PRIVACY POLICY

The following Privacy Policy governs the online information collection practices of Luganodes. It outlines the types of information that We gather about You while You are using our and/or when you use our Services / Platform.

Please read this Privacy Policy along with the Terms of Service ("Terms") carefully as by accessing or using the Platform or the Services, You agree to be bound by the terms described herein. Any personal information provided to Us is subject to this Privacy Policy.

IF YOU DO NOT AGREE TO ANY OR ALL OF THIS PRIVACY POLICY OR THE TERMS, DO NOT USE THE PLATFORM OR THE SERVICES. SHOULD YOU CONTINUE TO ACCESS AND USE THE PLATFORM AND PROVIDE YOUR PERSONAL INFORMATION, SUCH ACT WOULD CONSTITUTE YOUR CONSENT TO THE TERMS CONTAINED HEREIN.

All capitalized terms shall have the meaning ascribed to them in the Terms unless otherwise defined herein.

When and How the Information is collected?
1. Data You Provide: Personal data may be collected by Us as part of the Know-Your-Customer process, as specified from time to time. You as an individual, or an authorised representative of a business, may be require to provide certain documents and details. We may collect personal and sensitive personal information about You and store this information in connection with the provision and fulfilment of our Services to You, as further detailed in this Policy. Personal information may include: Name (First and Last), Email address, Contract Details, Role in the company, and KYC documents.
2. Data We Collect Automatically: When you visit and interact with our Platform or use Our Services, we may collect certain personal / non-personal information as below:
  1. Technical and Device Information: IP addresses, browser types, device identifiers, operating systems, and timestamps for security and analytics. After usage, the IP addresses of the users are removed or anonymized. Anonymization involves changing IP addresses in such a way that particular details of personal or factual situations cannot be attributed to a specific or identifiable real person, or can only be done with a disproportionate amount of time, money, and effort.
  2. Cookies and Tracking Data: Information gathered through cookies, web beacons, and similar technologies to enhance user experience and monitor website activity. The Platform uses temporary cookies to store certain data (that is not Personal Information) that is used by Us for maintenance of the Platform and its features as well as research and development, and for administration of your Account and Wallet. In the course of serving advertisements or optimizing services, We may allow authorized third parties to place or recognize a unique cookie on the your browser. We do not store Personal Information in the cookies.
  3. Transaction Data: Details of staking transactions and rewards processed through our Platform, including wallet details.
  4. Communication Records: Customer support inquiries, technical support requests, feedback submissions, survey responses, and interactions with our live chat, AI bots, or customer service teams.
  5. Audio, Electronic, and Visual Data: Voice recordings from customer support interactions (if applicable)
  6. Blockchain Data: Publicly available information from blockchain networks related to performance, staking history, and other relevant activities including preferences, delegation amounts, node participation records, governance voting, staking strategies, governance proposals, on-chain voting participation, forum discussions, and community input regarding network changes.
3. Data from Third-Party Sources: We may receive certain personal information from:
  1. Business Partners and Affiliates: To improve service delivery and marketing efforts.
  2. Analytics and Marketing Providers: For insights into user behavior and preferences, like Google analytics as detailed under c (iv) below.
  3. Regulatory and Compliance Sources: If required for legal, security, or fraud prevention purposes.
  4. Google Analytics: Google Analytics, a web analytics tool supplied by Google Inc., is used on this page (Google). Google Analytics uses cookies to help us understand how the website is used and make necessary technical, UX, and marketing optimizations. The cookie's information about your use of this website is typically sent to and stored on a Google server in the United States. If IP anonymization is enabled on this page, Google will first abbreviate your IP address inside European Union member states or other contracting states of the Agreement on the European Economic Area. In unusual instances, the complete IP address will be transferred to a Google server in the United States and abbreviated there. Google will use the information on behalf of the site operator to analyze website usage, generate reports on website activity, and offer the site operator other services relating to website and internet use. The legitimate interest in data processing lies in the optimization of this website, the analysis of the use of the website, and the adaptation of the content. The interests of the users are adequately protected by pseudonymization. The collection by Google Analytics can be prevented by the page visitor adjusting the cookie settings for this website. However, please note that if you do so, you may not be able to take full advantage of all the functions of this website. The collection and storage of the IP address and the data generated by cookies can also be objected to at any time with effect for the future. The corresponding browser plug-in can be downloaded and installed from the following link: https://tools.google.com/dlpage/gaoptout.
Why does Luganodes collect data?

At Luganodes, we collect and process minimal personal data to ensure the security, efficiency, and compliance of our services while enhancing user experience. The personal and identifiable data, if and when collected, serves multiple essential functions, as outlined below:
1. Delivering and Enhancing Our Services: Luganodes utilizes collected data to:
  1. Operate, manage, and optimize our staking platform, ensuring seamless functionality and improved user experience.
  2. Process staking transactions, validator rewards, and commission payments efficiently.
  3. Communicate critical information such as transaction confirmations, invoices, security updates, system notifications, and technical alerts.
  4. Generate de-identified, aggregated datasets for analytical and operational improvements.
2. Ensuring Security, Fraud Prevention, and Compliance
  1. Implement safeguards against spam, cyber threats, phishing attempts, and malware attacks.
  2. Conduct risk assessments, identify suspicious activities, and take appropriate actions to maintain platform integrity.
  3. Troubleshoot technical errors and ensure operational continuity.
  4. Enforce adherence to our Terms and investigate any violations or misuse of our Services.
  5. Fulfill regulatory obligations related to user verification and compliance with international financial and data protection laws.
3. Customer Support and User Engagement
  1. To provide efficient and responsive customer support.
  2. Address user queries and resolve concerns through various communication channels.
  3. Provide support through live chat, email, and/or other designated support platforms as supported by Us from time to time.
  4. Analyze support requests to enhance response efficiency and optimize service offerings.
  5. Offer guidance on troubleshooting, staking processes, and technical issues related to validator services.
  6. Maintain logs of interactions for quality assurance and dispute resolution.
4. Research, Development, and Performance Optimization: Luganodes is committed to innovation and continuous improvement. We may use collected data to:
  1. Conduct research and analysis to develop new features, enhance existing services, and improve staking performance.
  2. Identify patterns, trends, and user preferences to optimize our platform.
  3. Strengthen security measures to mitigate risks and vulnerabilities.
  4. Enhance fraud detection algorithms and develop automated solutions for system monitoring.
  5. Facilitate the integration of third-party tools that improve user experience and functionality.
5. Legal and Regulatory Compliance: As a participant in the blockchain and financial services ecosystem, Luganodes may be required to comply with various legal frameworks. We may collect and process personal data to:
  1. Adhere to Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) regulations.
  2. Verify user identity through government-issued documents and third-party compliance services, if and as required under the laws of Caymen Island or any other jurisdiction.
  3. Retain and report transaction records where legally mandated.
  4. Respond to legal inquiries, subpoenas, and regulatory requirements imposed by governing authorities.
  5. Mitigate financial risks and ensure compliance with industry-wide regulations.
  6. Enforce risk management strategies, including account restrictions in cases of non-compliance.
  7. If Users fail to provide legally required information, Luganodes reserves the right to restrict or terminate access as necessary, or take necessary legal action.
6. Marketing, Promotions, and User Communication: Luganodes may use collected data to:
  1. Deliver personalized marketing campaigns via email, push notifications, and in-app communications.
  2. Notify users about platform updates, promotions, staking opportunities, and ecosystem developments.
  3. Manage participation in events, webinars, surveys, and reward programs.
  4. Offer educational content on blockchain staking, validator operations, and network incentives.
What is not covered in this Policy?

NOTHING IN THIS PRIVACY POLICY SHALL APPLY TO DATA THAT IS ANONYMIZED, AGGREGATED, OR PUBLICLY AVAILABLE OR THE USER MATERIAL. WE MAY COLLECT, USE, AND PROCESS SUCH DATA FOR ANY PURPOSE WE DEEM FIT, INCLUDING BUT NOT LIMITED TO RESEARCH, ANALYSIS, STATISTICAL EVALUATION, MARKETING, PROMOTION, PRODUCT DEVELOPMENT AND OTHER BUSINESS DEVELOPMENT. THIS DATA MAY BE COMBINED WITH OTHER SOURCES AND USED IN A FORM THAT DOES NOT IDENTIFY ANY INDIVIDUAL, AND MAY BE SHARED, OR DISTRIBUTED IN ANY MANNER OR FORMAT WE FIND SUITABLE.

THE LUGANODES PLATFORM UTILIZES BLOCKCHAIN TECHNOLOGY, WHICH IS INHERENTLY DECENTRALIZED AND PUBLICLY ACCESSIBLE. TRANSACTIONS AND DATA STORED ON THE BLOCKCHAIN ARE TRANSPARENT AND CAN BE VIEWED BY ANYONE WITH ACCESS TO THE RELEVANT BLOCKCHAIN NETWORK. WHILE THE PLATFORM AIMS TO ENSURE SECURITY, PRIVACY, AND INTEGRITY OF TRANSACTIONS, LUGANODES DOES NOT CONTROL THE BLOCKCHAIN NETWORK, AND WE CANNOT GUARANTEE THE CONFIDENTIALITY, SECURITY, OR ACCURACY OF INFORMATION STORED OR TRANSMITTED ON THE BLOCKCHAIN. BY USING THE PLATFORM, YOU ACKNOWLEDGE AND ACCEPT THESE INHERENT CHARACTERISTICS OF BLOCKCHAIN TECHNOLOGY.
Consent Withdraw Policy: You have the right to withdraw your consent to the collection, processing, and use of your personal information at any time. If you wish to withdraw your consent, please contact us at [email protected]. Upon receiving your request, we will stop processing your data and take steps to delete your personal information, unless there is a legitimate legal basis for us to retain certain data (such as to comply with legal obligations or to enforce our agreements). Please note that withdrawing consent may limit our ability to provide you with certain Services, the Platform or respond to inquiries.
How we protect your personal data?
1. We do not sell your personal information to third parties since we value both your privacy.
2. We implement a variety of administrative, managerial, and technical security measures to help protect your personal information.
3. Our Company has internal control standards which relate specifically to the handling of personal information. These include certain controls to help safeguard the information we collect online.
4. Our employees are trained to understand and comply with these controls and we communicate our Privacy Policy practices and guidelines to our employees. However, while we strive to protect your personal information, you must also take steps to protect your information.
5. We urge you to take every precaution to protect your personal information, including the security keys, etc while you are on the Internet and Platform.
Who has access to your personal data within Luganodes?

Within our organization, access to your personal data is limited to those persons who require access in order to provide You with the Platform and/or Services, as detailed in the Section above. Employees only have access to data that is relevant to their team, on a 'need to know' basis.
Who do we share your personal data with outside our organization and why?
1. Processors: We may use service providers and third parties for operating and improving the Platform or the Services, to assist with certain functions, such as payment processing, email transmission, conducting surveys or contests, data hosting, managing our ads, third-party solutions for marketing and analytics, and some aspects of our technical and customer support. We take measures to ensure that these service providers access, process, and store information about You only for the purposes We authorize.
2. Authorities: We may access, preserve, and disclose information about you to third parties, including the content of messages if we believe disclosure is in accordance with or required by, applicable law, regulation, legal process, or audits. We may also disclose information about you if we believe that your actions are inconsistent with our Terms of Service or related guidelines and policies, or if necessary to protect the rights, property, or safety of, or prevent fraud or abuse of, Luganodes or others.
3. Transfer of business or Assets: In the event that Luganodes (or any of its assets) is involved in a merger, acquisition, reorganization, bankruptcy, or any other change of control, your personal information may be transferred as part of the business assets. In such cases, we may transfer or assign your personal information to the acquiring party, successor entity, or other third parties involved in the transaction. Any personal information transferred will remain subject to the terms of this Policy unless otherwise specified by the acquiring entity.
How long do we store information we collect from you?

We retain certain information collected from you while you are a member on the Platform or avail our Services (and thereafter for such period as required under Laws), and in certain cases where you have deleted your account, for the following reasons:
1. To better understand the traffic to our Platform so that we can provide all members with the best possible experience;
2. To detect and prevent abuse of our Platform, Services, illegal activities and breaches of our Terms of Service; and
3. To comply with applicable legal, tax or accounting requirements.
We retain personal data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates to, and the purposes for which we collected the data.
Our policy concerning children and their data

Our Platform and Services are not directed to children under the age of eighteen and we do not knowingly collect personally identifiable information from children or distribute such information to third parties. If we become aware that we have inadvertently received personally identifiable information from a child, we will delete such information from our records.
Links to other websites / parties

Our Platform and Services may contain links to other websites or services that are not operated by us. If you click on a third- party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. Third parties are under no obligation to comply with this Privacy Policy with respect to Personal Data that you provide directly to those third parties or that those third parties collect for themselves. We do not control the third-party sites that may be accessible through our Services. Thus, this Privacy Policy does not apply to information you provide to third-party sites or gathered by the third parties that operate them.
Yours rights under GDPR

You have certain rights if you are within the EU this includes:
1. Right to access. This right allows you to obtain a copy of your personal data, as well as other supplementary information.
2. Right to restrict processing. You have the right to restrict the processing of your personal data in certain circumstances.
3. Right to rectification. You have the right to have any incomplete or inaccurate information we hold about you corrected.
4. Right to object to processing. The right to object allows you to stop or prevent us from processing your personal data. This right exists where we are relying on a legitimate interest as the legal basis for processing your Personal Data. You also have the right to object where we are processing your Personal data for direct marketing purposes.
5. Right to erasure. You have the right to ask us to delete or remove Personal data when the personal data is no longer necessary for the purpose which you originally collected or processed.
To exercise your rights, You can contact us at [email protected]
Queries and complaints

We have appointed a data protection officer ("DPO") who is responsible for overseeing questions in relation to this Notice and our processing activities in general. If you have any questions or requests, including any requests to exercise your legal rights as a data subject, please contact the DPO using the details set out below.

Contact Details:

Name of DPO: Mr. Sanjeev
Email address: [email protected]