> For the complete documentation index, see [llms.txt](https://docs.clovis.network/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.clovis.network/more/yei-finance/legal/privacy-policy.md). # Privacy Policy Effective Date: May, 21, 2024 The Yei Protocol operates in a decentralized and permissionless manner. Although we may collect and process information about users of [https://app.yei.finance](https://app.yei.finance/) or the Interface in accordance with this Privacy Policy, we do not have information about all protocol users beyond what is publicly available and recorded on the blockchain. This Privacy Policy explains how Yei Finance ("we," "our," or "us") collects, uses, and shares information in connection with our Services, as well as your rights and choices regarding such information. These terms apply to Yei Protocol, the Interface, and any other online location that links to this Privacy Policy (collectively, the "Services"). This Privacy Policy provides notice of our information practices. Where applicable law requires consent, we will request consent separately and will explain how you can withdraw it. Your use of the Services does not constitute consent to processing for which consent is not legally required. If you do not agree with the [Terms of Use](/more/yei-finance/legal/terms-of-use.md), you should not use or access the Interface or the Services. ## 1. Information Collection #### A. Information You Provide We may collect information that you voluntarily provide when you use the Services, including: * Contact information, such as your name, email address, and other contact details; * Support communications, feedback, bug reports, questions, and other content that you send to us; * Information you provide when participating in surveys, events, campaigns, or community activities; * Your communication preferences and consent records; and * Any other information that you choose to provide. We do not request or collect private keys, seed phrases, wallet passwords, or transaction-signing credentials. You must not provide this information to us or to anyone claiming to represent Yei Finance. #### B. Information Collected Automatically Depending on how you use the Services, we may collect: * Wallet information, such as the public wallet address used to connect to the Interface, connected network, transaction status, and interactions with supported assets or features; * Device and browser information, such as device type, operating system, browser type, screen size, language, and time zone; * Log and network information, such as IP address, access time, referring URL, pages viewed, browser events, and error reports; * Usage information, such as the features, pages, links, and assets that you interact with; * Cookie and similar technology information, as described in the Cookies and Analytics sections; and * Information received from public blockchains, blockchain explorers, analytics providers, compliance providers, wallet providers, and other third parties. We do not collect every type of information listed above from every user. The information collected depends on the Services and features that you use. #### C. Sources of Information We may receive information: * directly from you; * automatically from your device or browser; * from public blockchain networks; * from wallet providers and other third-party services; * from service providers acting on our behalf; and * from public, legal, security, or compliance sources. ## 2. Use of Information We may use information for the following purposes: * Providing and operating the Services; * Connecting your wallet and displaying relevant protocol or transaction information; * Responding to support requests, feedback, and other communications; * Sending technical notices, security alerts, service updates, and policy updates; * Monitoring, detecting, preventing, and investigating fraud, abuse, security incidents, sanctions violations, and other unlawful activity; * Maintaining the security, availability, and integrity of the Services; * Improving the functionality, performance, and user experience of the Services; * Complying with applicable laws, regulations, legal processes, and governmental requests; * Managing business transactions such as a merger, acquisition, financing, reorganization, or sale of assets; * Enforcing our Terms of Use and other applicable policies; and * Processing information for other purposes disclosed at the time of collection or with your consent where required by law. We will not use personal information for purposes that are incompatible with the purposes described in this Privacy Policy unless permitted or required by applicable law. ## 3. Sharing and Disclosure of Information We may disclose information for the purposes described in this Privacy Policy to the following categories of recipients: * Service providers that support hosting, cloud storage, analytics, customer support, security, fraud detection, compliance, communications, and technical operations; * Blockchain infrastructure providers, RPC providers, blockchain explorers, bridges, wallet providers, and other third-party services involved in providing the Services; * Affiliates and related entities, where necessary to operate the Services, provide support, maintain security, comply with law, or manage our business; * Professional advisers, including lawyers, auditors, accountants, insurers, and financial advisers; * Government authorities, regulators, courts, law enforcement agencies, or other parties where disclosure is required or permitted by law; * Parties involved in a merger, acquisition, financing, reorganization, or sale of all or part of our business; and * Other parties with your direction or consent. We may also disclose aggregated or de-identified information that does not reasonably identify you, where permitted by applicable law. Service providers that process information on our behalf are required to use that information only for authorized purposes. Some third-party services may independently determine how they collect and use information and may be governed by their own privacy policies. ## 4. Third-Party Services The Services may link to or integrate with third-party wallets, blockchain networks, bridges, analytics tools, infrastructure providers, websites, and other services. These third parties may collect information directly from you or your device and may process it under their own privacy policies and terms. Yei Finance does not control the privacy practices, security, availability, or data retention practices of third-party services. You should review the applicable third-party privacy policies before using those services. ## 5. Cookies and Similar Technologies We may use cookies, local storage, pixels, software development kits, and similar technologies to operate, secure, analyze, and improve the Services. #### A. Strictly Necessary Technologies We may use technologies that are necessary to provide core features, maintain security, remember settings, connect your wallet, or prevent abuse. These technologies may not require consent where permitted by applicable law. #### B. Analytics Technologies We use analytics technologies, including Mixpanel, to understand how users interact with the Services and improve their performance. We will use analytics technologies only after obtaining consent where required by applicable law. #### C. Your Choices You can manage analytics preferences through \[ACTUAL CONSENT MANAGEMENT TOOL OR LINK]. You can also control cookies through your browser settings. Disabling certain technologies may affect the availability or functionality of the Services. #### D. Cookie and Technology List A current list of cookies and similar technologies, including the provider, purpose, category, and retention period, is available at \[COOKIE LIST URL]. ## 6. Analytics We use Mixpanel to analyze interactions with the Services, understand feature usage, identify technical issues, and improve the Services. Where consent is required, analytics will remain disabled until you opt in. You can change your analytics preference through \[ACTUAL SETTINGS LINK OR CONSENT TOOL]. If no consent-management tool is currently available, remove the statement that users can opt out through the "Manage Analytics" section. For more information about Mixpanel's processing practices, see the [Mixpanel Privacy Policy](https://mixpanel.com/legal/privacy-policy/). ## 7. Data Security We maintain administrative, technical, and organizational safeguards designed to protect information against unauthorized access, loss, misuse, alteration, disclosure, and destruction. These safeguards may include access controls, encryption where appropriate, monitoring, secure development practices, and vendor security reviews. No system or method of transmission over the Internet is completely secure. We cannot guarantee that information will never be accessed, disclosed, altered, or destroyed through a security incident. ## 8. Data Retention We retain information we collect as long as it is necessary to fulfill the purpose for which it was collected, as outlined in this Privacy Policy, and to the extent permitted by applicable legal requirements. If you request the deletion of your information, we may continue to retain and use your information as permitted or required under applicable laws for legal, tax, regulatory reasons, or legitimate and lawful business purposes. ## 9. International Transfers We and our service providers may process and store information in countries other than the country where you live. These countries may have data-protection laws that differ from those in your jurisdiction. When required by applicable law, we use appropriate safeguards for international transfers, such as an adequacy decision, standard contractual clauses, the UK International Data Transfer Addendum, binding corporate rules, or another legally recognized transfer mechanism. For information about the countries, recipients, and safeguards relevant to a particular transfer, contact us at . ## 10. Children The Services are intended for general audiences and are not directed at children. To use the Services, you must legally be able to enter into the Agreement. We do not knowingly collect personal information (as defined by the U.S. Children's Online Privacy Protection Act, or "COPPA") from children. If you are a parent or guardian and believe we have collected personal information in violation of COPPA, please contact us at , and we will remove the personal information in accordance with COPPA. ## 11. Additional Disclosures for California Residents These additional disclosures apply only to California residents. The California Consumer Privacy Act of 2018 ("CCPA") provides additional rights to know, delete, and opt-out, and requires businesses collecting or disclosing personal information to provide notices and the means to exercise consumer rights. ### A. Notice of Collection For further details on the information we may collect, including the sources from which we receive information, review the "Information Collection" section above. We may collect and use these categories of personal information for the business purposes described in the "Use of Information" section above, including to manage the Services. We do not "sell" personal information as defined under the CCPA. Please review the "Sharing and Disclosure of Information" section above for further details about the categories of parties with whom we share information. ### B. Right to Know and Delete You have the right to know certain details about our data practices within the past twelve (12) months. In particular, you may request the following from us: * The categories of personal information we have collected about you; * The categories of sources from which the personal information was collected; * The categories of personal information about you we disclosed for a business purpose; * The categories of third parties to whom the personal information was disclosed for a business purpose; * The business or commercial purpose for collecting or selling the personal information; and * The specific pieces of personal information we have collected about you. * In addition, you have the right to delete the personal information we have collected from you. To exercise any of these rights, please submit a request by emailing us at . In the request, please specify which right you are seeking to exercise and the scope of the request. We will confirm receipt of your request within ten (10) days. We may require specific information from you to help us verify your identity and process your request. If we are unable to verify your identity, we may deny your requests to know or delete. ### C. Authorized Agent You may designate an authorized agent to submit requests on your behalf; however, we may require written proof of the agent's permission to act on your behalf and verify your identity directly. ### D. Right of Non-Discrimination You have a right of non-discrimination for the exercise of any of your privacy rights guaranteed by law, such as the right to access, delete, or opt-out of the sale of your personal information. ### E. Shine the Light Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties' own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclose such information. To exercise a request, please write to us at the email or postal address set out in the "Contact Us'' section above and specify that you are making a "California Shine the Light Request." We may require additional information from you to allow us to verify your identity and are only required to respond to requests once per calendar year. ## 12. Additional Disclosures for Data Subjects in the European Economic Area and the United Kingdom ### A. Roles The General Data Protection Regulations in the European Economic Area and General Data Protection Regulations in the United Kingdom ("GDPR") distinguish between organizations that process personal data for their own purposes (known as "controllers") and organizations that process personal data on behalf of other organizations (known as "processors"). We act as a controller with respect to personal data collected as you interact with the Services. ### B. Lawful Basis for Processing The GDPR requires a "lawful basis" for processing personal data. Our lawful bases include where: * **(i) Consent**: You have given consent to the processing of your personal data for one or more specific purposes, either to us or to our service providers or partners. * **(ii) Contractual Necessity**: Processing your personal data is necessary for the performance of a contract between you and us. * **(iii) Legal Obligation**: Processing your personal data is necessary for compliance with a legal obligation. * **(iv) Legitimate Interests**: Processing your personal data is necessary for the purposes of the legitimate interests pursued by us or a third party, provided that your interests and fundamental rights and freedoms do not override those interests.Where applicable, we will transfer your personal data to third parties subject to appropriate or suitable safeguards, such as standard contractual clauses. | Purpose | Legal Basis | | ------------------------------------------------------ | ------------------------------------------------------------------------------------------------------- | | Operating and managing the Services | Necessary for the performance of our agreement | | To communicate with you | Necessary for the performance of our agreement | | Improving the Services | Legitimate interests, Consent | | To provide our Services | Legitimate interests, Consent | | Merger or Acquisition | Legitimate interests, legal obligation (when communicating with EEA, U.K., and Swiss regulatory bodies) | | Security and compliance with laws | Legal obligation, legitimate interests, necessary for the performance of our agreement | | Other purposes for which we have obtained your consent | Consent | ### C. Your Data Subject Rights If you are a user in the European Economic Area or the United Kingdom, you maintain certain rights under the GDPR. These rights 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; * (iv)request portability of your personal data. Additionally, if we have collected and processed your personal data with your consent, you have the right to withdraw your consent at any time. Notwithstanding the foregoing, we cannot edit or delete information that is stored on a particular blockchain. This information may include transaction data (i.e., purchases, sales, and transfers) related to your blockchain wallet address and any items held by your wallet address. To exercise any of these rights, please contact us via our email or postal address listed in the "Contact Us" section above and specify which right you are seeking to exercise. We will respond to your request within thirty (30) days. We may require specific information from you to help us confirm your identity and process your request. Please note that we retain information as necessary to fulfill the purpose for which it was collected and may continue to retain and use information even after a data subject request in accordance with our legitimate interests, including as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements. If you have any issues with our compliance, please contact us as set out in the "Contact Us" section above. You also reserve the right to lodge a complaint with the data protection regulator in your jurisdiction. ## 13. Changes to this Privacy Policy We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon our posting of the revised Privacy Policy. For the avoidance of doubt, your continued use of the Services indicates your consent to the revised Privacy Policy then posted. ## 14. Contact Us If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us by email: .