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Dabra Platform Privacy Notice

This Privacy Notice is designed to help you understand how Dabra Today Ltd ("RT," "we," "us,"or "our") collects, uses, processes, and shares your personal information on the Dabra Platform (https://dabra.app/realms), and to help you understand and exercise your privacy rights.

SCOPE AND UPDATES TO THIS PRIVACY NOTICE

This Privacy Notice applies to personal information processed by us on the Dabra Platform (https://dabra.app/realms), which to make this Privacy Policy easier to read, will be called the "Services." This Privacy Notice also applies to any optional features or programs we enable within our Services, including new functionality introduced by SPL Token v2 (Token-2022) on the Solana blockchain.

An Important Note regarding Blockchain Technologies: If you participate in our Services relating to the creation and management of a decentralized autonomous organization ("DAO"), smart contracts will be employed that necessarily collect information, such as your cryptocurrency wallet address (which some legal jurisdictions may consider personal information), and that information will be stored on a public blockchain that we do not control. Additionally, if you enable or interact with advanced features of Solana's SPL Token v2 ("Token-2022")—such as transfer fees, freeze authority, or confidential transfers—please be aware that such actions may record further details on the blockchain, including partially confidential transaction data or administrative control records. These details may still be public, permanent, and outside our control due to the immutable nature of blockchain. We do not manage or store private keys granting freeze or fee authority, nor can we remove or modify any data once recorded on-chain. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when a proposal is presented to a member's DAO and after all needed votes are made by respective DAO member, the smart contract will execute the proposed action if the proposal passed. In these situations, your personal information will be stored on that blockchain through the execution of a smart contract and may not be able to be modified or deleted due to the immutable nature of the blockchain.

Changes to our Privacy Notice. We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use our Services after the new Privacy Notice takes effect.

PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

DAO Creation

We may collect personal information when you create a decentralized autonomous organization ("DAO"), such as your cryptocurrency wallet address (which may be considered personal information in some legal jurisdictions). If you choose to configure SPL Token v2 ("Token-2022") extensions (for example, enabling fees or freeze authority), certain additional settings or metadata may be recorded on the blockchain alongside your wallet address. While this metadata is not collected or stored by Dabra Today Ltd off-chain, it may still be linked to your on-chain activity and wallet.

Your Communications with Us

We may collect personal information, such as cryptocurrency wallet address, email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.

Interactive Features

We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., DAO creation and blockchain transactions, commenting functionalities, etc). Any information you provide using the public sharing features of the Services will be considered "public," unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

Business Development and Strategic Partnerships

We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.

Provide Our Services

We use your information to fulfill our contract with you and provide you with our Services, such as:

  • Providing access to certain areas, functionalities, and features of our Services;
  • Answering requests for customer or technical support;
  • Communicating with you about your account, activities on our Services, and policy changes; and
  • Allowing you to register for events.

Where you elect to use Token-2022's optional functionalities, any additional on-chain data (e.g., fee parameters, freeze transactions) is processed by the underlying blockchain and not actively used by us for any separate analytics, marketing, or profiling purposes unless otherwise disclosed.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your personal information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

Disclosures to Provide our Services

The categories of third parties with whom we may share your personal information are described below.

Service Providers

We may share your personal information with our third-party service providers and vendors that assist us with the provision of our Services. This includes service providers and vendors that provide us with IT support, hosting, payment processing, customer service, and related services.

Business Partners

We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information with business partners with whom we jointly offer products or services.

Affiliates

We may share your personal information with our company affiliates.

Advertising Partners

We may share your personal information with third-party advertising partners. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as "interest-based advertising" or "personalized advertising."

YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

"Do Not Track"

Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Personalized Advertising

You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS, and others.

SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized access, use, disclosure, or loss of personal information.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

If we transfer personal information which originates in the European Economic Area, Switzerland, and/or the United Kingdom to a country that has not been found to provide an adequate level of protection under applicable data protection laws, one of the safeguards we may use to support such transfer is the EU Standard Contractual Clauses.

CHILDREN'S INFORMATION

The Services are not directed to those under the age of 18 (or other age as required by local law), and we do not knowingly collect personal information from children.

OTHER PROVISIONS

Third-Party Websites/Applications

The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority

If your personal information is subject to the applicable data protection laws of Brazil or Switzerland, you have the right to lodge a complaint with the competent supervisory authority or attorney general if you believe our processing of your personal information violates applicable law.

  • Autoridade Nacional de Proteção de Dados (ANPD)
  • Swiss Federal Data Protection and Information Commissioner (FDPIC)

CONTACT US

Dabra Foundation is the controller of the personal information we process under this Privacy Notice.

If you have any questions about our privacy practices or this Privacy Notice, or to exercise your rights as detailed in this Privacy Notice, please contact us at:

Dabra Foundation

Attn: Dabra Customer Support

31 Hengrave Road, London, SE 23 3NW, England

admin@dabra.app

Last Updated: January 2025