Privacy Policy

Last updated: March 26, 2026

1. Introduction

FrenFlow Projects Ltd ("FrenFlow," "Company," "we," "us," or "our"), an International Business Corporation (IBC) registered in Nevis under number C 63555, with its registered office at Suite 5, Horsford's Business Centre, Long Point Road, Charlestown, Nevis, is the data controller responsible for the processing of your personal data when you use our platform at https://www.frenflow.com and related services (the "Platform").

This Privacy Policy explains how we collect, use, store, share, and protect your personal information. We are committed to processing personal data in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR") where applicable, and other relevant data protection legislation.

By accessing or using the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with our data practices, please do not use the Platform.

2. Data Controller

  • Entity: FrenFlow Projects Ltd
  • Registration: IBC No. C 63555, Nevis
  • Address: Suite 5, Horsford's Business Centre, Long Point Road, Charlestown, Nevis
  • Email: [email protected]
  • Data Protection Contact: [email protected]

3. Data We Collect

3.1 Account Data

When you create an account or use authentication services, we may collect:

  • Email address
  • Username or display name
  • Profile picture (if provided)
  • Authentication provider identifiers (e.g., Google account ID, Telegram user ID, Twitter/X account ID)
  • Account preferences and settings

3.2 Blockchain and Wallet Data

When you connect a wallet or interact with blockchain-related features, we may collect:

  • Public blockchain wallet addresses
  • Transaction hashes and publicly available on-chain transaction data
  • Portfolio positions, trade history, and related analytics derived from public blockchain data

We do NOT collect or store private keys, seed phrases, or wallet passwords. All wallet connections are facilitated through third-party authentication providers (e.g., Privy) and we never have access to your private credentials.

3.3 Usage Data

We automatically collect certain information about your use of the Platform:

  • Pages visited, features used, and actions taken within the Platform
  • Referral source and navigation paths
  • Date, time, and duration of visits
  • Search queries and filter selections
  • Interaction with notifications and alerts

3.4 Device and Technical Data

  • IP address
  • Browser type and version
  • Operating system and device type
  • Screen resolution and viewport size
  • Language and timezone settings
  • Unique device identifiers

3.5 Communication Data

When you contact us or interact with community features:

  • Support request content and correspondence
  • Community posts, comments, and social interactions on the Platform
  • Feedback and survey responses

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

  • Contractual Necessity (Art. 6(1)(b) GDPR): Processing necessary for the performance of our Terms of Service, including account creation, service delivery, and platform functionality.
  • Legitimate Interests (Art. 6(1)(f) GDPR): Processing necessary for our legitimate interests, including platform security, fraud prevention, analytics to improve the Platform, and business operations, where such interests are not overridden by your rights and freedoms.
  • Consent (Art. 6(1)(a) GDPR): Where you have given explicit consent, such as for marketing communications, non-essential cookies, or optional data processing features. You may withdraw consent at any time.
  • Legal Obligations (Art. 6(1)(c) GDPR): Processing necessary to comply with applicable legal requirements, including tax reporting, regulatory obligations, and responding to lawful requests from authorities.

5. Purposes of Processing

We use your personal data for the following purposes:

  • Service Provision: To create and manage your account, provide platform features, display analytics and market data, and facilitate community interactions.
  • Platform Improvement: To analyze usage patterns, identify technical issues, optimize performance, and develop new features.
  • Security: To detect, prevent, and address fraud, abuse, security incidents, and violations of our Terms.
  • Communication: To send service-related notifications, respond to support requests, and provide updates about the Platform.
  • Legal Compliance: To comply with applicable laws, regulations, and legal processes.
  • Analytics: To understand how the Platform is used and to generate aggregated, anonymized statistical data.

6. Cookies and Tracking Technologies

6.1 Types of Cookies

We use the following categories of cookies and similar technologies:

  • Strictly Necessary Cookies: Essential for the Platform to function, including authentication tokens, session management, and security features. These cannot be disabled.
  • Functional Cookies: Used to remember your preferences, settings, and choices (e.g., dark mode, sidebar state, language preferences).
  • Analytics Cookies: Used to collect information about how you interact with the Platform, helping us improve performance and user experience. These may include third-party analytics services.

6.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to block or delete cookies. However, disabling certain cookies may affect the functionality of the Platform. For more information, consult your browser's help documentation.

7. Third-Party Services

We use the following categories of third-party services that may process your data:

  • Authentication Providers (Privy): To manage user authentication, wallet connections, and account security. Privy processes your authentication data pursuant to its own privacy policy.
  • Analytics Services: To understand Platform usage and improve our services. These services collect usage and technical data in anonymized or pseudonymized form.
  • Infrastructure Providers: Cloud hosting, content delivery, and database services necessary to operate the Platform.
  • Blockchain Data Providers: Services that provide public blockchain data, transaction information, and market data from prediction market protocols.
  • Communication Services: Email delivery, push notifications, and messaging services for service-related communications.

We require all third-party processors to handle your data in accordance with applicable data protection laws and our contractual obligations. We do not sell your personal data to third parties.

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

  • Account Data: Retained for the duration of your account and for up to 12 months after account deletion, to comply with legal obligations and resolve disputes.
  • Usage and Analytics Data: Retained in identifiable form for up to 24 months, after which it is anonymized or deleted.
  • Communication Data: Support correspondence retained for up to 36 months after resolution. Community content retained for the lifetime of the Platform or until you delete it.
  • Technical/Log Data: Retained for up to 12 months for security and debugging purposes.
  • Legal Compliance Data: Retained for the period required by applicable law (typically 5-7 years for tax and regulatory records).

Upon expiration of the retention period, data is securely deleted or irreversibly anonymized.

9. Your Rights

Under applicable data protection laws (including GDPR where applicable), you have the following rights:

  • Right of Access (Art. 15 GDPR): You may request confirmation of whether we process your personal data and, if so, access to that data along with supplementary information about the processing.
  • Right to Rectification (Art. 16 GDPR): You may request correction of inaccurate personal data or completion of incomplete data.
  • Right to Erasure (Art. 17 GDPR): You may request deletion of your personal data where there is no compelling reason for continued processing, subject to legal retention obligations.
  • Right to Restriction (Art. 18 GDPR): You may request that we restrict processing of your personal data in certain circumstances, such as when accuracy is contested.
  • Right to Data Portability (Art. 20 GDPR): You may request to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
  • Right to Object (Art. 21 GDPR): You may object to processing based on legitimate interests or for direct marketing purposes.
  • Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of prior processing.
  • Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe your data protection rights have been violated.

To exercise any of these rights, please contact us at [email protected]. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

10. Children's Privacy

The Platform is not intended for individuals under the age of eighteen (18). We do not knowingly collect personal data from children under 18. If we become aware that we have collected personal data from a child under 18, we will take steps to delete such data promptly. If you believe that a child under 18 has provided us with personal data, please contact us at [email protected].

11. International Data Transfers

Your personal data may be transferred to and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home country. When we transfer personal data internationally, we implement appropriate safeguards, including:

  • Standard Contractual Clauses (SCCs) approved by the European Commission, where applicable.
  • Ensuring that recipients are located in countries recognized as providing adequate data protection.
  • Contractual obligations requiring third-party processors to implement appropriate technical and organizational security measures.

By using the Platform, you acknowledge and consent to the transfer of your data as described in this section, subject to the safeguards outlined above.

12. Security Measures

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. These measures include but are not limited to:

  • Encryption of data in transit (TLS/SSL) and at rest.
  • Access controls and authentication requirements for systems processing personal data.
  • Regular security assessments and monitoring.
  • Employee training on data protection and security best practices.
  • Incident response procedures for data breaches.
  • Secure data storage with reputable cloud infrastructure providers.

While we take reasonable measures to protect your data, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security and are not liable for breaches beyond our reasonable control.

13. Automated Decision-Making

The Platform may use automated processing to provide analytics, rankings, and data visualizations. These automated processes do not make decisions that produce legal effects or similarly significant effects on you. If we introduce any automated decision-making that materially affects you, we will provide appropriate notice and safeguards, including the right to obtain human intervention.

14. Do Not Track Signals

Some browsers offer a "Do Not Track" ("DNT") setting. As there is no industry-standard interpretation of DNT signals, the Platform does not currently respond to DNT signals. We will update this policy if a standard for responding to DNT signals is established.

15. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will:

  • Update the "Last updated" date at the top of this policy.
  • Provide notice through the Platform or via email for significant changes.
  • Where required by law, obtain your consent before applying material changes to data already collected.

We encourage you to review this Privacy Policy periodically. Your continued use of the Platform after changes take effect constitutes acceptance of the updated policy.

16. Contact Information

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

  • General Inquiries: [email protected]
  • Privacy/Data Protection: [email protected]
  • Postal Address: FrenFlow Projects Ltd, Suite 5, Horsford's Business Centre, Long Point Road, Charlestown, Nevis

We aim to respond to all legitimate requests within 30 days. In exceptional circumstances, it may take longer, in which case we will notify you and provide an explanation.