Privacy Notice

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Welcome to Houdini Swap!

Last Updated: January 25, 2024 Welcome! Houdini Swap’s approach to data collection is carefully calibrated to balance your privacy, effective customer support and our obligations to third-party providers. This Privacy Notice explains how www.houdiniswap.com (“Houdini Swap”) collects, uses, discloses, and otherwise processes user information in connection with our website, https://www.houdiniswap.com, and other websites we own and operate, including but not limited to transactional services we facilitate, other products, functionality, and staking services offered on or through our online services (collectively, the “Services”) that link to this Privacy Notice governing the Services (“Privacy Notice”). Use of the words “we”, “us” or “our” herein refers to Houdini Swap. “You”, “your” and “user” refers to any individual who accesses the Services. By accessing the Services, or by acknowledging agreement to either the Terms of Service Agreement (”Agreement”) or Privacy Notice, you confirm that you have read, understood and agree to the Privacy Notice governing the Services in its entirety. You further agree that the defined terms used in the Privacy Notice, if defined in the Agreement, shall have the meanings set forth herein. Please read the Privacy Notice carefully. Feel free to print and keep a copy of the Privacy Notice, but please understand that we reserve the right to change any of these terms and conditions at any time. The latest version of the Privacy Notice, with its date of update, can be always found on this page. You agree and understand that by accessing or using the Services following any change to the Privacy Notice your access or use of the Services shall constitute your agreement to the amended Privacy Notice. You should, therefore, read the Privacy Notice from time to time. IF ANY TERM OR CONDITION OF THIS PRIVACY NOTICE IS UNACCEPTABLE TO YOU, YOU SHOULD NOT ACCESS OR USE THE SERVICES. This Privacy Notice does not address practices relating to Houdini Swap personnel.

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Transaction Data

A transactional related event accessed by the Services, such as a “swap”, “send” or “cross-chain swap”, requires the use of cryptocurrency, digital tokens or digital assets (“Digital Assets”) (collectively “Transaction”). When you use our Services for Transactions, we automatically collect data, which includes the sending wallet address, the receiving wallet address, types and quantity of token sent and types and quantity of token received and internet protocol (IP) address (“Transaction Data”). We do not engage in activity which may cause us to personally identify you. However, while ever we retain Transaction Data we do maintain personal information which may give us the ability to do so. WE RETAIN TRANSACTION DATA FOR A STANDARD PERIOD OF 72 HOURS AFTER WHICH IT IS AUTOMATICALLY DELETED. Doing so allows our customer support team to have sufficient information to address user queries or issues effectively. In instances where a customer support matter extends beyond the standard 72 hour retention window, we retain the relevant Transaction Data until the issue is fully resolved. Post-resolution, this Transaction Data is promptly deleted using our platform’s automated deletion processes.

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User Data Deletion

Recognising the importance of user autonomy, we offer users the option to immediately delete their Transaction Data from our platform database when transacting. This option, available on the Working Our Magic Page, empowers users to control their data privacy. You should be aware that opting for immediate deletion of Transaction Data may impact the complexity and effectiveness of resolving potential support issues. Please consider this trade-off when selecting this option.

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Law Enforcement

In cases where law enforcement authorities request information as part of their investigation into illicit activities, Houdini Swap will cooperate to the extent permitted by law.

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Our Collection of Personal Information

In addition, and separately to, Transaction Data, we collect other types of personal information in connection with your accessing the Services. This collection includes information that you provide in connection with the Services as well as information from third-parties.

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Personal Information Collected from Individuals

We may collect the following personal information submitted to us by individuals through the Services.

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Staking Service Information

Please be aware that by virtue of the public nature of blockchain networks, your Staking Service account and transactions associated with your wallet address will be available to us. Information stored on the blockchain may not be able to be modified or deleted due to its immutable nature. THE STAKING AND UNSTAKING OF DIGITAL ASSETS IN THE STAKING SERVICE IS UNDERTAKEN AS HOUDINI SWAP PRIVATE TRANSACTIONS. Please consider how privacy and transparency on the blockchain works. The details of our private transactions can be found here.

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Account Information

To use our Staking Service you are required to establish an account. This involves collecting the public blockchain address associated with your crypto wallet. We may also collect your usernames, Houdini ID and password for using our Staking Service and Services. We use this information to administer your account, provide you with the relevant services and information, communicate with you regarding your account, the Services, and for customer support purposes.

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Crypto Wallets

In participating in our Staking Service, when you connect your crypto wallet we receive information such as your wallet address. We do not engage in activity which may result in us accessing additional information in your crypto wallet but you should be aware that in accessing your wallet address we have the capability to do so. This includes information such as crypto wallet types (including amounts and balances), any related transaction and technical information associated with your crypto wallet address, including network information regarding transactions.

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Token Information

If you choose to participate in our Staking Service, we may receive certain token transaction and event-related information, including your public blockchain address associated with your self-hosted crypto wallet used in the Staking Service, the amount of your staked balance, and Staking Service event-related information such as dates, time and quantity of transfers of Digital Assets.

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Other Personal Information

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Communications

If you communicate with us through electronic form (i.e., email or Telegram), we may collect your name, email address, phone number, social media handle or any other personal information you choose to provide to us. We use this information to investigate and respond to your inquiries, and to communicate with you.

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User Content

You may upload, or transmit audio, videos, images, data, or information through your communications with us, your posts in Houdini Swap Telegram or Twitter of other social media platforms, and when you otherwise use the Services (collectively, “User Content”). We may collect this information, and information about this content, such as the date and time you created this content, along with other information about you, including your social media handle. Please remember that Houdini Swap may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. For more information, please see our Terms of Service. [Link]

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Employment Application Information

If you apply for employment we may collect your personal information, including your contact and demographic information, educational and work history, employment interests, information obtained during interviews and any other information you choose to provide, if you apply for employment.

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Personal Information We Automatically Collect

Automatic data we retain, other than Transaction Data, relates to user browsing actions and website usage patterns when visiting or interacting with our Services, which may include operating system, browser type, browser id, the URL entered, date/time of visit, the time spent on our Services, analytics data and general geographic location data. We do not use cookies.

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Personal Information from Third-Parties

We obtain personal information from third-parties which we may combine with personal information we collect either automatically or directly from an individual. We may receive the same categories of personal information as described above from the following third-parties:

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Other Users or Individuals who Interact with our Services

We may receive your information from other users or other individuals who interact with our Services. For example, if you engage in one of our communities hosted on a third-party platform, such as Telegram, we will be able to see any public communications made within that platform.

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Business Partners

We may receive your information from our business partners, such as companies that offer their products and/or services on our Service.

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Social Media or Third-party Platforms

When you interact with our Services through various social media networks, such as when someone follows us on Twitter, or other social networks, we may receive some information about you that you permit the social network to share with third-parties. The data we receive is dependent upon your privacy settings with the social network, and may include your profile information, profile picture, gender, username, user ID associated with the social media account, age range, language, country, and any other information you permit the social network to share with third-parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. Third-Party Websites Our Services may link to other websites operated by or with content provided by third-parties, and such other websites may link to our Services. You understand and agree that we have no control over any such other websites or their content and will have no liability arising out of or related to such websites or their content. The existence of any such links does not constitute an endorsement of such websites, their content, or their operators. We are providing these links to you only as a convenience.

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Information from Other Sources

We may collect personal information about individuals that we do not otherwise have from, for example, publicly available sources such as permissionless blockchains, third-party data providers, blockchain analytics providers, customers, third-party digital wallet providers, or through transactions such as mergers and acquisitions. Such information may include contact information, social media account information, general location, domains, crypto wallet address and related information, token ownership information (e.g., transfers of tokens between wallets), the corresponding smart contracts transactions paid and metadata describing each transaction and its properties as a digital asset, transaction recipient information, interest-in-services information and employment-related information. We may use this information to provide the Services, contact individuals, process employment applications and screen job applicants, or better understand the demographics of the individuals with whom we interact.

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Our Use of Personal Information

We may use personal information we collect to: (i) Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations, to deliver the Services; (ii) Manage our business and its day-to-day operations; (iii) Authenticate your account credentials and identify you, as necessary; (iv) Communicate with individuals, including via email and social media; (v) Request individuals to complete surveys about our company and Services; (vi) For marketing and advertising purposes, including to market to, or offer you through social media platforms, updates on products, services and the Services we think that you may be interested in; (vii) Enable you to communicate and share files with users you designate; (vii) Test, enhance, update and monitor the Services, or diagnose or fix technology problems; (viii) Facilitate customer benefits and services, including customer support; (viii) Identify and analyze how individuals use our Services; (ix) Conduct research and analytics on our customer and user base and Services; (x) Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with; (xi) Help maintain the safety, security and integrity of our property, Services, technology assets and business; (xii) Evaluate your candidacy for employment, to communicate with you during the application process and to facilitate the onboarding process, if you are applying for employment; (xiii) Fulfill or enforce our legal or contractual obligations and requirements (including in relation to our Terms of Service), to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third-parties; (xiv) Audit transactions conducted in connection with our services; (xv) Prevent, investigate or provide notice of fraud or unlawful or criminal activity; or (xvi) For any other lawful purpose, or other purpose that you consent to or for which you provide your information.

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Our Disclosure of Personal Information

We disclose personal information in the following ways:

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Affiliates

We may share user information with other companies owned or controlled by Houdini Swap, and other companies owned by or under common ownership as Houdini Swap, which also includes our subsidiaries (i.e., any business we own or control) or our ultimate holding company (i.e., any business that owns or controls us) and any subsidiaries it owns, particularly when we collaborate in providing the Services.

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Blockchain Participants

If you participate in Services, other than Private Transactions, by virtue of the public nature of the blockchain, the holdings and transactions associated with your crypto wallet address will be publicly available and accessible to blockchain participants and other third-parties, as well as any other information you choose to provide or make public.

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Other Service Providers

In addition to the third-parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, conducting cryptocurrency transactions, employment application-related services, and administrative services.

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Business Transaction or Reorganization

We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third-party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may be disclosed in the event of insolvency, bankruptcy or receivership.

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Legal Obligations and Rights

We may disclose personal information to third-parties, such as legal advisors and law enforcement: (i) in connection with the establishment, exercise, or defense of legal claims; (ii) to comply with laws or to respond to lawful requests and legal process; to protect our rights and property and the rights and property of others, including to enforce our agreements and policies; (iii) to detect, suppress, or prevent fraud; to protect the health and safety of us and others; (iv) or as otherwise required by applicable law.

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With Your Consent

We may disclose personal information about an individual to certain other third-parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may display their testimonial on our Services or service-related publications.

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Personal Information of Children or Young People

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children or young people under the age of 18. If an individual is under the age of 18, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child or young person under the age of 18 has provided personal information to us, we encourage their parent or guardian to contact us through our Support Team to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child or young person under the age of 18, we will promptly delete that personal information.

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Links to Third-Party Websites or Services

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to, or expressly adopt, or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any personal information practices of third-party websites and online services or the practices of other third-parties. To learn about the personal information practices of third-parties, please visit their respective privacy notices.

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Questions and Feedback

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please message our Support Team.