TrustLedger — Privacy Policy

Authors & Contributors: Kevin Le, Kellen Snider

Effective Date: June 9, 2026 Last Updated: June 30, 2026 Version: 2.2.0

Table of Contents

1. Introduction and Scope
2. Information We Collect
3. How We Use Information
4. Blockchain and Public Data
5. Cookies and Tracking Technologies
6. Third-Party Service Processors
7. Data Sharing and Disclosure
8. Data Retention
9. Security of Information
10. International Data Transfers
11. Your Rights and Choices
12. Children's Privacy
13. No Professional Advice
14. Limitations of This Policy
15. Changes to This Policy
16. Contact Information

1. Introduction and Scope

1.1 Who We Are. TrustLedger is a decentralized escrow, arbitration, and reputation platform operated by TrustLedger. This Privacy Policy describes how the Operator collects, uses, stores, shares, and protects information in connection with the TrustLedger Platform and Services.

1.2 Scope. This Policy applies to all users of the TrustLedger Platform, including the Frontend Application, API routes, email notification services, and related infrastructure, regardless of how they access the Services. It does not apply to third-party services or websites linked from the Platform.

1.3 Acceptance. By using the Services, You acknowledge that You have read and understood this Policy and consent to the collection, use, and processing of Your information as described herein, where consent is the applicable legal basis.

1.4 Relationship to Terms. This Privacy Policy is incorporated by reference into the Terms and Conditions. Capitalized terms not defined here have the meanings set forth in the Terms and Conditions.

1.5 Data Controller. For purposes of applicable data protection laws, including the GDPR and UK GDPR, the Operator of the TrustLedger Platform is the data controller of personal data collected in connection with the Services. Where the Operator engages third-party service providers to process data on its behalf, those parties act as data processors subject to contractual data processing obligations.

1.6 No Data Protection Officer. The Operator has not formally designated a Data Protection Officer (DPO) as of the Effective Date. The Operator has assessed whether a DPO appointment is required under applicable law. Users may direct all data protection inquiries to the contact address in Section 16.

2. Information We Collect

2.1 Information You Provide Directly.

(a) Email Address. If You use magic-link authentication or opt in to notifications, You provide Your email address. We use this to send magic links, deadline reminders, and service-related communications.

(b) User Content. You may submit contract documents, evidence, proof-of-work URIs, dispute summaries, and other content through the Services. Such content may be stored on the Platform or on IPFS.

(c) Feedback and Communications. If You contact us with questions, feedback, or bug reports, we retain records of such communications.

2.2 Information Collected Automatically.

(a) Wallet Address. When You connect Your Wallet to the Services, Your Wallet address is collected. Wallet addresses are pseudonymous but publicly visible on the blockchain.

(b) Transaction Data. Blockchain Transactions initiated through the Platform are recorded on-chain and permanently visible. We may also retain metadata about Transactions for operational purposes.

(c) Log Data. Our servers and third-party infrastructure providers may automatically collect server logs including IP addresses, browser type, operating system, referring URLs, pages visited, timestamps, and error data.

(d) Device and Browser Information. We may collect information about the device and browser You use to access the Services, including browser version, screen resolution, language preferences, and device identifiers.

(e) Usage Analytics. When privacy analytics are enabled, we may collect aggregate usage data such as page views and frontend error counts to improve the Services. TrustLedger's first-party analytics collector is disabled by default, honors Do Not Track and Global Privacy Control signals, strips query strings, and does not store wallet addresses, raw IP addresses, raw user-agent strings, email addresses, raw documents, encrypted draft bodies, session keys, private keys, or seed phrases.

(f) Cookies and Local Storage. See Section 5 for details on cookies and tracking technologies.

2.3 Information from Third Parties.

(a) Blockchain Data. We may retrieve publicly available data from blockchain networks, including transaction history, contract state, token balances, and wallet activity associated with wallet addresses used with our Services.

(b) Oracle Data. We receive exchange rate and market data from third-party oracle providers.

(c) Infrastructure Providers. Our cloud and infrastructure providers may provide us with operational data about service usage, errors, and performance.

2.4 Information We Do Not Collect. We do not collect:

(a) private keys, seed phrases, or wallet passwords (and you must never provide these to us);

(b) government-issued identification documents, unless we implement a KYC program;

(c) payment card numbers or banking information; or

(d) sensitive personal information such as racial or ethnic origin, health data, or biometric data.

3. How We Use Information

We use the information collected for the following purposes. For each purpose, we identify the lawful basis we rely upon under applicable data protection law (including the GDPR and UK GDPR where applicable). Where multiple bases may apply, we rely on the most appropriate one for the specific processing activity.

3.1 Service Delivery. To operate, provide, and maintain the Services, including processing Transactions, delivering notifications, managing sessions, and serving the Frontend Application. Legal basis: Performance of our agreement with You (GDPR Art. 6(1)(b)); or our legitimate interests in operating the Platform.

3.2 Authentication. To send magic links and verify user sessions. Legal basis: Performance of our agreement with You (GDPR Art. 6(1)(b)).

3.3 Notifications. To send deadline reminders, service alerts, and other operational communications related to the Services. Legal basis: Performance of our agreement with You (GDPR Art. 6(1)(b)); or Your consent where optional notifications are selected.

3.4 Security and Fraud Prevention. To detect, prevent, and respond to fraud, abuse, security threats, and violations of these Terms. Legal basis: Our legitimate interests in protecting the Platform and Users (GDPR Art. 6(1)(f)); or compliance with legal obligations (GDPR Art. 6(1)(c)).

3.5 Service Improvement. To analyze usage patterns, identify technical issues, and improve the Platform's features, performance, and user experience. Legal basis: Our legitimate interests in improving and operating the Platform (GDPR Art. 6(1)(f)).

3.6 Legal Compliance. To comply with applicable laws, regulations, legal processes, and governmental requests, including law enforcement demands and court orders. Legal basis: Compliance with legal obligations (GDPR Art. 6(1)(c)).

3.7 Enforcement. To enforce our Terms and Conditions, resolve disputes between Users, and protect our rights and the rights of Users. Legal basis: Our legitimate interests in enforcing our legal rights (GDPR Art. 6(1)(f)).

3.8 Communication. To respond to inquiries, feedback, and support requests. Legal basis: Our legitimate interests in maintaining User communications (GDPR Art. 6(1)(f)); or performance of our agreement with You.

3.9 Aggregate Analytics. To produce anonymized or aggregated analytics that do not identify individual users. Legal basis: Our legitimate interests in understanding Platform usage. Fully anonymized or aggregated data that cannot identify an individual is not subject to data protection law.

3.10 Withdrawal of Consent. Where processing is based on Your consent, You may withdraw that consent at any time by contacting us at the address in Section 16 or by following the unsubscribe instructions in any communication. Withdrawal of consent does not affect the lawfulness of processing based on consent before withdrawal, and does not affect processing conducted on other legal bases.

4. Blockchain and Public Data

4.1 Public Nature of Blockchain Data. All Transactions submitted to a blockchain are permanently and publicly visible on the relevant blockchain network. This includes:

(a) wallet addresses involved in Transactions;

(b) transaction amounts, timestamps, and function calls;

(c) escrow contract terms encoded in the Smart Contracts;

(d) evidence hashes and URIs submitted on-chain;

(e) juror selections, votes, and rulings; and

(f) reputation ratings.

4.2 No Deletion of On-Chain Data. The Operator has no ability to delete, modify, or obscure any data recorded on a public blockchain. Any request to delete on-chain data cannot be fulfilled. This is an inherent characteristic of public blockchain technology.

4.3 IPFS Content. Content pinned to IPFS is publicly accessible via the IPFS network and may be cached or republished by any node. Requests to delete IPFS content cannot be guaranteed to result in complete removal from the IPFS network.

4.4 Pseudonymity Limitations. Wallet addresses are pseudonymous, not anonymous. Blockchain analytics tools and public records may allow third parties to associate wallet addresses with real-world identities. The Operator is not responsible for deanonymization by third parties.

5. Cookies and Tracking Technologies

5.1 Types of Technologies Used. The Platform may use the following technologies:

(a) Essential Cookies. Cookies necessary for the operation of the Platform, including session management and security features. These cannot be disabled without affecting core functionality.

(b) Functional Cookies. Cookies that remember Your preferences and settings to improve Your experience.

(c) Analytics Technologies. Technologies that collect aggregate usage data to help us understand how the Platform is used and how to improve it.

(d) Local Storage. Browser local storage may be used to persist wallet connection state, session information, and user preferences.

5.2 Third-Party Cookies. Third-party services integrated into the Platform (such as analytics providers or wallet connection software) may set their own cookies or use tracking technologies. We do not control third-party cookies.

5.3 Cookie Control. You can control cookies through your browser settings. Disabling essential cookies may prevent You from using certain features of the Platform. A separate Cookie Policy may be published in the repository. Until published, the disclosures in this Section 5 constitute the Operator's full cookie disclosure. Requests for additional information about specific cookies used may be directed to the address in Section 16.

6. Third-Party Service Processors

6.1 Processors. In operating the Platform, we share data with third-party service providers that process data on our behalf, including:

6.2 Processor Obligations. We engage third-party processors subject to contractual obligations designed to protect data. However, we cannot guarantee the data practices of third-party processors and are not responsible for their independent data collection and use.

6.3 Third-Party Privacy Policies. Each third-party service provider has its own privacy policy. We encourage You to review the privacy policies of services You interact with.

7. Data Sharing and Disclosure

7.1 We Do Not Sell Data. We do not sell, rent, or trade Your personal information to third parties for their marketing purposes.

7.2 Service Providers. We share information with third-party service providers as described in Section 6 for the purpose of operating the Services.

7.3 Legal Requirements. We may disclose information: (a) in response to valid legal process, including subpoenas, court orders, warrants, or other lawful requests from governmental or law enforcement authorities; (b) to comply with applicable laws or regulations; (c) to protect the rights, property, or safety of the Operator, Users, or the public; or (d) in connection with fraud prevention or security investigations.

7.4 Business Transfers. If the Operator is involved in a merger, acquisition, reorganization, sale of assets, or bankruptcy, information about Users may be transferred as part of such transaction. We will use reasonable efforts to provide notice if information is transferred under materially different privacy practices.

7.5 Aggregated Data. We may share aggregated or de-identified information that cannot reasonably be used to identify You with third parties for analytics, research, or publication purposes.

7.6 With Your Consent. We may share information in other circumstances with Your prior consent.

8. Data Retention

8.1 General Retention. We retain non-public personal data for as long as necessary to fulfill the purposes described in this Policy, including to provide the Services, comply with legal obligations, resolve disputes, and enforce our Terms.

8.2 Email Data. Email addresses associated with magic-link sessions are retained for as long as necessary to deliver notifications and for a reasonable period thereafter for legal and audit purposes. Users may request deletion as described in Section 11.

8.3 Log Data. Server logs and usage analytics may be retained for a limited period for security and performance purposes, after which they are deleted or anonymized.

8.4 Blockchain Data. Data recorded on a blockchain is permanently retained on that blockchain and cannot be deleted by the Operator.

8.5 IPFS Data. Content pinned to IPFS may persist indefinitely on the IPFS network regardless of whether the Operator maintains an active pin. The Operator may discontinue pinning at any time but cannot guarantee content removal from the network.

8.6 Legal Hold. We may retain data beyond normal retention periods if required by applicable law, ongoing litigation, regulatory inquiry, or law enforcement request.

9. Security of Information

9.1 Security Measures. The Operator implements reasonable technical and organizational measures designed to protect non-public data against unauthorized access, alteration, disclosure, or destruction. These measures include transport layer encryption (TLS), server-side security controls, and access limitations.

9.2 No Absolute Security. No security system is impenetrable. THE OPERATOR CANNOT GUARANTEE THE SECURITY OF ANY DATA TRANSMITTED TO OR FROM THE SERVICES. DATA BREACHES, UNAUTHORIZED ACCESS, AND LOSS OF DATA ARE INHERENT RISKS OF OPERATING ANY ONLINE PLATFORM. You use the Services at your own risk.

9.3 User Responsibility. You are responsible for the security of Your own device, Wallet credentials, seed phrases, private keys, and email account. The Operator is not responsible for losses resulting from compromise of Your credentials or devices.

9.4 Breach Notification. In the event of a security breach that may affect Your non-public data, the Operator will use reasonable efforts to notify affected Users and, where required, applicable supervisory or regulatory authorities within the timeframes required by applicable law. Under the GDPR and UK GDPR, reportable breaches must generally be notified to the relevant supervisory authority within 72 hours of discovery; where feasible, affected individuals will also be notified without undue delay. Under applicable U.S. state data breach notification laws, notification timelines vary. The Operator will follow the most stringent applicable requirement.

10. International Data Transfers

10.1 Global Operations. The Services may be operated from and may process data in the United States and in other countries. By using the Services, You consent to the transfer, storage, and processing of Your information in any jurisdiction where the Operator or its third-party service providers operate.

10.2 Transfer Mechanisms. Where we transfer personal data from the European Economic Area, the United Kingdom, Switzerland, or other jurisdictions with data transfer restrictions, we implement appropriate safeguards in accordance with applicable law to the extent required. Appropriate safeguards may include European Commission Standard Contractual Clauses (SCCs), the UK International Data Transfer Agreement (IDTA), or other mechanisms recognized under applicable law. Copies of relevant transfer mechanisms may be obtained by contacting us at the address in Section 16.

10.3 Varying Privacy Standards. Other jurisdictions may provide lesser privacy protections than Your home jurisdiction. By using the Services, You acknowledge and accept this risk.

11. Your Rights and Choices

11.1 Access and Correction. Depending on Your jurisdiction, You may have the right to request access to, or correction of, personal data we hold about You. To make such a request, contact us at the address in Section 16. We will respond to requests within the timeframes required by applicable law (generally 30 days under the GDPR; 45 days under the CCPA, subject to a 45-day extension where reasonably necessary). For data stored locally in Your browser (Your preferences, consent choices, connected wallet address, and wallet-connection records), You can download a copy at any time using the "Download My Data" control in Your account settings, which produces a structured, machine-readable JSON file.

11.2 Deletion (Right to Erasure). You may request deletion of certain non-public personal data we hold about You, such as Your email address. We will honor deletion requests to the extent technically feasible and consistent with our legal obligations (including data retention obligations). We cannot delete data recorded on public blockchains or permanently pinned to IPFS. Deletion requests may be denied where data is required for the performance of a contract, compliance with a legal obligation, or the establishment, exercise, or defense of legal claims. You can also erase all data stored locally in Your browser — preferences, consent choices, and wallet-connection records — at any time using the "Delete My Data" control in Your account settings; this signs Your wallet out of the device but cannot affect immutable data already recorded on public blockchains.

11.3 Opt-Out of Notifications. You may opt out of non-essential email notifications by following the unsubscribe instructions in any email we send or by contacting us. You cannot opt out of service-essential communications (such as security notices or legally required disclosures).

11.4 Cookie Controls. You can control cookies through your browser settings. Essential cookies cannot be disabled without affecting core functionality. You can also review, change, or withdraw Your cookie and analytics consent at any time using the in-app cookie preferences manager, available from the site footer and Your account settings. Details on the specific cookies used and instructions for controlling them are available upon request to the address in Section 16.

11.5 GDPR and UK GDPR Rights. If You are located in the European Economic Area, the United Kingdom, or Switzerland, You may have the following rights under the GDPR, UK GDPR, or equivalent laws:

(a) Right of Access — to obtain a copy of Your personal data and information about how it is processed (Art. 15 GDPR);

(b) Right to Rectification — to correct inaccurate personal data (Art. 16);

(c) Right to Erasure — to request deletion in certain circumstances (Art. 17);

(d) Right to Restriction — to restrict processing in certain circumstances (Art. 18);

(e) Right to Portability — to receive Your data in a structured, commonly used, machine-readable format, where technically feasible (Art. 20);

(f) Right to Object — to object to processing based on legitimate interests (Art. 21);

(g) Right to Lodge a Complaint — You have the right to lodge a complaint with Your national data protection supervisory authority (Art. 77 GDPR). For EEA residents, You may contact the supervisory authority in the EU member state where You reside, work, or where the alleged infringement occurred. For UK residents, You may contact the Information Commissioner's Office (ICO) at ico.org.uk. The Operator's primary establishment for GDPR purposes, if applicable, is in the United States.

Contact us at the address in Section 16 to exercise any of these rights.

11.6 CCPA / CPRA Rights. If You are a California resident, You may have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

(a) Right to Know — what personal information we collect, use, disclose, and sell;

(b) Right to Delete — personal information we have collected from You;

(c) Right to Correct — inaccurate personal information;

(d) Right to Opt Out of Sale / Sharing — we do not sell or share personal data for cross-context behavioral advertising;

(e) Right to Limit Use of Sensitive Personal Information — we do not process sensitive personal information beyond what is necessary to provide Services;

(f) Right to Non-Discrimination — we will not discriminate against You for exercising any CCPA/CPRA right.

To submit a verifiable consumer request, contact us at the address in Section 16.

11.7 Other U.S. State Privacy Rights. If You reside in Virginia, Colorado, Connecticut, Texas, or another U.S. state that has enacted a comprehensive privacy law, You may have rights similar to those described above, depending on Your state's law. Contact us to inquire about available rights in Your state.

11.8 Verification. To protect Your privacy, we may verify Your identity before processing any access, correction, deletion, or other data request.

11.9 Limitations. We may be unable to fulfill certain requests if doing so would interfere with our ability to operate the Services, comply with applicable law, fulfill our legal obligations, or establish, exercise, or defend legal claims.

12. Children's Privacy

12.1 Not for Children. The Services are not directed to children under the age of eighteen (18). We do not knowingly collect personal information from children under the age of eighteen. If we learn that we have collected personal information from a child under eighteen, we will take steps to delete it promptly.

12.2 COPPA. We do not knowingly collect personal information from children under the age of thirteen (13) within the meaning of the Children's Online Privacy Protection Act (COPPA). If You are a parent or guardian and believe that Your child under 13 has provided us with personal information, please contact us at the address in Section 16, and we will take steps to delete such information promptly.

12.3 Reporting. If You believe we may have inadvertently collected information from a child under eighteen, please contact us at the address in Section 16.

12.4 Shine the Light (California). California Civil Code § 1798.83 permits California residents to request information about third parties to whom the Operator has disclosed personal information for direct marketing purposes during the preceding calendar year. The Operator does not disclose personal information to third parties for direct marketing purposes and therefore does not maintain records responsive to this section. California residents may contact us at the address in Section 16 to confirm this policy.

13. No Professional Advice

Nothing in this Privacy Policy constitutes legal advice regarding data protection law, GDPR compliance, CCPA compliance, or any other privacy regulation. You should consult a qualified privacy attorney regarding Your specific data protection obligations.

14. Limitations of This Policy

14.1 No Guarantees. This Policy describes our current data practices, but we cannot guarantee that all data handling will occur exactly as described due to technical limitations, third-party behavior, or unforeseen circumstances.

14.2 Blockchain Immutability. This Policy cannot and does not govern data recorded on public blockchains, as such data is outside the Operator's control.

14.3 Third-Party Sites. This Policy does not apply to third-party websites, services, or applications linked from the Platform, even if accessed through the Platform.

15. Changes to This Policy

We may update this Privacy Policy at any time. Material changes will be communicated by updating the "Last Updated" date and, where appropriate, by posting a notice on the Platform. Your continued use of the Services after any modification constitutes Your acceptance of the updated Policy.

16. Contact Information

Privacy inquiries, data access requests, and deletion requests:

TrustLedger Email: kevinle3212@gmail.com Repository: https://github.com/kevinle3212/TrustLedger

This Privacy Policy (Version 2.1.0) was last reviewed and updated on June 10, 2026, following a comprehensive legal red-team audit. Changes include: GDPR legal basis identification for each processing activity; data controller and DPO disclosure; expanded data subject rights (GDPR Art. 77 supervisory authority right; CCPA/CPRA rights; multi-state U.S. privacy rights); COPPA compliance statement; breach notification timeline specifics; SCC/IDTA transfer mechanism disclosure; consent withdrawal mechanism; California Shine the Light disclosure; cookie policy correction; response timeline commitments; and first-party privacy analytics disclosure.