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Last updated 15 September 2025 Neutron Services. Use of Neutron, the Neutron Website, and any Neutron Interfaces, may facilitate interaction with certain decentralized cryptographic protocols, apps, and blockchains, which are not owned or controlled (each, a “Protocol”) by the Neutron Foundation. If you utilize Neutron services relating to the creation and management of digital assets, smart contracts will be employed that necessarily collect information, such as your digital wallet address (which some legal jurisdictions may consider personal information), and that information will be stored on a public blockchain that we do not control. A smart contract is computer code that automatically processes events when certain conditions are met; for example, when a transaction is conducted to add a token to a digital wallet, a smart contract would automatically execute the proposed action. In these situations, your personal information, such as a digital wallet address, will be stored on that blockchain through the execution of a smart contract and that personal information may not be able to be modified or deleted due to the immutable nature of the blockchain. Please make sure to review Neutron’s Terms and Conditions for more information, including specific terms and obligations for the use of our Services that may include dispute resolutions. This Privacy Policy (the “Policy”) explains how the Neutron decentralized autonomous organization (“Neutron DAO”), the Neutron Foundation, and any service providers and/or affiliates (collectively “Neutron,” “we”, “us” or “our”) collects, uses, and shares data in connection with use of the Neutron blockchain network and associated interfaces and user interfaces, including neutron.org, governance.neutron.org, forum.neutron.org, bridge.neutron.org, and other such Neutron ecosystem subdomains and interfaces as may be launched in the future (the “Interface”). For purposes of applicable data protection laws, the Neutron acts as the Controller. Certain processing activities may also be conducted by Neutron DAO or designated service providers acting as processors on our behalf. Your use of the open source software related to the Neutron Network (“Neutron”) is subject to this Policy as well as our Terms and Conditions. This Policy supplements and is incorporated into our Terms and Conditions. By using the Interface or Services, you agree to this Policy. Scope of Neutron’s Privacy Policy. This Privacy Policy applies to personal information processed by us, including on our websites, and other online or offline offerings (collectively called the “Services”). Neutron does not collect and store personal data, such as first name, last name, street address, date of birth, email address, or IP address. All data collected is anonymized. Although we do not intentionally collect traditional identifiers (such as names or email addresses), certain laws treat blockchain addresses, device identifiers, and cookies as personal data. We treat this data accordingly. Neutron may use and/or collect, following due governance processes (voted in by the governance system), ​​non-identifiable data, such as public on-chain data, and limited off-chain data like device type, browser version, interface usage, etc. This is to help drive production vision, not track users. Neutron will offer opt-out options for data-tracking when applicable. Users are empowered to explore client-side privacy techniques and tools. Any material changes to privacy will be reflected in an updated version of this Privacy Policy. Definitions. For the purposes of the this Privacy Policy:
  • “Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • “Processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • “Controller” means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law;
  • “Processor” means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller;
  • “Consent” of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Data Neutron Collects. Privacy and accessibility is central to the ethos of Neutron. Accordingly, we aspire to be transparent about what little data we do collect. We do not maintain user accounts and do not collect and store personal data, such as your name or internet protocol (“IP”) address. When you interact with the Interface and/or the Protocol, we collect only:
  • Publicly-available Blockchain Data. When you connect your non-custodial blockchain wallet to the Interface, we collect and log your publicly-available blockchain address to learn more about your use of the Interface and to screen your wallet for any prior illicit activity. We may screen your wallet using intelligence provided by leading blockchain analytics providers. Note that blockchain addresses are publicly-available data that are not created or assigned by us or any central party, and by themselves are not personally identifying.
  • Information from localStorage and Other Tracking Technologies. We and our third-party services providers may access and collect information from localStorage, mobile deviceID, cookies, web beacons, and other similar technologies to provide and personalize the Interface and features of the Interface for you across sessions. We may use this information to learn about your preferences and your use of the Interface. Information we collect from these technologies may include things such as browser type, referring/exit pages, operating system, device or browser language, and other device information. We may also collect limited performance and diagnostic information, including page load times, crash reports, CPU/memory usage, and other technical metrics, to improve the reliability and performance of the Interface. We may group and analyze these user journeys collectively, in the aggregate, to improve our product user experience.
  • Information from Other Sources. We may receive information about your wallet address or transactions made through the Interface and/or the Protocol from our service providers in order to operate in good faith and remain aligned with legal obligations and potentially prevent the use of our Interface or Protocol in connection with fraudulent or other illicit activities.
  • Survey or Usability Information. If you participate in a survey or usability study with us, any and all information provided to us may be analyzed by Neutron.
  • Correspondence. We will receive any communications and information you provide directly to us via email, social media, or another support channel (such as Twitter or Discord), or when you participate in any surveys or questionnaires.
  • Biographical Information. If you apply for a role with us, we collect all information provided, including name, email, Discord handle and any other resume, cover letter, or free form text you include.
How We Use Data. We use the data we collect in accordance with your instructions, including any applicable terms in our Terms and Conditions, and to operate in good faith. We may also use data for the following purposes:
  • Providing Access to the Protocol. Our lawful bases for processing personal data include: (i) consent, (ii) performance of a contract, (iii) compliance with a legal obligation, and (iv) our legitimate interests, provided these are not overridden by your rights and freedoms. We use the data we collect to provide, maintain, customize and improve our Interface and features of the Interface.
  • Customer Support. We may use information to provide customer support for and answer inquiries about the Interface or the Protocol.
  • Safety and Security. Neutron may use data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect community members.
  • Compliance with Applicable Law. We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
  • Aggregated Data. We may use some of the information we collect or access to compile aggregated data that helps us learn more about how users use the Interface and where we can improve your experience. We may also aggregate or de-identify information so that it cannot reasonably be used to identify you. Such information may be used to analyse effectiveness, improve our services, or conduct research. We will not attempt to re-identify de-identified data unless required by law.
  • Retention. We retain personal data only for as long as necessary to fulfil the purposes outlined in this Policy, including to meet legal, regulatory, tax, accounting, or reporting requirements. Retention periods may vary depending on the nature of the data and the reasons for its collection. Where data is aggregated or anonymised, we may retain it for longer periods for research and statistical purposes.
How We Share Data. We may share or disclose the data we collect:
  • With Service Providers. We may share your information with our affiliates, service providers and vendors to assist us in providing, delivering, and improving the Interface.
  • To Comply with Applicable Law. We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, the Neutron, or others, and to enforce our agreements and policies, including our Terms and Conditions.
  • Safety and Security. We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, Neutron, and ecosystem.
  • Business Changes. We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, or other business transaction.
  • With Your Consent. We may share your information any other time you provide us with your consent to do so.
  • Third Parties. We do not share your information with any third parties for any marketing purposes whatsoever.
Privacy & the Blockchain. Because of the immutable and transparent nature of blockchain technology, information recorded on-chain (such as your wallet address or transaction data) cannot be altered or deleted. Such information is public and may be correlated by third parties, including regulators or law enforcement. By using Interface, you acknowledge and accept these limitations. Third-Party Cookies. We may use services provided by third parties that use tracking technology such as cookies, deviceID, and localStorage, to collect information about your use of the Interface and our interactions with you. All logs are anonymized and users’ Do Not Track settings are respected. You can opt out of having your online activity and device data collected through these third-party services, including by:
  • Blocking cookies in your browser by following the instructions in your browser settings. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit allaboutcookies.org.
  • Blocking or limiting the use of your advertising ID on your mobile device through the device settings.
  • Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.
  • Using any platform opt-out provided.
  • Using advertising industry opt-out tools on each device or browser where you use the Interface, available at optout.aboutads.info and optout.networkadvertising.org.
Third-Party Links and Sites. We may integrate technologies operated or controlled by other parties into parts of the Interface. For example, the Interface may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with these other parties, including when you leave the Interface, those parties may independently collect information about you and solicit information from you. You can learn more about how those parties collect and use your data by consulting their privacy policies and other terms. Google Analytics. We may share your information with Google Analytics to track and analyze the use of the Services. The Google Analytics Advertising Features that we may use include: Remarketing with Google Analytics, Google Display Network Impressions Reporting and Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can opt out of Google Analytics Advertising Features through Ads Settings and Ad Settings for mobile apps. Other opt out means include: For more information on the privacy practices of Google, please visit the Google Privacy & Terms page. Security. We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. You are responsible for all of your activity on the Interface and the Protocol, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys. Where we may use passkeys or other multifactor authentication mechanisms, you are responsible for keeping such credentials secure. We strongly encourage you not to share your access credentials with anyone. Disclosures for European Union Data Subjects. We process personal data for the purposes described in the section titled “How We Use Data” above. Our bases for processing your data include:
  • (i) you have given consent to the process to us or our service provides for one or more specific purposes;
  • (ii) processing is necessary for the performance of a contract with you;
  • (iii) processing is necessary for compliance with a legal obligation; and/or
  • (iv) processing is necessary for the purposes of the legitimate interested pursued by us or a third party, and your interests and fundamental rights and freedoms do not override those interests.
Where we transfer personal data outside of the EEA/UK, we will ensure appropriate safeguards are in place. Your rights regarding your data include the right to:
  • (i) request access and obtain a copy of your personal data,
  • (ii) request rectification or erasure of your personal data,
  • (iii) object to or restrict the processing of your personal data; and
  • (iv) request portability of your personal data.
Additionally, you may withdraw your consent to our collection at any time. Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control. To exercise any of your rights under this Policy, please contact us at legal (at) neutron.org. We may require additional information from you to process your request. Please note that we may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even after a data subject request in accordance with our legitimate interests, including to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. Children’s Privacy and Data Protection. Children under the age of eighteen (18) are not permitted to use the Services, and we do not seek to or knowingly collect any personal data about children under thirteen (13) years of age (or sixteen (16) years of age for individuals in the EEA/UK). If we become aware that we have unknowingly collected information about any child under eighteen (18) years of age, we will make commercially reasonable efforts to delete such personal data and other information from our database. If we learn that we have collected information from a child under the applicable age without parental consent, we will promptly delete such information. If you are the parent or guardian of a child under eighteen (18) years of age who has provided us with their personal data or other information, you may contact us using the below information to request that it be deleted. Removal of Personal Identifying Data and Questions. For any questions regarding your personally-identifying information stored with Neutron, for removal requests or any other suggestions or issues, please send us an email at legal (at) neutron.org. Changes to this Policy. If we make material changes to this Policy, we will notify you via the Interface. Nevertheless, your continued use of the Interface reflects your periodic review of this Policy and our Terms and Conditions, and indicates your consent to them. The date of the last revision will always be displayed at the top of this Policy. Protection of Certain Personally-Identifying Information. Neutron will not rent or sell potentially personally-identifying and personally-identifying information to anyone. If you are a registered user of Neutron and have supplied your email address, Neutron may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with Neutron and our products. We primarily use our website to communicate this type of information, so we expect to keep this type of email to a minimum. Neutron takes all measures reasonably necessary to protect against the unauthorized access, use, alteration, or destruction of potentially personally-identifying and personally-identifying information. Contact Us. If you have any questions about this Policy or how we collect, use, or share your information, please contact us at legal (at) neutron.org.
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