This Privacy Policy explains how Gingk collects, uses, shares, and protects information relating to you when you use Gingk’s websites, applications, and related features (collectively, the “Gingk Services”). The data controller for the Gingk Services is the Gingk team (“Gingk,” “we,” “us,” or “our”).
This Privacy Policy applies to the Gingk Services. It does not apply to any third-party website, wallet, product, or protocol that you access through Gingk.
1. Information We Process
1.1 Current Website
When you browse Gingk, we may process:
- Usage and Interaction Data: A randomly generated visitor identifier created by your browser, the types of pages you visit, the internal identifiers of products you view, the dates and times of your visits, and records of your clicks on links that redirect you to third-party subscription channels, for analytics and potential referral fee settlement purposes. When combined with information such as your IP address, this identifier may still constitute personal information in most jurisdictions. We therefore treat it as personal information and apply the same standard of protection even though it does not contain your name, email address, or wallet address;
- Technical Information: Your IP address, browser and device type, request timestamps, and necessary error and security logs; and
- Contact Information: Your email address, name (if provided), and the content of your communications when you voluntarily email us or submit feedback.
1.2 Wallet and On-Chain Features
If you use wallet or on-chain features that have been made available, we may process the public wallet address, selected network, connection or signing status, and related public on-chain transaction and holdings data necessary to perform the operation you request.
Gingk will not ask for, collect, or store your private keys or seed phrase. Public on-chain records may exist permanently and generally cannot be modified or deleted by Gingk.
1.3 Features Not Yet Available
The current public website does not provide user accounts, know-your-customer (“KYC”) verification, or on-site order management. We expect to introduce registration and account features in the future. When those features become available, the processing of account-related information, such as account details, identity verification information, order information, and compliance information, will be based on the applicable legal basis, including performance of an agreement. Before launching such features, we will update this Privacy Policy or provide a separate notice and, where required by law, obtain your consent.
2. Sources of Information
We obtain information through the following means:
- Directly from you, such as when you send us an email or connect a wallet;
- Automatically from your browser and our servers when you use the Gingk Services; and
- From public blockchains, node service providers, or relevant product providers when you use wallet or on-chain features.
3. Purposes and Legal Bases for Processing
| Purpose | Main Categories of Information | Legal Basis (Where Applicable) |
|---|---|---|
| Displaying the website and providing features you request | Technical information; wallet and on-chain information | Taking steps at your request or our legitimate interests; if you have registered an account, performance of our agreement with you also applies |
| Measuring usage, improving content and user experience, and administering referral fee arrangements | Random visitor identifier; page and product views; outbound-link events | Your consent; or, where permitted by local law, our legitimate interests |
| Securing the Gingk Services, preventing misuse, and troubleshooting | IP address; device and request information; error and security logs | Our legitimate interests or compliance with legal obligations |
| Responding to inquiries and handling complaints | Contact information and communications | Performance of an agreement, our legitimate interests, or your consent |
| Complying with law and protecting legal rights | Information relevant to the particular matter | Compliance with legal obligations or the establishment, exercise, or defense of legal claims |
Gingk does not use your personal information to provide personalized investment advice or make decisions based solely on automated processing that produce legal or similarly significant effects concerning you. Product risk assessments concern products, not individuals.
4. Local Storage, Cookies, and External Resources
4.1 Gingk currently uses the gingk-visitor browser local storage item for all visitors to store a random visitor identifier. We use this identifier to distinguish repeat visits and measure website usage, without differentiating based on a visitor’s location. You may clear this identifier at any time through your browser settings.
4.2 If the laws of your jurisdiction require prior consent or impose other specific protections in relation to non-essential usage analytics of this kind, your rights under those laws are not limited by this Privacy Policy. You may contact us using the details in Section 13 to learn more about the applicable processing or use your browser settings to reject or clear the identifier.
4.3 Certain pages may currently load fonts from Google Fonts. When they do, your browser sends your IP address and necessary request information directly to Google. Before formally publishing this Privacy Policy, we plan to review this arrangement and prioritize hosting fonts locally.
4.4 We currently do not use third-party advertising cookies, engage in cross-site behavioral advertising, or sell or rent personal information. If these practices change, we will update this Privacy Policy and provide legally required choices.
5. Sharing of Information
We disclose information only to the extent necessary to the following recipients:
- Service providers that provide cloud hosting, databases, storage, networking, security, fonts, or technical support;
- Node operators, wallet providers, and product service providers involved, at your direction, in wallet connections, on-chain queries, or related features;
- Authorities or other parties entitled to receive information in order to comply with applicable law, a court order, or a regulatory requirement, or to protect the rights and safety of users, Gingk, or others; and
- Professional advisers and transaction counterparties in connection with a merger, financing, restructuring, or transfer of assets, subject to appropriate confidentiality safeguards.
We require service providers acting on our behalf to process information only in accordance with our instructions and for the agreed purposes. Where a third party processes information as an independent controller, its own privacy policy applies.
6. Third-Party Links and Blockchain
When you follow a third-party link, you leave Gingk. The third party will receive information directly from your browser or wallet, and Gingk cannot control how that information is processed. Please review the third party’s privacy policy before using its services.
Wallet addresses and on-chain transaction records are generally public, may be analyzed by third parties, and may be linked to an individual’s identity. Do not disclose through Gingk or any other service wallet information that you do not wish to make public.
7. Cross-Border Processing
Gingk’s primary infrastructure is currently located in Johor, Malaysia and is provided by cloud service providers. For transfers outside the jurisdiction in which our infrastructure is located, we will conduct the cross-border transfer assessments required by current Malaysian law. For information originating from the European Union, the United Kingdom, or other regions with specific cross-border transfer requirements, we will, where appropriate, use recognized transfer mechanisms such as Standard Contractual Clauses (“SCCs”) and require recipients to provide appropriate safeguards. You may contact us using the details in Section 13 to inquire about the specific safeguards in place.
8. Data Retention
We retain your personal information only for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, comply with applicable legal obligations, resolve disputes, or establish, exercise, or defend legal claims. Specific retention periods vary depending on the type of information, the purpose of processing, and applicable legal requirements. When retention is no longer necessary, we will delete, anonymize, or otherwise securely dispose of the relevant information, unless a longer retention period is required by law.
9. Information Security
We implement technical and organizational measures proportionate to the relevant risks, including access controls, safeguards for data in transit, permissions management, and backups where necessary. No internet or blockchain service can guarantee absolute security. If you become aware of a suspected security issue, please contact us promptly.
If a security incident involving personal information occurs that is likely to pose a risk to your rights and freedoms, we will notify the appropriate supervisory authorities and affected users within the time limits required by applicable law.
10. Your Rights
Depending on the laws applicable where you reside, you may have the right to:
- Access and obtain a copy of the personal information we hold about you;
- Correct inaccurate information;
- Request deletion of, or restriction of processing concerning, your information;
- Object to processing based on legitimate interests;
- Obtain a portable copy of your information;
- Withdraw your consent without affecting the lawfulness of processing carried out before withdrawal; and
- Lodge a complaint with a competent data protection authority.
You may also clear the gingk-visitor identifier from your browser. Because this identifier does not contain contact information, we generally cannot locate the corresponding records using only a name or email address. To process your request, we may ask you to provide the identifier or other information reasonably necessary to verify the request.
These rights may be subject to exceptions under applicable law. We will not discriminate against you for lawfully exercising your privacy rights.
11. Minors
The Gingk Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected such information, we will take reasonable steps to delete it.
12. Changes to This Privacy Policy
We may update this Privacy Policy and will publish the new version and its last-updated date within the Gingk Services. If we make material changes, we will notify you through a prominent notice or by other appropriate means. Where consent is required by law, we will obtain it separately.
13. Contact Us
If you have any questions about this Privacy Policy or our processing of personal information, or if you wish to exercise your rights, please contact us:
- Email: support@gingk.com