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What this policy covers

This Privacy Policy explains how CruTrade collects, uses, and protects personal information when you access or use the Crutrade Platform and related Services.  This Privacy Policy forms part of and should  be read in conjunction with our Terms of Service. Unless otherwise defined herein, all terms shall have the meaning assigned to them in the Terms of Service. 

By accessing the Platform or using the Services (as defined in our Terms of Service), you acknowledge and agree to the collection, use, and disclosure of your information in accordance with this Privacy Policy. The Platform operates on blockchain technology where transaction data, wallet addresses, and NFT interactions are publicly accessible and immutable. By using our Platform, you acknowledge and consent to the public nature of blockchain data associated with your activities. If you do not agree with our practices, you must not use the Platform or Services, and you are not authorized to access them.

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Information We Collect: ‍The Company may collect various types of information from or about you when you use our Service to ensure a seamless experience, comply with legal obligations, and improve our offerings. This section outlines the categories of data we may collect and how they are obtained.

1. Information you provide to us:
   
   • Account Information: Email address, username, cryptocurrency wallet address, payment details, linked social media accounts, user/usage patterns or preferences, and display settings. Some information except email addresses may be publicly visible and may persist online after account removal.
     
     
   • Verification Information and Shipping: For wine collection, we or our storage/shipping partners may collect name, address phone number, date of birth, government-issued ID details, and verification photos through KYC processes.
     
     
2. Information collected automatically:
   
   • Transaction data: NFT purchase, sale, and transfer details including prices, timestamps, all public information on blockchain such as transaction details, holdings etc.
     
     
   • Technical information: Browser type, operating system, IP address, device ID, geolocation, blockchain wallet addresses, clickstream data, referral pages, and session timestamps collected via cookies and pixel tags.
     
     
   • Communication data: Support interactions including emails, chat messages, attachments, and any other customer support.
     
     
3. Cookies and similar technologies: We may use cookies, pixel tags, and analytics tools that continue operating regardless of "Do Not Track" browser settings. Third-party services (Google, analytics providers, wallet integrators) may collect usage information under their own privacy policies.

Information from third parties: We may receive data about you from external sources to support our operations or enhance your experience:

1. Wallet Providers: Third-party wallet providers may share your blockchain wallet address and any additional details you authorize them to disclose when connecting to Crutrade.
   
   
2. Verification Services: We may use third-party KYC providers to facilitate wine bottle collection or other related activities, they may share verification outcomes (e.g., “ID valid”) or related details.

How we use your information

We use your information for the following purposes:

1. To provide and improve the service: Manage your account, process transactions, enhance listing fulfillment, user experience and other obligations in the Crutrade ecosystem.
   
   
2. To comply with legal obligations: Meet regulatory requirements, including anti-money laundering (AML) and KYC for listing redemption, as well as other related laws.
   
   
3. To communicate with you: Respond to inquiries, send service-related notices (e.g., fee reminders), and, with your consent, provide marketing materials.
   
   
4. To personalize your experience: Tailor content, recommendations, and features based on your preferences and usage.
   
   
5. To ensure security: Detect and prevent fraud, unauthorized access, or violations of our Terms of Service.

Information Sharing

We share your data only with trusted entities. Here’s a comprehensive overview:

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1. Service Providers
   
   • Blockchain Networks: Share wallet addresses and transaction data to process NFT activities (e.g., Ethereum, Polygon).
   • Payment Gateways: Facilitate cryptocurrency payments or fiat conversions (if applicable).
     
     
   • Analytics Partners: Provide anonymized data to tools like Google Analytics or Mixpanel for usage insights.
     
     
   • KYC Vendors: Share verification details with third-party services to authenticate your identity.
     
     
   • Hosting and Storage: Use cloud providers to securely store and back up your data.
     
     
2. Warehousing, Storage and Shipping Partners
   
   • Collection coordination: Share your shipping details, NFT possession proof, and KYC results with our Partners for wine retrieval and delivery.
     
     
   • Inventory updates: Exchange data on bottle conditions or storage logistics.
     
     
3. Legal and Compliance Entities
   
   • Government agencies: Disclose data to regulators, tax authorities, or law enforcement when legally compelled (e.g., AML investigations).
     
     
   • Dispute resolution: Share relevant details with mediators or courts if a legal dispute arises (e.g., ownership claims).
     
4. Business transactions: Transfer data to a successor entity during mergers, acquisitions, or bankruptcy proceedings, with confidentiality safeguards.
   
   
5. Public and user sharing
   
   • Blockchain Visibility: NFT transactions and wallet addresses are inherently public on the blockchain.
     
     
   • Platform Visibility: Your username and trade history may be visible to other Crutrade users.
     
     
   • Consent-Based Sharing: With your approval, share data with marketing partners or third-party apps.

Data Security

We have implemented appropriate technical and organizational measures designed to protect the security of your personal information. However, please note that no method of transmission over the Internet or method of electronic storage is fully secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security

Your Rights

Depending on your location, you may have certain rights regarding your personal information, such as:

• Access and Information: You may have the right to access and receive information about the personal information we maintain about you.
  
  
• Correction: You may have the right to request that we correct inaccurate or incomplete personal information about you.
  
  
• Deletion: You may have the right to request the deletion of your personal information in certain circumstances.
  
  
• Restriction of Processing: You may have the right to request that we restrict the processing of your personal information in certain circumstances.
  
  
• Data Portability: You may have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that information to another controller in certain circumstances.
  
  
• Objection: You may have the right to object to the processing of your personal information in certain circumstances.
  
  
• Withdraw Consent: If we rely on your consent to process your personal information, you may have the right to withdraw your consent at any time.
  
  
• Complaint: You may have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

To exercise any rights, please contact us using the information provided in the "Contact Us" section below.
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‍Data Retention

We may retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, as well as applicable legal requirements.
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Children's Privacy

Our Services are not directed to children under the age of 18, and we do not knowingly collect personal information from children under 18. If you are a parent or guardian and you believe your child has provided us with personal information, please contact us, and we will take steps to delete such information from our systems.

Third-Party Links And Services

Our Services may contain links to other websites, applications, or services we do not operate. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review every site's privacy policy. We have no control over and assume no responsibility for any third-party sites or services' content, privacy policies, or practices.

International Users

If you are accessing our Services from outside the European Union or European Economic Area, please be aware that your information may be transferred to, stored, and processed in countries where our servers are located and our databases are operated. By using our Services, you consent to this transfer, storing, or processing.

Changes to This Policy

We may update this policy periodically. We will notify you of significant changes via email or through our platform.

Contact Us

If you have questions about this policy or our privacy practices, you can  contact us at:

• Email: privacy@crutrade.io

• Address: CRUDEX UAB, Vilnius, Zalgirio g.88-101, Lithuania

For inquiries related to the Crurated warehouse or physical wine handling, please contact Crurated Limited at support@crurated.com.

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