How We Use Your Information

We use the personal data we collect for the following purposes (and other purposes that are closely related or ancillary to these, as permitted by law):

Providing and Maintaining Services: We use your information to operate, maintain, and provide you with the features and functionalities of the CICADA Finance platform. For example, we use public wallet addresses to facilitate your authorized transactions and to display your balances and transaction history to you. If you provide personal details for account creation or KYC, we use those to establish and verify your account and allow you access to relevant Services.

Customer Support and Communications: We use contact information (like your email or phone number) and communication content to respond to your inquiries, questions, and requests, and to provide customer service. For instance, if you contact us for help resolving an issue, we will use the information in your request to troubleshoot and get back to you. We may also send you technical or administrative notifications, such as alerts of changes to our policies or to relay important information about the Services (these are service-related and not promotional in nature).

Service Improvement and Analytics: We analyze usage information and feedback to understand how our Services are used and to make improvements. This helps us debug problems, optimize user experience, and develop new features. For example, we might track that a certain feature is rarely used and decide to redesign it. Most analytics data we use for this purpose are aggregated and do not directly identify you. We may also use information like device data to test and ensure the Services work well across different platforms and devices.

Personalization: To the extent permitted, we might use certain data to customize your experience. For example, we may remember your preferences (such as language or display settings) or use your interaction history to show relevant content on our platform. Any such personalization is generally automated and aimed at making the Service more useful to you.

Marketing and Newsletters (with Consent): If you explicitly opt in, we will use your email address or contact info to send you marketing communications, such as newsletters, product updates, or promotions about our Services or affiliated projects. We will only send you marketing emails with your consent, and you can withdraw that consent at any time (see Section 7 on your rights). Even after you opt-in, you will have the opportunity to opt out via an “unsubscribe” link in any marketing email or by contacting us. We will not spam you or share your contact details with third parties for their own marketing.

Compliance and Legal Obligations: We may process personal data as necessary to comply with applicable laws, regulations, and legal obligations. This includes using personal data for:

• Know Your Customer (KYC) & Anti-Money Laundering (AML): If we are legally required to verify identity or perform background checks, we will use the information you provided (like identification documents) to do so. We may share your information with third-party service providers for identity verification (see Section 4 on sharing with service providers). We also use transaction and blockchain data to monitor for unusual or potentially illegal activity as part of our AML obligations.

• Sanctions and Screening: We may compare your information (e.g., name, government ID) against government and international watchlists (such as OFAC’s SDN list or MAS sanctions lists) to ensure we are not providing services to sanctioned parties, as required by law.

• Record-Keeping: Laws may require us to keep certain information for a set period (for example, financial transaction records or KYC data). We will retain and use personal data as necessary to comply with such laws (see Section 6 on retention).

• Tax and Reporting: We might use relevant data to fulfill tax reporting obligations or respond to government inquiries (for example, reporting to the IRS or IRAS if applicable).

Protection of Rights and Interests: We may use and process personal data to protect our rights, property or safety, or that of our users or others. Examples include:

• Security and Fraud Prevention: We monitor activities (including using automated tools) to detect and prevent fraud, cyber-attacks, and other harmful activities. If we detect threats or malicious behavior, we may use relevant data to mitigate and address the issue (e.g., analyzing logins to identify account takeover attempts).

• Enforcing Our Terms: We use data to investigate and take action against users who violate our Terms of Use or engage in illegal activities on the platform. This could include sharing information with law enforcement (see Section 4) or blocking users after analysis.

• Legal Defense: If a dispute arises or legal claim is asserted, we may use personal data relevant to the incident (such as communication records or transaction logs) as evidence to defend ourselves or address the issue, consistent with due process.

We will not use your personal data for purposes that are incompatible with those described above without obtaining your permission, unless such use is otherwise permitted or required by law. If we need to process your personal data for a new purpose that is not detailed in this Policy, we will notify you and obtain consent when required.