Privacy Policy

General

Helix Hub S.A. with the address at Oceania Business Plaza, 21st Floor, Punta Pacifica, City of Panama, Republic of Panama (“us”, “we”, “our”, or “Company”) owns and operates this website (which, for the avoidance of doubt, includes all content, functionality, subdomains, and services) (collectively, the “Interface”). We are committed to respecting and protecting your privacy in respect of information collected through or in connection with this Interface.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at the following email:dpo@helixfinance.io.

We take our applicable responsibilities under Republic of Panama’s Law No. 81 of March 26, 2019, supplemented by Executive Decree No. 285 of May 28, 2021 (together, the Ley sobre Protección de Datos Personales; the “Data Protection Law”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This privacy policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us (“Personal Data”), as well as to assist you in making an informed decision before providing us with any of your personal data (“Privacy Policy”).

Any terms used in this Privacy Policy that are not expressly defined herein shall have the meanings ascribed to them in our Terms of Service. Please refer to the Terms of Service for any additional definitions of clarifications.

This Privacy Policy, together with our Terms of Service and any other agreements that you agree to be bound by in the course of your use of this Interface, sets out the basis on which we use and process any personal data we collect from you as a user of this Interface, whether as a guest or a registered user. In the event and to the extent only of any conflict or inconsistency between any of these documents, the agreement for a particular service found on the Interface will prevail. By accessing and using the Interface you hereby agree to be bound by the terms of this Privacy Policy.

In addition, this Interface may, from time to time, contain links to and from the websites of our partner networks, affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies and you access and provide your personal data to these third party websites at your own risk. Please check these policies before you submit any personal data to any such websites.‍

Children Under the Age of 18

The Interface, Protocol, and the Services are not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at dpo@helixfinance.io.

Information We Collect

We may collect and process data about you, including but not limited to:

  1. Information that you may provide when filling in forms on, or otherwise submitting or making available information to, this Interface. This includes but is not limited to any information provided when you create an Account and/or register as a user of this Interface or for any services made available via the Interface such as your name, email address and contact details;
  2. Available information on an underlying blockchain, including, without limitation, your public blockchain address (but excluding any private keys), account balances, crypto-asset holdings, blockchain transaction history, interaction history with smart contracts or “decentralized applications,” or any data included in a data field associated with your public blockchain address transactions (“Blockchain Identifiers”);
  3. Any correspondence you may have with us;
  4. Information that may be captured via any error logging and reporting tool that captures error report data and sends this data to us in order for us to be informed of any software errors or problems that may occur during your use of the Interface or the Services provided on it;
  5. Details of your visits to our Interface, the activities you engage in when using the Services made available via the Interface and the resources that you access on or via the Interface;
  6. Information that may be captured through your cookies and other forms of data analytics applications or services which may be used on the Interface; and
  7. Your responses to surveys that we might ask you to complete for research purposes.

You may also provide information for publication or display (“Posted”) on public areas of the Interface or the Protocol (collectively, “User Contributions”). Your User Contributions are Posted and transmitting to others at your own risk. Additionally, we cannot control the actions of third parties when whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. This paragraph (and this Privacy Policy generally) does not apply to information provided by borrowers specifically for the purposes of soliciting or servicing liquidity provided through the Protocol, which may be subject to another document separately executed by the user.

How We Use Your Information

We may use information held about you for the following purposes:

  1. To process, administer and/or manage your Account with us;
  2. To analyze and utilize the information provided by you in order to present content and information on the Interface in the most suitable manner for you and the equipment and devices from which you view the Interface;
  3. To inform you of investment and/or funding opportunities which we, in our sole and absolute discretion, think may be of interest to you;
  4. To contact you through the contact information provided by you in order to provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
  5. To provide you with any services that you may request from us from time to time(whether paid for or not) and to communicate with you in relation to those services;
  6. To manage and administer your Account and contact you as may from time to time be necessary in connection with your use of the Interface and/or the services made available on it;
  7. To contribute to the facilitation and operation of the Protocol;
  8. To collect information relating to your online interactions with us (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalized experience in your relationship with us and better serve your needs by customizing the content and services and that we share with you;
  9. To store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Panama;
  10. For record-keeping purposes;
  11. To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our Interface, services and facilities in order to enhance the Services we provide to you, where you have consented to be contacted for such purposes;
  12. To respond to legal process, pursue legal rights and remedies, defend litigation and manage any complaints or claims;
  13. To respond to requests for information from public and governmental / regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes;
  14. To comply with any applicable law, regulation, legal process or government request;
  15. To enforce or apply our Terms of Service; or
  16. To protect the rights, property or safety of any person (including for the purposes of fraud detection and prevention)

Disclosure of Your Information

Your personal data may be used, disclosed, maintained, accessed, processed, and/or transferred to the following third parties, for the purposes set out above:

  1.  Other Members of the Interface;
  2.  Our subsidiaries, affiliates, and other related corporations;
  3. Third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us to : (a) to provide and maintain any IT equipment used to store and access your personal information; (b) to host and maintain this Interface; or (c) otherwise in connection with the provision of the Services provided to you on or via this Interface;
  4. Our auditors, legal advisors, professional advisors, contractors, service providers, and other third parties we use to support our business;
  5. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Interface is among the assets transferred;
  6. To fulfil the purpose for which you provide it. For example, if you give us an email or Account address to message a member our Interface, we will transmit the contents of your message and your email or Account address to the recipients;
  7. For any other purpose disclosed by us when you provide the information;
  8. To enforce our rights arising from any contracts entered into between you and us, including (without limitation) the Terms of Service;
  9. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our entities, the Protocol, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and scam deterrents;
  10. Public and governmental/regulatory authorities, statutory boards, industry associations;
  11. Courts and other alternative dispute forums; and
  12. Any third party in connection with (a) the sale of any of our business or assets, in which case we may disclose your personal data to the prospective buyer of such business or assets; or (b) the acquisition of us or substantially all of our assets by a third party, in which case personal data held by us about you and our other customers will be one of the transferred assets.

Third Party Information Collection

When you access the Interface or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  1. Analytics companies.
  2. Your device manufacturer.
  3. Your service provider.

When you use the Interface, certain third parties may use automatic information technologies to collect information about your on-chain activities. These third parties may include:

  1. Blockchain explorers.
  2. Decentralized infrastructure providers.
  3. Your Web3 service
  4. Any DAO or other entity that controls, interacts with, or provides services related to the Protocol.
  5. Any other party with access to the underlying blockchain

These third parties may use tracking technologies to collect information about you when you use the Interface or the Protocol. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible party directly.

Protection of Your Information

We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of your personal data.

We have entered into contractual undertakings to ensure that the personal data which we collect from you and transfer to our service providers is adequately protected.

Where we have given you, or where you have chosen, a password to access certain parts of the Interface or your Account, you should not share this password with others.

Updating Your Information

Where you submit information on the Interface, you should try to ensure such information is accurate and let us know if such information changes so that we are not holding any inaccurate information about you. If you have registered an Account for the Interface, you can review and update your personal information yourself at any time by logging in to your account.

Your Rights

Access: You may obtain your Personal Data, know its origin, and the purpose for which it has been collected.

Rectification: You may request the correction of your Personal Data if you consider the Personal Data provided to be incorrect, irrelevant, incomplete, outdated, inaccurate, false, or inappropriate.

Cancellation: You may request the deletion of your Personal Data, if you consider that it is incorrect, irrelevant, incomplete, outdated, inaccurate, false, or inappropriate. The Personal Data cannot be deleted if the storage of the Personal Data is required by special laws, such as laws for prevention of money laundering or taxation, among others.

Objection: When you consider that there are well-founded and legitimate reasons related to a particular situation, you may refuse to provide your Personal Data or to be subject to a certain processing, as well as revoke your consent. The objection shall be given within a period not exceeding ten (10)working days following the request. If applicable, no alternate measures to our policies and procedures may be applied to comply with the due diligence, AML, KYC, and/or CTF requirements to access our Interface, Protocol, and/or Services.

Portability: You have the right to obtain a copy of the Personal Data in a structured manner, in a generic and commonly used format when:

  1. You have provided your Personal Data directly to us.
  2. You have consented to the processing or the Personal Data is required for the performance or execution of a contract.

All these rights from 9(a) to 9(e), as a whole, are called “ARCO Rights”. You may exercise these rights at any time. These rights cannot be waived, except for the exceptions established in special laws.

Request Processing

To request the fulfilments of your ARCO Rights, you must send a formal request to us, to the email address dpo@helixfinance.io.The request must contain the following information in order to provide you with a prompt response:

  1. First and last name;
  2. Email address;
  3. Contact telephone number(s);
  4. Means by which you wish to be contacted by us, in response to your request;
  5. A copy of your personal identification document (identity card or passport);
  6. In the case of being represented by an attorney, provide the power of attorney that authorizes the attorney to carry out the process;
  7. Provide a clear and precise description of the Personal Data with respect to which you are seeking to exercise any of your ARCO Rights, revoke consent, or refusal or use or data for secondary purposes; and
  8. Provide the information or document that may assist in the processing of the request.

Cookies

We use cookies on the Interface. A cookie is a text file that a website transfers to your computer's hard disk so that the website can remember who you are. Cookies only record those areas of a website that have been visited by your computer and for how long.

The Interface uses the following two types of cookies:

  1. Session Cookies - these are temporary cookies which remain on your computer until you leave the Interface and allow you to carry information across pages of the Interface without having to re-enter information.
  2. Persistent Cookies - these remain on your computer after you leave the Interface.

You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our Interface if cookies are disabled.

Changes to This Privacy Policy

We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our Interface. You are expected to check this page from time to time to take notice of any changes we have made as they are binding on you. Your continued use of this Interface, the Protocol and/or the Services made available on or via the Interface following any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms.

Important Note About Public Blockchains

Information stored on a blockchain may be public, immutable, and not easily removed or deleted. Your transactions and addresses may reveal information about you, and information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. We do not control how other parties may use this information and cannot provide you any protection related to such information. Use our Interface at you own risk.

Contact Us

If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact our Data Protection Officer at dpo@helixfinance.io.