Privacy Policy

Last updated: January 2024

1. General Information

Sol Trader (“we”, “us”, or “our”) operates the DIZON platform, which provides digital certificates of authenticity for artworks and collectibles using blockchain technology. This privacy policy explains how we collect, use, and protect your personal information when you use our services.

As a company based in the Republic of Cyprus, we comply with the General Data Protection Regulation (GDPR) and Cyprus data protection laws.

2. Legal Basis for Data Processing

We process your personal data based on the following legal grounds:

• Contract Performance: Processing necessary for the performance of our services contract
• Legitimate Interest: For improving our services, security, and customer support
• Consent: Where you have given specific consent for processing
• Legal Obligation: Where processing is required by law

3. Data We Collect

3.1 Personal Information

• Name and contact details (email, phone, address)
• Account credentials and authentication information
• Payment information (processed by secure third-party providers)
• Identification documents (where required for verification)

3.2 Certificate Data

• Artwork or collectible information
• Certificate details and blockchain records
• Ownership transfer records
• Verification activity logs

3.3 QR Code Information Data

• Public information you provide (pricing, artist details, contact information)
• Scan statistics and access logs
• Geolocation data (on aggregated basis)

3.4 Technical Data

• IP addresses and device information
• Browser type and version
• Usage data and analytics
• Cookies and similar technologies

4. How We Use Your Data

We use your personal data for the following purposes:

• Providing and managing DIZON certificate services
• Creating and maintaining blockchain records
• Providing QR code information services
• Customer support and communication
• Fraud prevention and security
• Compliance with legal obligations
• Improving our services and user experience
• Marketing communications (with your consent)

5. Data Sharing and Disclosure

We may share your data with:

• Service Providers: Third-party companies providing technical services, payment processing, or customer support
• Blockchain Networks: Certificate data is stored on public blockchain networks
• QR Code Users: Public information you have shared for QR code display
• Legal Authorities: When required by law or to protect our rights
• Business Transfers: In case of merger, acquisition, or sale of assets

We do not sell your personal data to third parties for marketing purposes.

6. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area. We ensure adequate protection through:

• European Commission adequacy decisions
• Standard Contractual Clauses
• Certification schemes or codes of conduct
• Other appropriate safeguards as required by GDPR

7. Data Retention

We retain your personal data for as long as necessary to:

• Provide our services and maintain your account
• Comply with legal obligations
• Resolve disputes and enforce agreements

Blockchain records are permanent by nature and cannot be deleted once confirmed on the network.

8. Your Rights Under GDPR

As a data subject, you have the following rights:

• Right of Access: Request information about your personal data
• Right to Rectification: Correct inaccurate personal data
• Right to Erasure: Request deletion of your personal data (subject to limitations)
• Right to Restrict Processing: Limit how we process your data
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent for consent-based processing

9. Blockchain Specifics

By using our blockchain-based services, you acknowledge:

• That blockchain records are immutable and permanent
• That certain data is stored publicly on the Ethereum blockchain
• That deletion of certain blockchain data is technically impossible
• That you are responsible for the security of your wallet keys

10. Cookies and Tracking

We use cookies and similar technologies to:

• Enable website functionality
• Remember your preferences
• Analyze website usage
• Provide personalized content

You can control cookie settings through your browser preferences.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data, including:

• Encryption of sensitive data
• Access controls and authentication
• Regular security assessments
• Staff training on data protection
• Incident response procedures

12. Children’s Privacy

Our services are not intended for children under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware of such data collection, we will delete it promptly.

13. Data Protection Officer

For data protection inquiries, you can contact our Data Protection Officer at:

Email: dpo@dizon.digital

14. Supervisory Authority

You have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection or your local supervisory authority if you believe we have not handled your personal data properly.

15. Changes to This Policy

We may update this privacy policy from time to time. We will notify you of significant changes through our website or by email. The date of the last update will be shown at the top of this policy.

16. Contact Us

If you have questions about this privacy policy or wish to exercise your rights, please contact us:

Last updated: January 2024