority. In the UK, this is the Information Commissioner's Office (www.ico.org.uk).

9. Automated Decision-Making

We may use automated decision-making processes to restrict access to certain Services based on your location and Know Your Customer (KYC) status. If you're concerned about an automated decision affecting you, please contact us for more information or to request human intervention.

10. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized or unlawful processing, accidental loss, destruction, or damage. However, no method of transmission over the Internet or electronic storage is 100% secure, so we cannot guarantee absolute security.

11. Children's Privacy

Our Services are not intended for children under the age of 18. We do not knowingly collect or process data relating to children. If you become aware that a child has provided us with personal data, please contact us, and we will take steps to delete such information.

12. Changes to This Privacy Policy

We may update this privacy policy from time to time to reflect changes in our practices or for legal reasons. We will notify you of any material changes by posting the new policy on our Site and, where appropriate, via email.

13. Contact Us

If you have any questions about this privacy policy or our data practices, please contact us at: