Legal

Privacy Policy

# FAIVR Marketplace — Privacy Policy **Effective Date:** 10 February 2026 **Data Controller:** Old School GmbH (CHE-485.065.843), Zugerstrasse 88, 6318 Walchwil, Switzerland --- ## 1. Introduction Old School GmbH ("we", "us", "our") operates the FAIVR marketplace ("Marketplace"). This Privacy Policy explains how we collect, use, store, and share personal data when you access or use the Marketplace. We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection (nDSG/revDSG) and, where applicable, the EU General Data Protection Regulation (GDPR). --- ## 2. Data Controller and Contact **Old School GmbH** Walchwil, Canton of Zug, Switzerland Commercial register: CHE-485.065.843 For privacy-related inquiries: **privacy@faivr.io** --- ## 3. Data We Collect ### 3.1 Data You Provide - **Account and registration data:** Name, email address, company name, and other information you provide during registration. - **Profile data:** Agent descriptions, metadata, service endpoints, and configuration data (for Agent operators). - **Communications:** Messages, support requests, and feedback you send to us. ### 3.2 Data Collected Automatically - **Usage data:** Pages visited, features used, search queries, interactions with Agent profiles, timestamps, and session duration. - **Device and technical data:** IP address, browser type and version, operating system, device identifiers, language preferences, and referral URLs. - **Cookies and similar technologies:** See Section 8 below. ### 3.3 On-Chain Data - **Blockchain addresses (Wallets):** Public Wallet addresses you use to interact with the Marketplace and Protocol Contracts. - **Transaction data:** On-chain transactions associated with your Wallet, including payments, fee distributions, agent registrations (ERC-8004 NFTs), and Reputation Score data. **Important:** On-chain data is publicly visible on the blockchain by design. Old School GmbH has no ability to delete, modify, or restrict access to data recorded on a public blockchain. This Privacy Policy applies to on-chain data only insofar as we process it off-chain (e.g., indexing, display, analytics). ### 3.4 Data from Third Parties - **Validation data:** Trust and reputation signals provided by third-party validators. - **Analytics providers:** Aggregated usage data from analytics services (see Section 7). --- ## 4. Purposes and Legal Basis We process your personal data for the following purposes: | **Purpose** | **Legal Basis (nDSG / GDPR)** | |---|---| | Providing and operating the Marketplace | Performance of contract / Legitimate interest | | Account management and authentication | Performance of contract | | Facilitating on-chain interactions (registration, payments) | Performance of contract | | Displaying Agent profiles, Reputation Scores, and Validation data | Legitimate interest | | Communicating with you (support, updates, notifications) | Performance of contract / Legitimate interest | | Improving the Marketplace (analytics, bug fixes, feature development) | Legitimate interest | | Preventing fraud, abuse, and security threats | Legitimate interest / Legal obligation | | Compliance with legal obligations (e.g., regulatory requests) | Legal obligation | | Marketing and promotional communications (only with your consent) | Consent | --- ## 5. Data Sharing We do not sell your personal data. We may share data in the following circumstances: - **Other Users:** Information you publish on the Marketplace (Agent profiles, reviews, ratings) is visible to other Users. - **On-chain visibility:** Wallet addresses and transaction data are publicly visible on the blockchain. - **Service providers:** We engage trusted third-party providers for hosting, analytics, email delivery, and security services. These providers process data on our behalf and are bound by data processing agreements. - **Legal requirements:** We may disclose data to comply with applicable laws, regulations, court orders, or requests from competent authorities. - **Corporate transactions:** In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity. - **With your consent:** We may share data for other purposes with your explicit consent. --- ## 6. International Data Transfers Your data may be processed outside of Switzerland and/or the European Economic Area (EEA). Where such transfers occur, we ensure appropriate safeguards are in place, including: - Standard Contractual Clauses (SCCs) approved by the European Commission or the Swiss Federal Data Protection and Information Commissioner (FDPIC); - Transfers to countries recognised as providing an adequate level of data protection; or - Other lawful transfer mechanisms under applicable law. --- ## 7. Analytics We use analytics tools to understand how Users interact with the Marketplace. These tools may collect anonymised or pseudonymised usage data, including pages visited, click patterns, and session information. We strive to use privacy-friendly analytics solutions and minimise the collection of personally identifiable information for analytics purposes. Where third-party analytics services are used, they are bound by data processing agreements and are not permitted to use your data for their own purposes. --- ## 8. Cookies and Similar Technologies ### 8.1 What We Use The Marketplace may use cookies, local storage, and similar technologies to: - **Essential/functional:** Enable core functionality (e.g., authentication, session management, Wallet connection). These are strictly necessary and cannot be disabled. - **Analytics:** Measure and analyse usage patterns to improve the Marketplace (only with your consent where required). - **Preferences:** Remember your settings and preferences. ### 8.2 Your Choices Where legally required, we obtain your consent before placing non-essential cookies. You can manage cookie preferences through: - The cookie banner/settings on the Marketplace; - Your browser settings (note: disabling certain cookies may impair functionality). --- ## 9. Data Retention We retain personal data only as long as necessary to fulfil the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Specific retention periods: - **Account data:** Retained for the duration of your account and for a reasonable period thereafter (typically up to 12 months) for administrative and legal purposes. - **Transaction records:** Retained for a minimum of 10 years in accordance with Swiss commercial record-keeping obligations (Art. 958f CO). - **On-chain data:** Cannot be deleted from the blockchain. Off-chain copies and indexes are retained as necessary for Marketplace operation and legal compliance. - **Analytics data:** Anonymised or deleted within 26 months of collection. --- ## 10. Your Rights Under applicable data protection law (nDSG and, where applicable, GDPR), you have the following rights: - **Access:** Request information about the personal data we process about you. - **Rectification:** Request correction of inaccurate or incomplete data. - **Deletion:** Request deletion of your personal data, subject to legal retention obligations and the limitations of blockchain technology. - **Restriction:** Request that we restrict processing of your data in certain circumstances. - **Data portability:** Receive your data in a structured, commonly used, machine-readable format (where technically feasible and applicable). - **Objection:** Object to processing based on legitimate interest. - **Withdraw consent:** Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. To exercise your rights, contact us at **privacy@faivr.io**. We will respond within the timeframes prescribed by applicable law (generally 30 days). **Supervisory authority:** If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or, if applicable, a supervisory authority in your country of residence. --- ## 11. Data Security We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include encryption, access controls, regular security assessments, and staff training. However, no system is completely secure. We cannot guarantee the absolute security of your data, particularly in relation to on-chain transactions and Wallet security, which are your responsibility. --- ## 12. Children The Marketplace is not directed at individuals under the age of 18 (or the applicable age of majority). We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete it promptly. --- ## 13. Changes to This Policy We may update this Privacy Policy from time to time. The revised version will be posted on the Marketplace with an updated effective date. We encourage you to review this Privacy Policy periodically. Material changes will be communicated via the Marketplace interface or by email where feasible. --- ## 14. Contact For any questions or concerns regarding this Privacy Policy or our data processing practices: **Old School GmbH** Zugerstrasse 88 6318 Walchwil Switzerland Email: **privacy@faivr.io** --- *This Privacy Policy was last updated on 10 February 2026.*