Privacy Policy

I. Types of Information We Collect

CICADA collects information that you voluntarily provide, information automatically generated by systems, and information shared by third parties. We only collect data necessary for service delivery, security, and compliance purposes. 1.1 Information You Voluntarily Provide We request identity information (KYC) only when essential, such as for Real World Asset (RWA) modules, statutory regulatory requirements, sanctions screening, or risk management. You may be required to provide the following: (1) Identity and Verification Information

• Full name, date of birth, nationality, residential address;

• Government-issued identification documents (passport/ID card);

• Proof of residence (utility bills, bank statements, tax documents);

• Proof of investment funds and source of wealth;

• For corporate users: registration documents, ownership structure, and authorized representative details.

(2) Contact Information

• Email address, phone number, mailing address, social media handles (e.g., Telegram, X, Discord);

• Notification preferences and language selections.

Standard on-chain functions (e.g., wallet connection, swaps, staking) do not require identification documents or contact details. However, the following may be obtained: (1) On-Chain and Transaction Information

• Wallet addresses, blockchain network types, token interaction records, transaction hashes, staking or bridging operation details;

• Asset types, quantities, transfer and conversion records.

1.2 Automatically Collected Information CICADA and its service providers (e.g., analytics and anti-fraud tools) automatically collect certain device and usage data, including:

• Technical Information: Browser type, operating system, language settings, IP address, access dates and times;

• Device Data: Device model, OS version, screen resolution, device identifiers;

• Website Usage Information: Navigation paths, dwell times, click behaviors, page scrolls, exit pages;

• Location Information: IP-based city or country, for identifying regional compliance restrictions;

• Cookies and Tracking Data: For session identification, preferences, and security validation.

This data is used to enhance performance, detect anomalous activities, and analyze platform usage. 1.3 Blockchain Information Collected Blockchain serves as a shared, immutable ledger for recording asset transactions. In providing services, we may collect current and historical blockchain data directly from individuals, the aforementioned third parties, or public blockchains themselves:

• Account Addresses: Unique blockchain addresses or domains for asset transfers.

• Wallet Information: Wallet providers and wallets linked to specific account addresses.

• Account Balances and Assets: Balances associated with blockchain addresses, along with stored assets linked to the account.

• Transaction Details: Transaction identifiers, blockchain locations, dates and times, transaction types, sent/received amounts, fees, sender/receiver addresses, and storage sizes.

In certain cases, we may combine blockchain information with the above data, such as when you connect a blockchain wallet (e.g., via Coinbase Wallet, WalletConnect, Fortmatic, Ledger, or Trust Wallet) to the services for account address creation and wallet linking. 1.4 Information from Third Parties To ensure compliant and secure services, we may obtain or verify information from:

• Identity verification and compliance service providers (for KYC/AML/CFT);

• Wallet and blockchain data providers (for on-chain transaction identification and risk analysis);

• Analytics and security partners (e.g., Chainalysis, TRM Labs, Nansen);

• Community and social platforms (when you actively interact with CICADA's official accounts);

• Public blockchain data (for asset flows, transaction transparency, and risk modeling).

II. Purposes and Legal Bases for Using Personal Data

We process collected information on lawful bases (including contract performance, legitimate interests, legal obligations, or with your consent), primarily for:

2.1 Service Provision

• Enabling token minting, redemption, conversion, staking, and yield generation;

• Verifying user identities and wallet associations;

• Supporting account logins, KYC processes, and transaction confirmations;

• Facilitating cross-chain bridging, governance voting, and reward distributions.

2.2 Security and Compliance Maintenance

• Adhering to anti-money laundering (AML), counter-terrorist financing (CFT), and sanctions requirements;

• Detecting and preventing fraud, theft, or abusive behaviors;

• Auditing system activities and smart contract interaction logs;

• Providing statutory reports to regulators or assisting in investigations.

2.3 Product and Service Improvement

• Analyzing usage data and user feedback;

• Developing new features, optimizing performance, and enhancing user experience;

• Testing security mechanisms and defense models.

2.4 Communication and Support

• Responding to your inquiries or complaints;

• Delivering system announcements, updates, and security alerts;

• Sending educational content, tutorials, and policy change notifications.

2.5 Marketing and Community Engagement

• Distributing CICADA product updates, event invitations, and educational materials;

• You may opt out at any time via the "unsubscribe" link in email footers.

III. Security and Confidentiality

We employ industry-standard firewalls and encryption systems to safeguard platform data. Technical and organizational measures are implemented to prevent data loss, misuse, unauthorized access, disclosure, alteration, or destruction. CICADA commits to not selling, renting, or misusing user information. We share information only in the following circumstances:

• With Affiliates: For intra-group compliance, technical, and risk management sharing.

• With Service Providers: Such as identity verification, cloud storage, smart contract auditing, analytics, and legal counsel.

• Legal Obligations: When required by regulators or courts under applicable law.

• Asset Transactions: In the event of a merger, reorganization, or acquisition involving CICADA, user information may be transferred as an asset.

• Public Blockchain Data: Your transactions and addresses may be publicly visible.

• With User Consent: For participation in specific projects, airdrops, or collaborative activities.

All third parties are bound by data protection agreements, limiting data use to specified purposes. CICADA retains data in accordance with legal and compliance requirements, typically as follows:

• KYC/Compliance Data: 5–7 years (or as mandated by local regulations);

• Transaction and Blockchain Interaction Records: Permanently stored on-chain (non-deletable);

• System Logs and Security Audit Data: 12–24 months;

• Communication and Customer Service Records: 3 years.

Upon expiration, CICADA will anonymize or delete data as appropriate.

IV. Children's Personal Data

CICADA Finance's services are intended for users aged 18 and above. We do not knowingly collect data from minors under 18. If a minor wishes to use the Platform, it must be with guardian consent. Guardians may request access, modification, or deletion of a minor's personal information.

V. Your Rights

Subject to applicable laws, you have the following rights:

• Access: Request copies of your personal information we hold;

• Rectification: Update or correct inaccurate information;

• Erasure: Request deletion where legally permissible;

• Restriction: Limit processing to specific purposes;

• Portability: Receive a transferable electronic copy;

• Withdrawal of Consent: Revoke authorization for specific processing at any time;

• Complaint: Lodge a complaint with relevant regulatory authorities.

VI. Social Media Interactions

We maintain official accounts on Twitter (X), Medium, Discord, and Telegram for user communication and updates. When engaging with these platforms, you are subject to their respective privacy policies and data handling practices.

VII. Obligation to Provide Data

You are not required to provide any personal data, but in certain cases, such information (e.g., wallet addresses) may be necessary to deliver our services. If you disagree with this Privacy Policy, we may be unable to provide full services.

VIII. Changes to the Privacy Policy

We may update this Privacy Policy based on business needs and legal requirements. Please review it periodically for the latest version.Updates will take effect via website announcements. Continued use post-update constitutes acceptance.

IX. Inquiries and Complaints

If you have questions or complaints about this Privacy Policy, please contact us. We will strive to ensure your data privacy is adequately protected.If you have any questions about this agreement or wish to exercise your statutory rights, contact us. We will respond within a reasonable timeframe under applicable law. Feel free to reach out via official social channels.

Email: [e-mail]

X: https://x.com/CicadaFinance