Privacy Policy
Last updated: February 2, 2026
This Privacy Policy explains how Senoa collects, uses, discloses, and protects personal information when you access or use the Platform.
Table of Contents
- 1. Scope and Controller
- 2. Information We Collect
- 3. Sources of Information
- 4. How We Use Information
- 5. Legal Bases for Processing
- 6. How We Share Information
- 7. Cookies, Analytics, and Tracking
- 8. Blockchain and Public Ledgers
- 9. International Data Transfers
- 10. Data Retention
- 11. Security
- 12. Your Privacy Rights
- 13. Marketing Preferences
- 14. Children's Privacy
- 15. Changes to This Policy
- 16. Contact Us
- Annex C: Jurisdiction-Specific Disclosures
1. Scope and Controller
1.1 This Privacy Policy applies to the Platform and related services that reference it.
1.2 Controller. The data controller is: [Insert Legal Entity Name and Address]. Where we act as a processor for business customers (for example, where a Creator uses tools to manage their audience), the Creator may be the controller for certain data.
1.3 This Policy does not cover third-party services you access through the Platform, which are governed by their own policies.
2. Information We Collect
We collect information in the following categories:
2.1 Account and Profile Information
Name, email, username, social login identifiers, profile details, and settings.
2.2 Identity Verification (KYC)
Where required, government ID, selfie/biometric checks, date of birth, address, and screening results (processed by verification providers).
2.3 Wallet and On-Chain Data
Wallet addresses, transaction hashes, token interactions, pass ownership status, and other on-chain activity associated with your use of on-chain features.
2.4 Transaction and Payment Information
Purchase history, subscription status, billing details, and payment confirmations (payment card details are typically processed by third-party payment processors).
2.5 Marketplace and Seller Data
Listings, order details, fulfillment status, customer support records, and disputes.
2.6 Usage and Device Data
IP address, device identifiers, browser type, operating system, app version, log data, clicks, pages viewed, and performance metrics.
2.7 Communications
Messages sent through the Platform, support tickets, emails, and feedback.
2.8 AI Inputs/Outputs
Prompts, uploaded materials, and AI-generated outputs (where you use AI features), subject to applicable settings and law.
2.9 Inferences
We may derive inferences about preferences or interests based on your activity to personalize features or reduce fraud.
3. Sources of Information
We collect information: (a) directly from you; (b) automatically from your device and usage; (c) from connected wallets and public blockchains; (d) from third-party providers (social login, payment processing, identity verification, analytics, fraud prevention); and (e) from other users where relevant to transactions or interactions.
4. How We Use Information
We use information to:
- Provide and operate the Platform, including account creation, authentication, and feature access.
- Enable marketplace transactions, escrow workflows, and customer support.
- Calculate and administer rewards, commissions, and program integrity checks.
- Personalize content, recommendations, and user experience.
- Detect, prevent, and investigate fraud, abuse, and security incidents.
- Comply with legal obligations, including sanctions screening, KYC/AML where applicable, and law enforcement requests.
- Maintain, debug, and improve performance, analytics, and product development.
- Communicate with you about service updates, security alerts, and (where permitted) marketing.
5. Legal Bases for Processing (where applicable)
Where required by law (e.g., GDPR/EEA/UK), we process personal data based on: (a) contract (to provide the Platform); (b) legitimate interests (security, fraud prevention, improvement); (c) consent (certain cookies/marketing); and (d) legal obligation (compliance, recordkeeping).
8. Blockchain and Public Ledgers
Blockchain transactions are typically public and immutable. When you use on-chain features, wallet addresses and transaction data may be visible to anyone and may not be erasable by Senoa. We may associate your account with wallet addresses you connect to the Platform.
9. International Data Transfers
Your information may be processed in countries other than your country of residence. Where required, we use appropriate safeguards for international transfers, such as contractual clauses and security controls.
10. Data Retention
We retain personal information as long as necessary to: (a) provide the Platform; (b) comply with legal obligations; (c) resolve disputes; and (d) enforce agreements. Retention periods may vary by data type and legal requirements.
11. Security
We implement administrative, technical, and organizational safeguards designed to protect personal information. However, no system is completely secure. You are responsible for protecting your credentials and wallet keys.
12. Your Privacy Rights
Depending on your jurisdiction, you may have rights to access, correct, delete, port, or restrict processing of your personal information, and to object to certain processing.
To exercise rights, contact: privacy@senoa.io (or legal@senoa.io). We may need to verify your identity before responding.
13. Marketing Preferences
You may opt out of marketing emails by using the unsubscribe link, adjusting in-Platform settings, or contacting us. We may still send non-marketing service messages.
14. Children's Privacy
The Platform is not intended for individuals under 18 and we do not knowingly collect personal information from children. If you believe a child has provided information, contact us so we can take appropriate action.
15. Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will provide notice as required by law. Continued use after the effective date constitutes acceptance.
16. Contact Us
Privacy inquiries: privacy@senoa.io
Legal inquiries: legal@senoa.io
Annex C: Jurisdiction-Specific Disclosures
C1. GDPR/EEA and UK
You may have the right to lodge a complaint with a supervisory authority. If processing is based on consent, you may withdraw consent at any time.
C2. California (CCPA/CPRA)
California residents may have rights to know, delete, correct, and opt out of certain sharing for cross-context behavioral advertising. We will respond to verified requests as required by law.
C3. Canada (PIPEDA)
We collect, use, and disclose personal information for purposes a reasonable person would consider appropriate, and we obtain consent where required. You may request access and correction and may challenge our compliance by contacting us.
C4. Do Not Track
Some browsers offer "Do Not Track" signals. There is no uniform standard, and we may not respond to all signals.
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