Mind Network Airdrop Privacy Policy
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Effective Date: April 3, 2025
Last Updated: April 4, 2025
Introduction and Scope
This Privacy Policy ("Policy") describes how Mind Network ("Mind Network," "we," "us," or "our"), as the data controller, collects, uses, stores, shares, and protects your information when you interact with or participate in the (the "Airdrop").
We are committed to protecting your privacy and handling your data in an open and transparent manner. Participation in the Airdrop is subject to this Policy and the accompanying FHE Token Airdrop Terms of Service ("Terms"). By participating in the Airdrop, you acknowledge you have read and understood this Policy.
This Policy specifically covers information collected in the context of the Airdrop. It does not necessarily cover data processing activities outside of this specific campaign, which may be governed by other Mind Network privacy policies.
Information We Collect
In connection with the Airdrop, we may collect the following categories of information:
a. Blockchain Information (Pseudonymous Data):
Your public blockchain wallet address(es) that you connect or provide for participation.
Publicly available on-chain transaction data and history associated with your provided wallet address(es), particularly interactions relevant to Mind Network eligibility criteria (e.g., staking, transaction history, specific token holdings).
Note: This information is publicly accessible on the blockchain, but we collect and process it specifically for Airdrop purposes.
b. Voluntarily Provided Information (Potentially Personal Data):
Social media identifiers (e.g., Twitter handle, Discord ID) if you choose to connect these accounts or participate in specific social tasks or referral programs requiring them. Provision is optional and based on your explicit action.
Centralized Exchange (CEX) account identifiers (e.g., User ID) or proof of transaction (e.g., deposit confirmation screenshot) only if you voluntarily submit this information for specific verification purposes outlined by the Airdrop campaign rules.
Provision is optional and based on your explicit action.
c. Automatically Collected Information (Technical Data):
IP address(es) used to interact with Airdrop interfaces or systems.
Device metadata (e.g., browser type, operating system, device type) associated with your interaction. This information is primarily collected for security purposes, such as fraud detection, bot prevention (e.g., identifying duplicate entries from the same source), and ensuring the integrity of the Airdrop.
How We Use Your Information (Purpose of Processing)
We collect and process your information for the following specific purposes:
a. Airdrop Administration:
To verify your eligibility to participate in the Airdrop according to the criteria set forth in the Terms.
To calculate and determine potential Token allocations.
To facilitate the distribution or claiming process of FHE Tokens to eligible wallet addresses.
b. Security and Fraud Prevention:
To detect, prevent, and investigate fraudulent activities, Sybil attacks (multiple account abuse), bot usage, and other violations of the Terms.
To maintain the security and integrity of the Airdrop process and our systems.
c. Improvement and Analytics:
To analyze Airdrop campaign effectiveness and participation trends (often using aggregated or anonymized data).
To understand user engagement and improve future community initiatives or product features.
d. Compliance:
To comply with applicable legal and regulatory obligations, potentially including sanctions screening or responding to lawful requests from authorities (subject to legal review).
We will only use your information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose and legally permissible.
Data Sharing and Disclosure
We uphold strict confidentiality standards and do not sell your personal data. We may share your information only in the following limited circumstances:
a. Service Providers: We may share necessary information with trusted third-party service providers who assist us in operating the Airdrop. This may include providers for:
Data analytics (for campaign analysis).
Security services (for fraud and bot detection).
Cloud hosting and infrastructure.
Verification services (if specific KYC/AML checks become necessary, subject to prior notification and consent where required).
These providers are contractually obligated to protect your data, use it solely for the purposes we specify, and comply with relevant data protection laws.
b. Legal Requirements: We may disclose your information if required to do so by law, regulation, court order, or other governmental authority request, or if we believe in good faith that such disclosure is necessary to:
Comply with a legal obligation.
Protect and defend the rights or property of Mind Network.
Prevent or investigate possible wrongdoing in connection with the Airdrop.
Protect the personal safety of users or the public.
c. Aggregated/Anonymized Data:
We may share aggregated or anonymized data (which cannot identify you) for research, analysis, or public reporting purposes.
d. Blockchain Data:
Information recorded on the blockchain (wallet addresses, transaction history) is inherently public.
Data Security
We implement robust technical and organizational security measures designed to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:
Encryption of sensitive data where applicable (both in transit and at rest).
Access controls to limit data access to authorized personnel on a need-to-know basis.
Regular security assessments and updates.
Secure development practices.
However, please note that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are also responsible for maintaining the security of your wallet and any credentials used to interact with the Airdrop.
Data Retention
We will retain your information only for as long as necessary to fulfill the purposes for which it was collected, including for the duration of the Airdrop, distribution, any applicable vesting periods, and as required to satisfy any legal, accounting, or reporting requirements. Once the information is no longer necessary for these purposes, we will securely delete or anonymize it, except where retention is mandated by law. Blockchain data, by its nature, remains permanently on the public ledger.
International Data Transfers
Mind Network may operate globally, and your information might be processed in jurisdictions outside of your country of residence (including Singapore), where data protection laws may differ. We will ensure that appropriate safeguards (such as Standard Contractual Clauses or adequacy decisions, where applicable) are in place for any international transfers of personal data, providing a level of data protection comparable to that required within Singapore or other relevant jurisdictions like the EU (if GDPR applies).
Your Data Protection Rights
Depending on your jurisdiction (e.g., Singapore under the PDPA, potentially GDPR for EU residents), you may have certain rights regarding your personal data. These may include the right to:
a. Access: Request access to the personal data we hold about you.
b. Correction: Request correction of inaccurate or incomplete personal data.
c. Withdraw Consent: Withdraw consent previously given for processing optional data (like social media links). Withdrawal does not affect the lawfulness of processing based on consent before its withdrawal. Note: Withdrawing consent for essential data processing may impact your eligibility for the Airdrop.
d. Erasure/Deletion: Request the deletion of your personal data, subject to certain exceptions (e.g., where retention is necessary for compliance or legal claims). Note: Requesting deletion may result in forfeiture of Airdrop eligibility or rewards. Furthermore, data on the public blockchain cannot be deleted.
e. Object to Processing: Object to processing based on legitimate interests under certain circumstances.
f. Data Portability: Request the transfer of your personal data to another party in a structured, commonly used format (where technically feasible and legally applicable).
To exercise these rights, please contact us using the details provided in Section 12. We may need to verify your identity before processing your request. We will respond to your request within the timeframes mandated by applicable law.
Cookies and Tracking Technologies
If the Airdrop involves interaction with a Mind Network website or web application, we may use cookies, pixel tags, and similar tracking technologies. These are used to:
Ensure the functionality and security of the web interface.
Improve user experience.
Gather analytics data about usage patterns (often anonymized).
Help detect and prevent fraudulent activity and bot traffic.
You can typically manage your cookie preferences through your web browser settings. Disabling certain cookies may affect the functionality of the Airdrop interface.
Children's Privacy
The Airdrop is not intended for individuals under the age of 18 or the age of legal majority in their jurisdiction. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child, we will take steps to delete such information promptly.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or Airdrop mechanics. We will notify you of any material changes by updating the "Last Updated" date at the top of this Policy and potentially through announcements on the Airdrop page or official Mind Network communication channels (e.g., Discord, Twitter). We encourage you to review this Policy periodically. Your continued participation in the Airdrop after any changes constitutes your acceptance of the revised Policy.
Contact Us
Should you have any questions about our privacy practices or this Airdrop Privacy Policy, please email us at [email protected].