Privacy Policy

In this Policy, “Sury Protocol,” “we,” “us,” and “our” refer to the entity that operates the website at this domain and the related services. The entity is [Operating Entity, Jurisdiction], registered at the address shown at the end of this Policy.

We act as the “data controller” for the personal information described in this Policy, except where otherwise stated. If you have questions about how your information is handled, the contact details are in section 10.

This Policy applies to:

• Visitors to our website and any subdomains we operate.
• People who interact with us by email, social channels, or other support mechanisms we operate.
• Counterparties in business transactions (institutional partners, service providers).

This Policy does not cover:

• On-chain activity. Blockchain data is public and we are not the controller of it. When you connect a wallet to our interface, the wallet address you sign with becomes part of an on-chain record we cannot modify or delete.
• Third-party sites linked from ours. Those have their own privacy policies and we have no control over them.

We collect information in three ways.

Information you give us directly. If you contact us by email, sign up for any communication, or correspond with us about a partnership, you give us your name, email address, and whatever else is in the message. If you complete any form on our site, we receive what you put in that form.

Information we collect automatically. When you visit our website, our hosting infrastructure logs basic technical information for security and operational purposes:

• IP address (truncated where feasible)
• Browser type and version, device type, operating system, referring URL
• Time of access, pages requested, and response codes
• Cookies and similar technologies, as described in the Cookie Policy

Information from third parties. If you connect a wallet to our interface, the public wallet address is shared with our front-end. We do not custody, store, or transmit private keys. We may use [third-party services such as analytics, wallet-connect providers, fraud-prevention tools] that may collect their own technical information when you use the site. Those vendors are listed in the Cookie Policy.

We use the information described above for the following purposes, each backed by an appropriate legal basis where applicable law requires one:

We do not sell personal information, and we do not use it for automated decision-making with legal or similarly significant effects.

We share information only where it is necessary for one of the purposes above, and only with parties bound by appropriate contractual safeguards.

• Service providers. Hosting, email delivery, analytics, security, and customer-support vendors process information on our behalf. They are bound by contracts that restrict their use of the information to what we instruct.
• Professional advisors. Lawyers, auditors, and accountants who need access to specific information for their professional services to us.
• Authorities, when required. If we are compelled by a valid legal process or where disclosure is necessary to protect rights, property, or safety, we may share information with public authorities or other third parties as required.
• In a corporate transaction. If we are involved in a merger, acquisition, or sale of assets, information may be transferred as part of that transaction. We will require any successor to honour the terms of this Policy.

A current list of our key processors is available on request to the contact in section 10.

Our infrastructure and our service providers may be located in countries outside your country of residence. Where we transfer personal information across borders, we rely on appropriate safeguards such as Standard Contractual Clauses, adequacy decisions, or other mechanisms recognised under applicable law.

You may request a copy of the safeguards in place for any specific transfer by contacting us at the address in section 10.

We retain information only as long as necessary for the purposes for which it was collected, or as required by law:

• Email correspondence: typically up to three (3) years from last contact.
• Server access logs: typically up to thirty (30) days, unless retained longer for security investigation purposes.
• Records required for legal compliance: for the period required by the applicable law (typically up to seven (7) years for tax and corporate records).

When we no longer need information for any of these purposes, we delete or anonymise it.

Depending on your location and applicable law (including the EU/UK GDPR, the California Consumer Privacy Act, and similar regimes), you may have the right to:

• Access the personal information we hold about you.
• Correct inaccurate or incomplete information about you.
• Request deletion of information, subject to retention obligations we are required to honour.
• Object to certain uses or restrict processing.
• Receive a copy of information you provided to us in a portable, machine-readable format.
• Withdraw consent where processing is based on consent — without affecting the lawfulness of processing before withdrawal.
• Lodge a complaint with a supervisory authority. For users in the EEA or UK, that is the data protection authority of your country.

To exercise any of these rights, contact us using the details in section 10. We will respond within the timeframe required by applicable law (usually one month).

We use technical and organisational measures designed to protect personal information against unauthorised access, alteration, disclosure, or destruction. These include encryption in transit, access controls, monitoring, and periodic security reviews.

No system is perfectly secure. If we ever become aware of a personal data breach affecting your information, we will notify you and the relevant authorities within the timeframes required by applicable law.

For privacy questions, requests, or concerns, contact us at:

If you are in the EU, we will appoint an EU representative as required by Article 27 GDPR; their details will be added here once confirmed.

We may update this Policy from time to time. The “Effective date” at the top of this page reflects the current version. Material changes will be communicated through the website or, if we hold your contact details, by email. Continued use of our services after changes take effect indicates your acceptance of the updated Policy.