Valhalla

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Privacy Policy

Last updated on February 25, 2025


This Privacy Policy (“Policy”) for Green Candle Fdn, (“Company,” “we,” “us,” or “our”) sets out the basis on which we may handle personal data collected from users of the Company’s website, app.valhalla.exchange, including any subdomains (“Website”), in accordance with the relevant law. Under applicable data-protection regulations, the Company is the controller. In this Policy, “you” and “your” refer to any user of the Website. Please read this Policy thoroughly so that you understand your rights relating to your personal data and our collection, usage, and processing of that data. If you disagree with any aspect of this Policy, do not use, access, connect to, or otherwise interact with the Website, nor provide us with any of your information.


PERSONAL DATA WE COLLECT, WHY WE PROCESS IT, AND OUR LEGAL BASIS When you use, visit, connect to, or otherwise interact with the Website, we may gather certain information about you, which may be considered personal data, from various sources.


Information You Provide

  • Wallet and Geolocation Data. This may include: (i) addresses associated with digital assets, smart contracts, or related protocols (“Wallet”); and (ii) details regarding your location. You voluntarily provide such data when you link your Wallet to the Website.
  • Transaction or Interaction Data. This may involve blockchain transaction records (e.g., public transaction histories, addresses, and token balances). If you reach out to us, we will collect any details you share in those communications, which could include the email address used to contact us.

Information Collected Automatically

  1. When you browse certain sections of our Website, our servers log each visit. This data might include:
  2. The date and time of access;
  3. The country from which the Website is accessed;
  4. Any API endpoints accessed;
  5. User agent details;
  6. Your computer’s operating system and browser (version, language, etc.); and
  7. The transfer protocol used (e.g., HTTP/1.1).

We may also utilize web beacons or clear gifs, geolocation features, and other tracking methods when you visit the Website, potentially through third-party services. Such data (“Usage Data”) may be aggregated, anonymized, or de-identified to further our legitimate interests in operating the Website effectively.


Third-Party Wallet Connections and Disclaimer

Certain Website functionalities require you to link a compatible external digital Wallet. By doing so, you accept that your use of the third-party Wallet is subject to that provider’s individual terms and privacy policy. We disclaim any responsibility for incidents stemming from your usage of such Wallets, including any related disclosures of personal data by those third-party services.


Legal Basis for Processing

We generally process personal data to perform our contract with you. For instance, we collect and process data so that you can connect to and interact with the Website and to determine whether you might be a “Restricted Person,” as set out in our Terms of Use at app.valhalla.exchange/terms. Where required, we do so both to provide services to you and in our legitimate interests to grant access to the Website.

With your explicit consent, we may use collected data, including Usage Data, to personalize and optimize the Website’s features and presentation for your device. We may also run analytics to learn how you engage with the Website and enhance your overall user experience.

Additionally, we may process data in our legitimate interests to preserve system security and stability, address troubleshooting issues, conduct internal research, and refine the Website’s usability and performance. We may also process data to comply with legal obligations, enforce any relevant terms, and protect the Website, our rights, and the rights of our users or others.


COOKIE POLICY

We use strictly necessary cookies to improve your experience on the Website and for operational reasons (such as supporting compliance with our Terms of Use). These cookies are not utilized for marketing. By continuing to use the Website, you consent to their placement on your device.


YOUR RIGHTS

Depending on applicable data-protection laws, you may have some or all of the following rights regarding your personal data:

  1. Access: Request to see the personal data we hold about you and learn how it’s used or shared.
  2. Rectification: Request that we update any inaccurate or incomplete personal data, subject to verification.
  3. Erasure: Ask for the deletion of your personal data in certain circumstances.
  4. Objection: Oppose specific processing activities, again subject to certain conditions.
  5. Restriction: Limit how we process your personal data (beyond merely storing it) in certain situations.
  6. Portability: Obtain a copy of your personal data and/or transfer it to a third party in a structured format.
  7. Withdraw Consent: Where consent is the basis for processing, you may withdraw that consent at any time (this withdrawal will not invalidate previously lawful processing).

You can submit written requests concerning the processing of your personal data by emailing support@valhalla.exchange. Before we respond, we may require you to verify your identity. We may also have valid legal grounds to refuse certain requests, in which case we will inform you accordingly.

Please remember these rights are not universally applicable and may be limited by relevant laws. For instance, there may be situations where the rights of other individuals, trade secrets, or legal obligations take priority over your request. Where obligated by law, we will address your requests in a timely manner and within any legally mandated timeframe (commonly one month, possibly extendable by two additional months in certain scenarios).


SHARING OF PERSONAL DATA

We may share your information with third parties under specific circumstances (with your consent or where permitted or required by law), including:

  • Service Providers and Vendors. We might share personal data with entities that process it on our behalf—for instance, blockchain analysis providers, screening tools, developers, or analytics providers. They could help us, for example, with geo-restriction measures via IPdata or anonymized device data collection through Mixpanel.
  • Professional Advisors. We may share data with advisors as part of normal business operations or when legally required.
  • Legal, Security, and Protection. We may share data as necessary to fulfill legal obligations or to protect the Website and its users, in line with our legitimate interests or the law.

Your personal data may be transferred and/or stored in regions outside your residence, including outside the European Economic Area (“EEA”) or United Kingdom (“UK”), for the purpose of providing the Website. Staff working outside of the EEA/UK may also handle your data. We will take reasonable steps to ensure your personal information is protected consistent with this Policy. If we transfer your data outside the EEA/UK, we will seek to implement appropriate safeguards, such as standard contractual clauses (“SCCs”) or equivalent arrangements, unless transferring the data to a jurisdiction already recognized for adequate personal data protections.


RETENTION

We will retain your personal data only as long as necessary to fulfill the purposes for which it was collected—including meeting legal, accounting, or compliance obligations. The retention period varies based on the nature of the data and how we use it.


CHILDREN’S PRIVACY

If we learn that we have inadvertently gathered personal data from a person under eighteen (18) years of age, we will take reasonable steps to delete that data promptly.


SECURITY MEASURES

While we strive to protect your personal data through various security measures, no method of electronic transmission or storage is completely secure. Any information you transmit is at your own risk. We cannot guarantee absolute protection of personal data sent through the Website.


USAGE DATA COLLECTION

By accessing, using, connecting to, or interacting with the Website, you acknowledge that both the Company and approved third-party providers may receive, record, and process personal data that you supply and associated digital signatures.


SOCIAL MEDIA AND EXTERNAL LINKS

We may include links on the Website leading to third-party sites or social media platforms (e.g., X (formerly Twitter), Medium). We do not control these third-party sites and are not responsible for the accuracy, privacy, security, or reliability of the content or services they offer. You should review these platforms’ terms and privacy practices before using them. Our providing such links does not signify any endorsement unless expressly stated on the Website.

Similarly, other third parties and contributors to the broader Valhalla ecosystem may operate tools, dashboards, or services linked from time to time via the Website or social media. These are external, independent entities, and we are not responsible for their content, privacy policies, or reliability.

By clicking a link to a social media platform, a direct connection can be established between your browser and that platform’s servers, possibly linking your Website visit to your account on that platform. To prevent this, log out of your social media accounts before clicking any such links.


PERIODIC REVIEWS AND POLICY UPDATES

This Policy accounts for Panama’s Law No. 81 of 2019 on Personal Data Protection and various general privacy norms. Depending on your location, additional rights may apply under the EU General Data Protection Regulation (GDPR) or the UK GDPR. You can also file complaints with the supervisory authority in your EEA country of residence or with the UK Information Commissioner’s Office, as appropriate.

We may revise this Policy periodically. Updates will only affect information gathered after the revised Policy’s publication date. In the event of substantial modifications, we will update the “Last updated” date above.


CONTACT

If you have any queries or concerns about how we handle personal data or about this Policy in general, please contact us at support@valhalla.exchange.