NeoCoins Privacy Policy

Introduction

The NeoCoins platform is one of the utilities of the NeoLea ecosystem, enabling various blockchain-based features such as token transactions, staking rewards, and community governance. This Privacy Policy explains how the NeoCoins project team (“NeoLea”, “we”, “us”, or “our”) collects, uses, and protects your personal information when you interact with our website, token services, and related features. By using NeoCoins and our services, you agree to the practices described in this Policy. We are committed to complying with applicable data protection laws, including the European Union’s General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), to safeguard your privacy rights.

Scope: This Policy applies solely to NeoCoins and its direct functionalities (such as the NLC presale, on-chain transactions, staking, and our official website). It does not cover any other products or services outside of NeoCoins. We do not integrate any third-party advertising platforms, and we do not employ marketing or analytics trackers that compromise your privacy.

Information We Collect

We aim to minimize the personal data we collect. The information we may collect and process includes:

• Information You Provide Voluntarily: If you contact us via our website (support@neocoins.io) or participate in any NeoCoins-related program, you may provide personal details such as your name, email address, and any information you include in your message. For example, when sending an inquiry or subscribing to an update, we collect your contact details and correspondence so we can respond to you.
• Wallet and Transaction Data: When you interact with NeoCoins blockchain features (such as participating in the NLC token presale, conducting token transactions, or staking your NLC tokens), we may record your public blockchain wallet address and transaction details. This data is inherent to blockchain operations and is publicly recorded on the blockchain ledger. While wallet addresses are pseudonymous (not directly identifying you by name), they may be considered personal data if combined with other identifying information. We do not collect any private keys, seed phrases, or wallet secret information from you – never share these with anyone, including us.
• Automatically Collected Data: When you visit our website or use online services for NeoCoins, certain information is collected automatically for security and functionality. This includes technical data such as your device type, operating system, browser type, IP address, and usage logs (e.g. timestamps of visits and actions on the site). We use this information to safeguard our platform (for example, monitoring for suspicious activity) and to improve performance (like ensuring compatibility with popular browsers). This technical data is generally collected in an aggregate and non-identifying manner.
• Cookies and Similar Technologies: We use minimal cookies on our site, strictly limited to those necessary for core functionality (such as maintaining a user session or remembering preferences). We do not use any third-party advertising cookies, tracking pixels, or marketing analytics that follow you across other sites. The cookies we set, if any, are primarily to ensure the website works correctly (for instance, if you log into a secure area or if we implement a language preference). You will not encounter targeted ads or unrelated tracking through our platform. You have the option to disable cookies in your browser settings; however, note that doing so might affect certain basic features of our site (for example, if in the future we introduce a login or forum feature for the community).
• Optional Survey or Feedback Data: (If applicable) From time to time, we may run optional surveys or collect feedback from NLC holders to improve our token’s utility or community experience. Participation in such activities is voluntary, and you will be informed of any personal data requested (such as an email or Telegram handle for follow-up). Any data you provide for these purposes will be used only for the stated purpose and handled in line with this Policy.

No Sensitive Personal Data Collected: We do not actively collect sensitive personal information such as your financial account numbers, government-issued IDs, or biometric data through the NeoCoins platform. The NeoCoins project does not require any personal identity verification (KYC) for general use of the token at this time. If future regulatory obligations require identity checks for certain transactions (for example, large token purchases or exchange listings), we will provide a clear notice and collect such information through a secure, compliant process. In any case, unless mandated by law, we avoid collecting sensitive data about our users.

How We Use Your Information

We use the limited information we collect for the following core purposes related to NeoCoins and its services:

• Providing and Improving Our Services: We process your data to deliver the services you expect. For example, if you participate in the NLC presale or staking program, we use your wallet and transaction information to credit your account with tokens or calculate your staking rewards. If you contact us with a question, we use your email and message to communicate with you and resolve your inquiry. We may also use aggregated technical data and feedback to improve our website’s user experience, fix performance issues, and develop new features that enhance NeoCoins’ utility.
• Transaction Execution and Verification: NLC is a blockchain-based token. When you initiate a token transaction or staking operation, your public blockchain address and the details of that operation are used to execute the transaction on the blockchain network. We may temporarily log these transaction details on our backend systems to verify execution and provide you with confirmation (for instance, showing your updated token balance or staking status on a user dashboard). All such on-chain transactions are immutable public records on the blockchain; we use your data solely to facilitate and confirm these operations for you.
• Security and Fraud Prevention: We are committed to maintaining a secure platform for all NeoCoins participants. The automatically collected technical information (like IP addresses and usage logs) is used to detect and prevent malicious or unauthorized activities. For example, we may use IP information to mitigate distributed denial-of-service (DDoS) attacks or to detect multiple fraudulent participation entries in a token airdrop. This data helps us safeguard user accounts, protect against hacking attempts, and ensure the integrity of token transactions and staking processes. Our use of this data is limited strictly to security and abuse prevention purposes.
• Legal Compliance: We may process and retain certain data as necessary to comply with our legal and regulatory obligations. For instance, if applicable laws require us to maintain transaction records for auditing or tax purposes, or to prevent illicit activities (such as money laundering or terrorist financing), we will use the relevant information (e.g. transaction logs or identity data if provided) to fulfill those obligations. Additionally, if we are required by law enforcement or regulatory authorities to provide information, we will only disclose what is legally mandated. Importantly, we do not use your personal data for any marketing or advertising purposes, and we do not engage in selling or renting your information to any third parties.
• Communication and Updates: With your consent, we may use your contact information to send you important updates related to NeoCoins. For example, we might email you about major platform announcements, security alerts, changes to this Privacy Policy, or information about upcoming governance votes or token features. We will only send you such communications if you have provided your contact info for this purpose (such as subscribing to a newsletter or requesting notifications). You can opt out of non-essential communications at any time. Transactional or service-related communications (for example, a confirmation email if you made a presale contribution and provided an email for a receipt) are sent as needed to fulfill our services to you.

Legal Bases for Processing (GDPR): If you are in a jurisdiction that requires a lawful basis for processing personal data (such as the EU under GDPR), our legal bases include: (a) Performance of a Contract – we process data to provide the services you request (e.g., delivering tokens you purchased, enabling staking rewards, responding to your inquiries is part of our user agreement with you); (b) Legitimate Interests – we use certain data to secure and improve our platform (our legitimate interest in maintaining a safe, efficient token ecosystem, balanced against your privacy rights); (c) Consent – where applicable, we rely on your consent (for example, sending marketing communications or collecting optional feedback); and (d) Legal Obligation – when processing is necessary for us to comply with laws or regulations. We only rely on consent as a legal basis for optional uses – and where we do, you have the right to withdraw your consent at any time.

Data Sharing and Disclosure

Your privacy is important to us. We do not sell or rent your personal information to third parties for marketing or any other purpose. We also do not use third-party ad networks or social media “pixels” that would share your information for advertising. We only share personal data in a few limited circumstances:

• Service Providers (Processors): We may share certain information with trusted third-party service providers who help us operate the NeoCoins platform and deliver our services. Examples include web hosting providers, database/cloud storage services, email service platforms (for sending out newsletters or support responses), or analytics tools that help us understand aggregated usage (if we use one, it would be configured in a privacy-compliant manner without tracking individuals). When we engage service providers, we ensure they are bound by contractual obligations to process personal data only on our instructions and in compliance with this Policy and applicable law. They are not permitted to use your data for their own purposes.
• Blockchain and Decentralized Networks: Transactions involving NLC tokens (such as transfers or staking events) are recorded on a public blockchain (distributed ledger). By design, any data published to the blockchain (including your wallet address and transaction details) will be visible to the public and may be processed by a global network of nodes. This data is immutable and outside of our direct control once written to the blockchain. Important: Because of this, when you use NeoCoins, some information (your blockchain transactions) is inherently shared publicly. This is a fundamental aspect of blockchain technology and not something we have the ability to limit or erase. We do not consider this “third-party disclosure” under our control, but it is a form of data transparency you should be aware of.
• Legal Compliance and Protection: We may disclose personal information if required to do so by law or in the good faith belief that such action is necessary to: (i) comply with a legal obligation, judicial or government requests, or an applicable court order (for example, responding to a subpoena or lawful request related to a fraud investigation); (ii) enforce our Terms of Service or other agreements, or investigate potential violations thereof; or (iii) protect the rights, property, or safety of NeoLea, our users, or the public. If we receive a government or regulatory request for user data, our policy is to review it carefully, require proper authority (such as a warrant or court order), and only then disclose the minimal data necessary to comply.
• Business Transfers: In the unlikely event that the NeoCoins project undergoes a major business transaction, such as a merger, acquisition by another organization, or sale of some or all assets, personal data may be transferred to the successor or new owner as part of that transaction. Should this happen, we will ensure that the new owner understands that your information must remain protected under terms at least as strict as this Privacy Policy, and we will provide notice of any change in data ownership or use, giving you the opportunity to discontinue use of the services if you desire.

Apart from the situations listed above, no other parties receive your personal data. In particular, we do not share user information with advertisers, analytics companies, or social media platforms for marketing purposes. We maintain strict confidentiality of your data within our organization.

International Data Transfers

NeoCoins is a global project – by nature of the internet and blockchain, data may be processed in various countries. If you are located outside of the regions where our servers or team members are based, your personal data (such as contact or technical data) may be transferred across international borders. Regardless of where data is processed, we apply the same high standards of privacy protection. For users in the European Economic Area (EEA) or United Kingdom, if we transfer personal data out of the EEA/UK (for example, to a service provider in the United States or another country), we will ensure an appropriate transfer mechanism is in place as required by GDPR. This may include using providers in countries deemed adequate by the European Commission, or implementing standard contractual clauses (SCCs) or other lawful safeguards to protect your information. Our aim is to ensure that your data receives equivalent protection as it would under local privacy laws, no matter where it is stored or processed.

Data Security

We take data security seriously and implement industry-standard security measures to protect your information from unauthorized access, alteration, disclosure, or destruction. These measures include, for example: encryption of data in transit (HTTPS is enforced on our website to secure data exchange), firewalls and network monitoring to guard against external attacks, regular security audits of our smart contracts and web infrastructure, and access controls to ensure that any sensitive information is only accessible to authorized team members who need it to perform their duties. Internally, our team members are educated about privacy and security best practices. Any personal data we hold (such as email correspondence or user inquiries) is stored on secure platforms with strict access controls and is only accessible on a need-to-know basis. We periodically review our security procedures to incorporate new technologies and address emerging threats.

No system is 100% secure: While we strive to protect your data, we cannot guarantee absolute security. Blockchain transactions, by their nature, are secured by cryptographic mechanisms, but it’s also important that you take steps to protect your own information. Never share your private keys or seed phrases with anyone – our team will never ask for them. Use strong, unique passwords for any accounts related to crypto, and enable two-factor authentication (2FA) where applicable. If you suspect any unauthorized access to your personal data or accounts related to NeoCoins, please notify us immediately so we can help secure your account and investigate.

Data Retention

We retain personal information only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable laws and regulations. This means:

• Contact and Inquiry Data: If you reach out to us or submit a support request, we will retain your contact information and communications for as long as needed to address your inquiry or provide you with assistance. We may keep a record of our correspondence (support@neocoins.io) to reference if you have future questions, and to improve our customer service. These records are typically kept for a reasonable period, after which they are securely deleted, unless we are legally required to retain them longer.
• Presale and Transaction Records: For any token sale contributions or on-platform transactions, we may retain associated records (transaction logs, amounts, blockchain addresses involved) for audit and compliance purposes. Financial and transaction data might be retained for a certain number of years as required under financial regulations or tax laws, even if our direct interaction with you has ended – this ensures we can demonstrate compliance with laws and respond to any legal inquiries. However, this data will not be used for any other purpose beyond what is necessary for compliance and record-keeping.
• Technical Logs: Our server and security logs (which may include IP addresses and device information) are generally retained only for a short duration (typically a few weeks up to a few months) unless we are actively investigating a security incident in which the logs are pertinent. We periodically purge or anonymize these logs when they are no longer needed.
• Staking Information: If you participate in staking NLC tokens, the details of your stake (amount staked, duration, and earned rewards) are recorded on the blockchain and possibly in our application’s database for user interface purposes. On-chain staking records are permanent (by nature of the blockchain). Any off-chain copy or summary of this staking info that we maintain will be kept only as long as the staking program is active or as required for dispute resolution and support. If staking ends or you withdraw, off-chain records may be pruned or archived in anonymized form.

Once personal data is no longer necessary for the purpose it was collected, we will either delete it or anonymize it (so it can no longer be linked back to you). Please note: Data recorded on public blockchains (such as transaction history) cannot be altered or deleted by us, and may persist indefinitely outside our control – this includes your NLC transactions and staking records on the blockchain ledger. However, any personal data we hold in our systems can be deleted or anonymized per your requests and according to our retention policies.

Your Rights & Choices

We respect your rights to control your personal information. Depending on your jurisdiction, you may have some or all of the following rights regarding the personal data we hold about you:

Rights Under GDPR (EU/EEA and Similar Jurisdictions)

If you are located in the European Union, EEA, UK, or other regions with similar data protection laws, you have the following rights under GDPR (and applicable local legislation):

• Right to Access: You have the right to request a copy of the personal data we hold about you and to obtain information about how we process it. We will provide you with a summary of the data and details of its use, subject to applicable law.
• Right to Rectification: If any personal data we have about you is incorrect or incomplete, you have the right to have it corrected or updated. For example, if you believe we have an incorrect email address on file, you can ask us to fix it.
• Right to Erasure: You can request that we delete your personal data. We will honor this “right to be forgotten” for the information we control, provided we do not have a legal obligation to retain it. For instance, if you had previously contacted us and want your inquiry emails removed from our records, we can erase those. Keep in mind that we cannot remove data that is stored on the public blockchain (e.g., your past NLC transactions) since we do not control the blockchain ledger. However, any data we store off-chain will be erased upon valid request (after verifying your identity for security).
• Right to Restrict Processing: You have the right to ask us to suspend the processing of your personal data in certain circumstances – for example, if you contest the accuracy of the data or have objected to our processing (pending a resolution). This means we would hold the data but not use it during the restriction period.
• Right to Object: You may object to our processing of your data if you feel it impacts your fundamental rights and freedoms. For example, you can object to data processed under our legitimate interests (like for improvement or security), and we will assess your request. You also have an unconditional right to object to your personal data being used for any direct marketing.
• Right to Data Portability: Where applicable, you have the right to request a copy of certain personal data in a structured, commonly used, machine-readable format so you can transmit it to another service. This typically applies to data processed based on your consent or for performance of a contract.
• Right to Withdraw Consent: If we rely on your consent to process any personal data (for instance, if you subscribed to a newsletter), you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing we did prior to your withdrawal.
• Right to Lodge a Complaint: If you have concerns about our data practices, you have the right to lodge a complaint with a supervisory data protection authority in your country. We would appreciate the chance to address your concerns directly first, but you are fully entitled to contact your local authority.

Rights Under CCPA (California Residents)

If you are a California resident, the California Consumer Privacy Act (CCPA) provides you with specific rights regarding your personal information:

• Right to Know: You have the right to request that we disclose what personal information we collect, use, and share about you. This includes the categories of personal information, the categories of sources from which that information is collected, our business purpose for collecting it, the categories of third parties with whom we share it, and specific pieces of personal information we hold about you.
• Right to Delete: You have the right to request that we delete personal information we have collected from you (and direct our service providers to do the same), subject to certain exceptions.
• Right to Opt-Out of Sale: We do not sell your personal information to third parties. Therefore, under CCPA, there is no need for you to request an opt-out – we don’t disclose your data in a way that constitutes a “sale” under CCPA definitions.
• Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Exercising Your Rights: To exercise any of your rights under GDPR, CCPA, or other privacy laws, please contact us using the contact information provided in the next section. We may need to verify your identity or authority to make the request (especially for access, deletion, or download requests) by asking for some information. We aim to respond to valid requests as promptly as possible, typically within 30 days for GDPR requests and within 45 days for CCPA requests. Please note that some rights may not be absolute.

Children’s Privacy

NeoCoins and its services are not directed to children under the age of 18. We do not knowingly collect personal information from anyone under 18 years old.

Third-Party Links

Our website or documentation may contain links to third-party websites or services for your convenience or information. Please note that this Privacy Policy does not apply to those third-party sites or services, which are outside of our control.

Updates to This Privacy Policy

We may update or revise this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make changes, we will update the “Last Updated” date at the top of this Policy. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your information.