Legal

Privacy Policy

Updated

This Privacy Policy describes how Leigon Ltd, a British Virgin Islands company ("Raiku", "we", "us" or "our"), collects, uses, discloses and otherwise processes personal data through raiku.com and its related subdomains, content, forms and interfaces (the "Services"). It is the common website privacy notice for the corporate, Blackline, validator and rkuSOL pages. Leigon Ltd is the controller for the website processing described here. Product specific terms and notices apply to additional processing outside that scope where relevant.

This Policy explains our processing; it does not ask you to give blanket consent by browsing the Site. Where consent is required, we request it separately and you may withdraw it. Read this Policy together with the Terms of Use and, where relevant to your activity, the Risk Disclosure.

1. Scope

This Policy covers personal data we process through or in connection with the Services, including enquiries about group products. It does not govern an independent provider's separate processing through Sanctum, a wallet, an independently operated validator, a decentralised finance application or another third party service. Such providers have their own privacy notices. Embedding a third party interface does not exclude from this Policy any personal data that Raiku itself receives or processes through that interface. Separate customer arrangements may require additional privacy information or data processing terms.

Transactions on public blockchains are public and may be permanent and immutable. We do not control the public blockchain or independently published records. However, where we collect or analyse public wallet addresses or transaction information that constitutes personal data, our own processing is covered by this Policy. Publication on a blockchain does not by itself remove applicable data protection rights.

2. Information we collect

We collect the following categories of information in connection with the Services:

2.1 Information you provide to us

  • contact and professional information you provide, such as your name, email address, employer and role, when making an enquiry, subscribing to updates, completing a form or communicating with us;
  • any other information you choose to provide, including in the body of your communications.

2.2 Information collected automatically

  • technical and device information, including IP address, device type, operating system, browser type and version, screen resolution and device identifiers;
  • usage information, including pages accessed, visit times, duration, referring pages and interactions;
  • approximate location derived from an IP address, used for security, relevant eligibility controls and service improvement;
  • information collected through cookies, pixels, tags and similar technologies, subject to Section 9.

2.3 Wallet address information

  • if you connect a wallet to an interface we make available, we may receive its public address and transaction information relevant to that interaction or compliance checks. An independent interface provider may also receive data under its own privacy notice. Wallet addresses and transaction data may be personal data when linked to an identifiable person. Raiku does not ask you to disclose a private key or seed phrase.

3. How we use personal data

We process personal data for the following purposes:

  1. to provide, maintain and improve the Services and diagnose technical issues;
  2. to understand usage and analyse trends, subject to the applicable cookie and consent rules;
  3. to respond to enquiries, route them to the relevant group team, provide administrative information and send updates you request or that we may otherwise lawfully send;
  4. to protect security and prevent fraud, abuse and unlawful activity;
  5. to enforce the Terms, including product specific rkuSOL eligibility restrictions and applicable sanctions restrictions, rather than automatically excluding all corporate site visitors from every rkuSOL restricted country;
  6. to comply with applicable laws, legal processes and lawful requests, and establish, exercise or defend legal claims; and
  7. for another purpose explained at collection, where a valid legal basis permits it.

4. Legal bases (EEA / UK users)

Where the GDPR or UK GDPR applies, the applicable legal basis depends on the processing purpose:

  1. Legitimate interests: operating and securing the Site, responding to business enquiries, improving the Services, preventing fraud and protecting legal rights, where those interests are not overridden by your rights (Article 6(1)(f));
  2. Consent: cookies and similar technologies, newsletters or other processing for which consent is required or relied on (Article 6(1)(a)); consent can be withdrawn;
  3. Contract: processing necessary to perform a contract with you or take steps at your request before entering one (Article 6(1)(b)); and
  4. Legal obligation: processing necessary to meet an obligation recognised by the applicable data protection law (Article 6(1)(c)).

Other applicable data protection laws, including Swiss law where relevant, may provide additional requirements. Providing information needed to answer an enquiry, verify eligibility or perform a contract may be necessary for that purpose; without it, we may be unable to proceed.

When relying on legitimate interests, we assess the relevant purpose, necessity and impact on your rights. You may request further information about that assessment by contacting us. You may object to direct marketing at any time and unsubscribe using the mechanism in the communication or by contacting us.

Automated access checks. IP location checks and, where used, sanctions or wallet screening may automatically restrict an interface or relevant content under our eligibility rules. They do not give Raiku control of your wallet. You may contact us to challenge an incorrect result and request human review. We do not otherwise use solely automated decision making producing legal or similarly significant effects; if that changes, we will provide the information and safeguards required by applicable law.

5. Sharing and disclosure

We may share personal data in the following circumstances:

  1. with service providers acting on our behalf, including hosting, content delivery, analytics, communications and security providers, subject to appropriate safeguards;
  2. with professional advisers where needed for advice or legal claims;
  3. with relevant group companies, including Raiku Labs, to handle product enquiries and the other purposes described here; where another group company processes the data for its own purposes, its role and any additional privacy information will be communicated as required;
  4. with authorities where disclosure is required or otherwise lawful, including to respond to valid legal process, protect rights or address unlawful activity;
  5. in connection with a financing, reorganisation, sale or similar transaction, subject to lawful grounds and appropriate confidentiality protections; and
  6. with your consent or at your direction.

We do not sell personal data in exchange for monetary consideration.

6. International transfers

Raiku is established in the British Virgin Islands. Personal data may be processed there and in other countries where our affiliates or service providers operate, including the Cayman Islands, United States and United Kingdom. Protection in those countries may differ from that in your country. Where a restricted international transfer requires safeguards, we use an applicable adequacy mechanism, appropriate contractual safeguards or another lawful mechanism. Contractual safeguards may include European Commission standard contractual clauses and, for UK transfers, the UK International Data Transfer Agreement or the UK Addendum to those clauses, as appropriate. Contact us for information about the applicable safeguards and how to obtain a copy, subject to necessary confidentiality redactions.

7. Retention

We retain personal data for as long as is necessary for the purposes for which it was collected, or as required to comply with our legal and regulatory obligations, to establish, exercise or defend legal claims, or to enforce our agreements. The retention period depends on the nature of the personal data and the purposes for which it is processed. When personal data is no longer needed, we will securely delete, anonymise or aggregate it.

8. Your rights

Depending on your jurisdiction, you may have the following rights in respect of your personal data:

  1. to request access to, and a copy of, your personal data;
  2. to request correction of inaccurate or incomplete personal data;
  3. to request erasure of your personal data in certain circumstances;
  4. to object to, or request restriction of, certain processing activities;
  5. to request portability of certain personal data you have provided to us, in a structured, commonly used and machine readable format;
  6. to withdraw any consent you have given us, without affecting the lawfulness of processing prior to withdrawal; and
  7. to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement (for EEA users), or the UK Information Commissioner's Office (for UK users).

To exercise any of these rights, please contact us at [email protected]. We may need to verify your identity before responding to your request. We will respond within the period required by applicable law.

9. Cookies and similar technologies

We use cookies and similar technologies to operate the Services and, where permitted, analyse use and personalise content. Our Cookie Notice or cookie management tool identifies the technologies used, their purposes, providers and duration. Where consent is required, optional technologies are not activated until you consent. You can reject optional categories and change or withdraw your choice through the Site's cookie controls. Browsing the Site alone is not consent. Strictly necessary technologies may be used without consent where the law permits.

10. Security

We implement appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure or access. However, no system or transmission of data over the internet can be guaranteed to be completely secure. You are responsible for the security of any device you use to access the Services, and of any wallet, private key, seed phrase or credential you use in connection with rkuSOL or any Third Party Service.

11. Children

The Services are not directed at, and are not intended for use by, individuals under the age of 18. We do not knowingly collect personal data from any individual under the age of 18. If you believe we have inadvertently collected personal data from an individual under the age of 18, please contact us at [email protected] and we will take steps to delete that information.

12. Changes to this Privacy Policy

We may amend this Policy and publish the revised version with an updated "Last Updated" date. We will communicate material changes as required, including through a prominent website notice or an appropriate direct communication. A revised notice does not replace any fresh consent or other lawful basis required for changed processing.

13. Contact

For questions or to exercise your rights, contact [email protected]. The controller is Leigon Ltd (BVI company number 2208336), Commerce House, Wickhams Cay 1, P.O. Box 3140, Road Town, Tortola, British Virgin Islands, VG1110.