>>Privacy Policy

Privacy Policy

CryptHub Innovations s.r.o.

TABLE OF CONTENTS

1. GENERAL PROVISIONS
2. PERSONAL DATA CONTROLLER
3. AGE RESTRICTIONS
4. CATEGORIES OF DATA WE PROCESS
5. DATA WE DO NOT PROCESS
6. PURPOSES OF PROCESSING
7. LEGAL BASES (GDPR ART. 6)
8. USE OF ARTIFICIAL INTELLIGENCE
9. THIRD-PARTY SERVICES (PROCESSORS)
10. DATA RETENTION
11. STORAGE LOCATION & INTERNATIONAL TRANSFERS
12. USERS’ RIGHTS
13. DATA SECURITY
14. CHANGES TO THIS POLICY
15. CONTACT INFORMATION
AI ETHICS POLICY

1. General Provisions

This Privacy Policy sets out the procedure for collecting, processing, storing, and protecting the personal data of users of the CryptHub platform (the “Platform”), operated by CryptHub Innovations s.r.o. (the “Company”, “we”).

The Company processes personal data in accordance with:

Regulation (EU) 2016/679 (GDPR);
applicable EU rules and national data protection laws.

By using the Platform, the user confirms that they have read and understood this Policy.

2. Personal Data Controller

The personal data controller is: CryptHub Innovations s.r.o.

Registered address: Komarovova 402/6, Zábřeh, 700 30 Ostrava, Czech Republic

IČO: 21112690

Data protection contact email: [email protected] (Privacy Team)

3. Age Restrictions

The Platform is intended for users aged 16 and older.

The Company does not knowingly collect or process personal data of individuals under 16.

If the Company becomes aware of the unintentional collection of data of a person under 16, the Company will take reasonable steps to delete such data and/or deactivate the account.

4. Categories of Data We Process (Data Minimization Principle)

The Company processes only the data necessary for the Platform’s operation.

4.1 Users’ Personal Data

We may process:

email address;
username and account data;
IP address and technical identifiers of the request/device (e.g., user-agent);
technical logs of interactions with the Platform (security events, errors, diagnostics);
reviews, ratings, and comments voluntarily published by the user;
support requests and correspondence initiated by the user.

4.2 Public Blockchain Data

We may process:

public blockchain addresses;
transaction and activity data in public blockchain networks.

⚠ Important: Blockchain data is publicly available information in distributed ledgers. Depending on the context, public addresses and related data may be considered personal data if a person can be identified with a reasonable likelihood. The Company does not aim to identify individuals based on blockchain addresses and applies measures of minimization, aggregation, and separation of data (off-chain) where possible.

5. Data the Company Does Not Process

The Company does not collect or process:

passport and identity documents;
users’ KYC data;
individuals’ financial data (e.g., bank card/account details);
special categories of personal data under Article 9 GDPR.

6. Purposes of Processing Personal Data

Personal data is processed to:

provide access to the Platform’s functionality;
create and manage accounts;
ensure security and stability, prevent abuse and fraud;
publish user content at the user’s initiative;
communicate with the user (support, service notifications);
analyze and improve the service (where possible—in aggregated/anonymized form).

7. Legal Bases for Processing (GDPR, Art. 6)

The Company processes data on the following legal bases:

performance of a contract (Art. 6(1)(b) GDPR): registration, access to the account and functions;
consent (Art. 6(1)(a) GDPR): where required for certain optional features/settings (if applicable). Consent can be withdrawn at any time;
legitimate interest (Art. 6(1)(f) GDPR): security, infrastructure protection, prevention of abuse, and service improvement, subject to a balance of interests.

8. Use of Artificial Intelligence

8.1 General Provisions

The Platform may use AI technologies to analyze, systematize, and present information related to blockchain ecosystems and Web3 projects. AI is used for analytical and informational purposes.

8.2 Proprietary AI Models

CryptHub uses its own AI models which:

are deployed and operate on the Company’s servers in the EU (Germany and Finland);
are trained/fine-tuned on publicly available blockchain data and open sources;
are not trained on users’ personal data;
are not intended to identify individuals;
are not used for automated decision-making that produces legal effects or similarly significantly affects the user’s rights.

8.3 Use of External AI Tools

The Company may use external AI tools (including, but not limited to, OpenAI and Google Gemini) as technical tools for processing:

public data;
aggregated and/or anonymized data.

Users’ personal data is not intended to be transferred to external AI services and is not used by the Company to train such models. The Company applies minimization measures and technical restrictions to prevent the sending of personal data.

8.4 Human Oversight

AI outputs that may affect the perception of projects or users’ behavior are subject to human oversight and may be reviewed. AI outputs are not investment advice.

9. Third-Party Services (Processors)

The Company may use third-party services to ensure the operation, security, and resilience of the Platform, including:

OpenAI — a technical tool for processing public/aggregated/anonymized data;
Google Gemini — a technical tool for processing public/aggregated/anonymized data;
Cloudflare — protection and content delivery (e.g., CDN/WAF). In such use, technical request data (e.g., IP address, user-agent, traffic metadata) may be processed for security and service operation purposes.

The Company uses third-party services under contractual terms and applies data protection measures, including access restrictions and the principle of minimization.

10. Storage of Personal Data

We store personal data no longer than necessary for the processing purposes:

account data — for the duration of the account’s existence;
technical logs and security logs — for a limited period necessary to ensure security, investigate incidents, and improve stability;
support requests and correspondence — until request handling is completed and then for a reasonable period for quality control and legal protection.

After account deletion, data is deleted or anonymized unless otherwise required by applicable law or the Company’s legitimate interests (e.g., protection against abuse and dispute resolution).

⚠ Blockchain specifics: Records in public blockchains may be immutable and are not controlled by the Company. The Company may delete/anonymize data in its own infrastructure (off-chain) but cannot delete records from a public ledger.

11. Storage Location and International Transfers

Core infrastructure and data storage are organized on servers within the European Union (Germany, Finland).

When using certain third-party services, technical data may be processed by such services within their infrastructure and global network. In such cases, the Company applies GDPR protection mechanisms (e.g., contractual safeguards and other measures) and seeks to minimize the volume of processed data.

12. Users’ Rights

The user has the right:

to access their personal data;
to rectify data;
to erase data (“right to be forgotten”)—to the extent the data is controlled by the Company;
to restrict processing;
to object to processing (in cases of legitimate interest);
to data portability (where applicable);
to withdraw consent (if processing is based on consent);
to lodge a complaint with an EU supervisory authority.

Requests should be sent to: [email protected] (Privacy Team).

13. Data Security

The Company applies technical and organizational security measures, including:

encryption (where applicable);
access control and role/permission separation;
logging and monitoring;
infrastructure protection and regular updates.

14. Changes to This Policy

The Company reserves the right to update this Policy. The current version is published on the CryptHub website with the effective date.

15. Contact Information

For privacy matters: [email protected] (Privacy Team)

AI Ethics Policy

CryptHub Innovations s.r.o.

1. Purpose of the Document

This AI Ethics Policy defines the ethical, legal, and organizational principles for using artificial intelligence technologies within the CryptHub Platform and aims to:

comply with the GDPR and EU rules;
ensure transparency of AI systems;
protect users and the Web3 ecosystem;
prevent abuse and harm.

2. Scope

This Policy applies to all the Company’s AI systems, including:

proprietary AI models;
data analysis and classification algorithms;
automated information processing systems;
integrations with external AI tools (if used).

3. Core Ethical Principles

CryptHub adheres to the following principles:

lawfulness;
transparency;
data minimization;
accountability;
human oversight;
safety and resilience.

4. Data Used

CryptHub AI systems:

use public blockchain data and open sources;
do not use users’ personal data for training;
are not used to identify individuals;
apply aggregation and minimization where possible (e.g., removing direct identifiers and separating data environments).

5. Proprietary AI Models

CryptHub’s proprietary AI models:

are deployed on servers in the EU;
are trained on public data and open sources;
do not make automated legally significant decisions;
are used for analytical purposes and to improve the quality of information presentation.

6. Transparency of AI Use

CryptHub:

informs users about the use of AI in the Platform;
provides a general description of the purpose and logic of AI features in an understandable manner;
seeks to avoid “black boxes” in processes that may materially affect users.

7. Human Oversight

Material AI outputs:

are subject to human review and may be revised;
allow a correction mechanism (including upon a user’s request, where applicable);
do not replace expert judgment and do not create binding decisions for the user.

8. Prevention of Harm, Bias, and Manipulation

The Company:

identifies and assesses risks of harm, bias, and information distortion;
applies risk mitigation measures (validation, quality rules, monitoring);
prevents manipulative presentation formats and misleading users.

9. Investment Neutrality

CryptHub AI systems:

do not provide investment advice;
do not guarantee profitability;
do not encourage investment decisions;
provide information in an analytical/reference format.

10. Audit, Monitoring, and Accountability

The Company implements internal control procedures, including:

regular review of AI models and quality rules;
monitoring of errors and feedback;
corrective actions when issues are identified;
logging of material changes to AI logic (internal change log).

11. Users’ Rights and Requests

The user has the right to:

request information about the use of AI within the Platform;
request deletion of their content (to the extent the data is controlled by the Company);
challenge AI outputs or report an error/harm.

Requests should be sent to: [email protected] (AI Ethics / Privacy Team).

12. Risk and Incident Management

The Company maintains procedures for:

assessing risks of AI features before deployment and upon material changes;
incident response (errors, abuse, vulnerabilities, complaints);
updating security and quality measures based on investigation results.

13. External AI Tools

When using external AI tools, the Company:

applies the minimization principle;
seeks to prevent transferring users’ personal data;
uses such tools as technical components for processing public/aggregated/anonymized data;
appoints responsible persons for configuring and overseeing such integrations.

14. Policy Updates

The Policy is updated in case of:

changes in EU legislation;
development of AI regulation;
new regulator guidance and best practices.

15. Contacts

For ethics and AI matters: [email protected] (AI Ethics / Privacy Team)