Tread Safely Inc (“Safely”, “we”, “us”, or “our”) is committed to protecting your privacy and handling your personal information with transparency and care.

This Privacy Policy describes how we collect, use, store, and disclose Personal Information when you access or use our website, mobile applications, software, or related services (collectively, the “Services”). This Privacy Policy is incorporated by reference into the Safely Terms of Service (the “Terms”) and should be read in conjunction with the Terms. Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms.

By accessing or using the Services, you acknowledge that you have read and accepted this Privacy Policy. If you do not agree with this Policy, you must not access or use the Services.

1. Information We Collect

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to an identified or identifiable individual or household. Personal Information does not include publicly available information, deidentified information, or aggregated information that cannot reasonably be used to identify you.

Information You Provide

Because our wallet is a non-custodial cryptocurrency wallet, you are generally not required to provide personal information (name, email, phone number, etc) in order to download, install, or use the wallet’s core functionality. If you do not agree with the terms of this Privacy Policy, you should discontinue use of the Services. If, at any time in the future, you decide that you no longer agree with this Privacy Policy, you must discontinue your access to and use of the Services.

Non-Custodial Nature of Services. Safely provides non-custodial wallet services, meaning we do not have access to, and cannot recover, your private keys, seed phrases, or passwords. You are solely responsible for maintaining the security and confidentiality of your private keys, seed phrases, passwords, and any credentials associated with your wallet, as well as the devices used to access the Services. If you lose access to your private keys or seed phrases, we cannot restore access to your wallet or recover any digital assets. Security risks inherent in blockchain technology, including smart contract vulnerabilities, phishing attacks, and network attacks, are outside our control.

The information we collect depends on how you interact with our Services. You may choose to provide different types of information depending on the way you communicate with us.

Communications: When you contact us through email, contact forms, live chat, or other communication channels, we collect the information you submit, including your contact details and the content of your messages.

Customer Support: If you request assistance, we may collect information necessary to investigate and resolve your issue, including your contact information, device or application details, and any information you share about your support request.

Additional Information: You may voluntarily provide other information, such as cryptocurrency wallet addresses, transaction-related details, feedback, survey responses, or any other information you choose to share while using our Services.

Data Collected Automatically

Blockchain Data

When you use our Services to interact with blockchain networks, certain information may be publicly recorded on the applicable blockchain, including your public wallet address, transaction details, token balances, and smart contract interactions. This information is publicly visible on the blockchain and cannot be deleted, modified, or controlled by Safely. We do not control the blockchain networks and cannot ensure the privacy of on-chain transaction data.

Blockchain analytics providers, law enforcement, or other third parties may be able to link your public wallet address to your identity or other information through analysis of on-chain data, IP addresses, or other means. We encourage you to review and understand the privacy implications of using public blockchain networks.

Device and Technical Data

When you access or use our Services, certain information may be collected automatically to help us operate, maintain, and improve the user experience. This information may include your IP address, account ID (a unique ID for Safely’s internal use), approximate geographic location (such as your city or region), wallet address, browser type and version, device country, operating system, device type, device identifiers, screen resolution, language preferences, hardware information, application version and language, store country, usage activity, pages or features accessed, timestamps, application performance data, crash reports, and other technical or diagnostic information related to your interactions with the Services. In some circumstances, this information may be capable of identifying you or your device.

When you broadcast transactions through our Services, we may collect your public wallet address, transaction hash, transaction details, gas fees, and related metadata. This information may be associated with other data we collect, such as your IP address and device information.

Cookies and Tracking Technologies

We and our service providers may use cookies, web beacons, pixels, local storage, and similar tracking technologies to collect information about your interactions with the Services. These technologies serve the following purposes:

Strictly Necessary: Essential for the operation of the Services, including security, authentication, and fraud prevention. These cannot be disabled without affecting core functionality.

Performance and Analytics: Used to understand how users interact with the Services, measure performance, and analyze usage trends to improve the user experience.

Functional: Used to remember your preferences and settings, such as language, region, and display preferences.

You may manage your cookie preferences through your browser settings. Most web browsers allow you to manage or delete cookies through browser settings. Please note that disabling cookies may affect the functionality of the Services.

Where supported by your device or browser, we may determine your approximate location based on technical information such as your IP address. This information is used for purposes such as improving service performance, security, regulatory requirements, analytics, and delivering a more relevant user experience.

Third-Party Analytics

We may use third-party analytics providers to evaluate usage of our Services. These providers may collect usage and analytics data, including pages viewed, features used, clickstream data, session duration, referring and exit URLs, frequency of visits, interaction patterns, and other information about how you use the Services.

2. How We Use Your Information

We may use the Personal Information we collect for a variety of legitimate business and operational purposes, including to:

3. Disclosure

We do not sell your Personal Information. We may disclose or share your Personal Information only in the circumstances described below:

Affiliated Entities: We may share your information with our parent company, subsidiaries, or other affiliated entities when necessary to operate, support, or improve our Services.

Analytics Providers: We may work with third-party analytics providers, such as Google Analytics, to better understand how users interact with our Services and to improve their performance and functionality.

Blockchain Network Participants: When you initiate transactions through our Services, certain information (including your public wallet address and transaction data) is transmitted to blockchain networks and may be visible to validators, miners, node operators, and other network participants. This information becomes part of the public blockchain record.

RPC Providers: To enable blockchain interactions, we may use remote procedure call (RPC) providers to transmit your transactions and retrieve blockchain data. These providers may receive your IP address, wallet address, and transaction data. We select RPC providers that maintain appropriate security and privacy practices.

Legal, Regulatory, and Government Requirements: We may access, use, preserve, or disclose your Personal Information to governmental bodies, law enforcement agencies, courts, regulatory authorities, or other parties when we reasonably believe it is necessary to comply with applicable laws, regulations, legal proceedings, or government requests, or to protect our rights, users, property, or the security and integrity of our Services.

Professional Advisors: We may share Personal Information with our legal counsel, auditors, accountants, consultants, and other professional advisors in connection with their provision of services to us.

Business Transactions: If we are involved in a merger, acquisition, financing, asset sale, restructuring, bankruptcy, or another corporate transaction, your Personal Information may be transferred or disclosed as part of that process, subject to applicable legal requirements.

Service Providers: We may share information with trusted third-party vendors, contractors, infrastructure providers, payment processors, API providers, and other service providers that perform services on our behalf or support the operation of our Services.

All service providers engaged by us process personal data on our behalf and in accordance with our instructions, subject to data processing agreements and appropriate security measures. These providers are contractually prohibited from using your Personal Information for their own purposes, including marketing or advertising.

With Your Authorization: We may disclose your Personal Information to other parties when you direct us to do so or otherwise provide your consent.

4. Legal Bases for Processing (EEA)

If you reside in the European Economic Area (EEA), we process your Personal Information only where we have a lawful basis to do so under applicable data protection laws, including the EU General Data Protection Regulation (“EU GDPR”). These legal bases may include:

We process personal data of EEA individuals on the legal bases described above. Where we rely on legitimate interests, we have conducted a balancing test to ensure that our interests are not overridden by your fundamental rights and freedoms.

5. Your Rights Under EEA Data Protection Law

If you are located in the EEA, you have the following rights under applicable data protection laws in addition to the rights described elsewhere in this Privacy Policy:

6. International Data Transfers

If you access or use the Services from outside the United States, you acknowledge that your Personal Information may be transferred to, processed, and stored in the United States, where data protection laws may differ from, and in some cases provide a lower level of protection than, those in your country of residence.

International Transfers from the EEA

Where we transfer Personal Information outside the EEA, we implement appropriate safeguards as required by applicable data protection law. Such safeguards may include:

You may request a copy of the relevant transfer mechanism by contacting us at support@safely.app.

7. Data Security

We implement appropriate technical and organizational measures to protect your Personal Information from unauthorized access, use, disclosure, alteration, or destruction. These measures include, where appropriate, TLS encryption in transit, encryption at rest, role-based access controls, multi-factor authentication on administrative accounts, firewalls, web application firewall protections, secure development practices, and periodic security assessments.

Although we strive to use commercially reasonable security measures, no method of transmitting data over the Internet or storing information electronically can be guaranteed to be completely secure. As a result, we cannot guarantee the absolute security of your information.

If you believe that your Personal Information has been compromised or that the security of your interactions with our Services has been affected, please notify us promptly so that we can investigate and take appropriate action.

In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the relevant supervisory authority and, where required by applicable law, notify affected individuals without undue delay.

8. Data Retention

We retain your Personal Information only for as long as necessary to fulfill the purposes described in this Privacy Policy, provide and maintain the Services, comply with applicable legal, regulatory, and compliance obligations, prevent fraud and maintain security, resolve disputes and enforce our agreements, or support legitimate business purposes such as analytics and service improvement, unless a longer retention period is required or permitted under applicable law. We may also retain certain information where necessary to establish, exercise, or defend legal claims, resolve disputes, comply with legal or regulatory obligations, or participate in investigations or legal proceedings.

Blockchain Data Retention: Information recorded on public blockchain networks persists indefinitely and is outside the control of Safely. We cannot delete, modify, or restrict access to on-chain transaction data. Your deletion requests under applicable privacy laws apply only to data within our control and do not affect data recorded on blockchain networks.

9. Third-Party Services

Our Services may include links to, or integrations with, third-party websites, applications, APIs, or other services that are owned and operated by independent organizations. We do not control these third parties or their privacy, security, or data handling practices, and this Privacy Policy does not apply to any information you provide to them or that they collect through their services. We recommend reviewing the privacy policies and terms of any third-party service before sharing your Personal Information or connecting your account or wallet.

Third-Party Blockchain Networks and Protocols

Our Services enable you to interact with third-party blockchain networks, decentralized applications (dApps), decentralized finance (DeFi) protocols, smart contracts, and other third-party services. These third-party services operate independently and are not controlled by Safely. When you interact with such services through our wallet, you may be subject to their separate terms and privacy policies. We are not responsible for the privacy practices, security, or content of third-party blockchain networks, dApps, or protocols.

Connecting your wallet to third-party dApps or protocols may expose your wallet address and transaction history to those third parties. Some dApps may request additional permissions or access to your wallet data. You should carefully review the permissions requested by any dApp before connecting your wallet.

10. Your Privacy Rights

You may contact us to request access to the Personal Information we hold about you, or to ask that we update, correct, or delete such information where applicable. We will make reasonable efforts to respond to and fulfill eligible requests in accordance with applicable data protection laws. In certain situations, we may be required to retain specific information to satisfy legal, regulatory, accounting, security, or legitimate business obligations, as permitted by applicable law.

11. Complaints and Supervisory Authorities

We are committed to addressing and resolving concerns regarding our handling of your Personal Information. If you have any questions, concerns, or complaints about this Privacy Policy or the way we collect, use, or process your Personal Information, please contact us at support@safely.app. We will review your complaint and provide a response within thirty (30) days.

If you are located in the EEA and believe your data protection rights have not been adequately addressed, you have the right to lodge a complaint with your local supervisory authority. A list of EEA supervisory authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.

12. Changes to This Privacy Policy

We may update or modify this Privacy Policy from time to time to reflect changes in applicable laws, our privacy practices, the way we collect or use information, or improvements in technology. Any updated version of this Privacy Policy will be made available through our Services, and we encourage you to review it periodically to stay informed about how we protect and process your Personal Information. The “Last Updated” date displayed at the beginning of this Privacy Policy indicates when the most recent changes were made.

By continuing to access or use our Services after any updates become effective, you acknowledge that you have reviewed and understood the revised Privacy Policy.

13. Children’s Privacy

Our Services are not directed to, and we do not knowingly collect Personal Information from, children under the age of 13 (or such other age as may be specified by applicable law, including 16 in certain jurisdictions). Furthermore, our Services are intended for use only by individuals who are at least 18 years of age or the age of legal majority in their jurisdiction of residence, whichever is greater. In accordance with applicable children’s privacy laws, including the Children’s Online Privacy Protection Act (COPPA), if we become aware that we have collected Personal Information from a child under the age of 13 without verified parental consent, we will take steps to delete such information promptly. If you believe we have inadvertently collected information from a child under 13, please contact us at support@safely.app.

14. U.S. State Privacy Rights

Certain U.S. states have adopted privacy laws that provide residents with specific rights regarding their Personal Information. If you live in a state with applicable privacy protections, including California, Colorado, Virginia, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive consumer privacy laws, this section describes those rights and our related practices.

We are committed to protecting your privacy and handling your data in accordance with applicable data protection laws, including the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA/CPRA”), the Virginia Consumer Data Protection Act (“VCDPA”), the Colorado Privacy Act (“CPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Texas Data Privacy and Security Act (“TDPSA”), the Oregon Consumer Privacy Act (“OCPA”), the Montana Consumer Data Privacy Act (“MCDPA”), and other applicable U.S. privacy frameworks.

Categories of Personal Information We May Collect: Depending on your use of our Services or how you communicate with us, we may collect categories of Personal Information that include:

We do not sell Personal Information, share Personal Information for cross-context behavioral advertising, or disclose Personal Information for targeted advertising purposes as those terms are defined under applicable state privacy laws.

To the extent that our use of cookies, pixels, or similar tracking technologies constitutes a “sale” or “sharing” of Personal Information under applicable state law, you may opt out of such activities by contacting us at support@safely.app or using the “Do Not Sell or Share My Personal Information” link on our website, if available.

We honor browser-based opt-out preference signals, including the Global Privacy Control (“GPC”), where required by applicable law. When we detect a GPC signal, we will treat it as a valid opt-out request for sales or sharing of Personal Information under applicable state law.

Right to Non-Discrimination: You have the right to exercise your privacy rights without receiving discriminatory treatment or being denied access to services because you submitted a valid privacy request.

Right to Correction: You have the right to request correction of inaccurate Personal Information we hold about you.

Right to Know / Access: You have the right to request information about the categories and specific pieces of Personal Information we have collected about you, the sources of collection, the purposes for collection, and the categories of third parties with whom we share your information.

Right to Deletion: You have the right to request deletion of Personal Information we have collected from or about you, subject to certain exceptions (e.g., where retention is required by law or necessary for security or compliance purposes).

Right to Data Portability: You have the right to request a copy of your Personal Information in a portable, readily usable format, where technically feasible.

Right to Opt-Out of Sale/Sharing: You have the right to opt out of the “sale” or “sharing” of your Personal Information for targeted advertising purposes, as those terms are defined under applicable state law.

Right to Limit Use of Sensitive Personal Information: Where applicable law provides, you may direct us to limit our use and disclosure of sensitive personal information to purposes permitted under applicable law.

Right to Appeal: If we decline to fulfill your privacy request, you may have the right to appeal our decision by contacting us using the methods provided in this Privacy Policy.

Authorized Representatives: You may designate an authorized agent to submit a privacy request on your behalf. We may require that you provide written authorization and verify your identity directly, or that the authorized agent provide proof of a valid power of attorney.

How to Exercise Your Rights: To submit a privacy rights request, please contact us at support@safely.app. We will verify your identity before processing your request. We will respond to your inquiry or request within the time periods required by applicable law.

15. Contact Us

If you have any questions, comments, or concerns about this Privacy Policy or our privacy practices, please contact us at:

Tread Safely Inc.
Email: support@safely.app
Address: 8 The Green #21969, Dover, DE 19901, USA

For privacy-specific inquiries or to exercise your data protection rights, you may also contact our Privacy Team at: privacy@safely.app

We will respond to your inquiry within a reasonable timeframe and in accordance with applicable law.