Privacy Policy

1. Introduction

Webounties ("we", "us", "our", or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our decentralized freelance marketplace platform ("Webounties").

This Privacy Policy complies with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.

2. Information We Collect

2.1 Information You Provide Directly

Account Information:

• Name and username
• Email address
• Profile information and biography
• Professional skills and experience
• Portfolio samples and work examples
• Payment preferences

Transaction Information:

• Job postings and applications
• Project details and deliverables
• Communication with other users
• Dispute information and resolutions
• Feedback and ratings

Verification Information (when required):

• Government-issued identification
• Proof of address
• Business registration documents
• Information required for AML/KYC compliance

2.2 Information Collected Automatically

Technical Information:

• IP address and device identifiers
• Browser type and version
• Operating system
• Referring URLs and exit pages
• Pages viewed and time spent on pages
• Click data and interaction patterns

Blockchain Information:

• Wallet addresses (publicly generated)
• Transaction hashes and timestamps
• Smart contract interactions
• On-chain activity related to platform use

Cookies and Similar Technologies:

• Session cookies for authentication
• Analytics cookies for usage patterns
• Preference cookies for user settings
• See Section 9 for detailed cookie information

2.3 Information from Third Parties

• OAuth authentication data (if you connect social accounts)
• Blockchain network data (publicly available)
• Payment processor information (for fiat transactions)
• Fraud prevention and security services

3. How We Use Your Information

We use your information for the following purposes:

3.1 Service Provision

• Creating and managing your account
• Facilitating job postings and applications
• Processing transactions and payments
• Generating blockchain wallets for escrow services
• Enabling communication between users
• Providing customer support

3.2 Platform Operations

• Maintaining platform security and integrity
• Preventing fraud and abuse
• Enforcing our Terms and Conditions
• Resolving disputes
• Monitoring platform performance

3.3 Improvement and Development

• Analyzing usage patterns and trends
• Improving platform features and functionality
• Developing new products and services
• Conducting research and analytics

3.4 Communication

• Sending transactional emails (order confirmations, payment notifications)
• Platform updates and announcements
• Marketing communications (with your consent)
• Responding to your inquiries
• DAO governance notifications

3.5 Legal Compliance

• Complying with legal obligations
• Responding to law enforcement requests
• Protecting our legal rights
• Preventing illegal activities
• AML/KYC compliance

3.6 Legal Basis for Processing (UK GDPR)

We process your personal data under the following legal bases:

• Contract Performance: To provide services you've requested
• Legal Obligation: To comply with AML, KYC, and tax regulations
• Legitimate Interests: For fraud prevention, security, and platform improvement
• Consent: For marketing communications and optional features (you may withdraw consent at any time)

4. Blockchain and Wallet Information

4.1 Wallet Generation

When you create an account, we generate a blockchain wallet on the Solana network for you. This involves:

• Creating a unique wallet address
• Generating cryptographic key pairs
• Important: Private keys are NOT stored by us and are provided to you only once

4.2 Your Responsibilities

• You are solely responsible for securing your private keys
• We cannot recover lost private keys
• Never share your private keys with anyone, including our staff

4.3 Blockchain Transparency

You acknowledge that:

• Blockchain transactions are publicly visible and permanent
• Wallet addresses and transaction histories are recorded on public ledgers
• This information cannot be deleted or modified once recorded
• Anyone can view transactions associated with your wallet address

4.4 Non-Custodial Nature

• We do not have custody or control over your funds
• You maintain full ownership of your digital assets
• We facilitate transactions but do not hold your cryptocurrency
• Escrow is managed by smart contracts, not by us directly

5. How We Share Your Information

5.1 Within the Platform

Public Information:

• User profiles (name, bio, portfolio, ratings)
• Job postings and public project details
• DAO governance participation and votes
• Department Head status
• User earnings

Between Users:

• Contact information when engaged in a project
• Project-related communications and files
• Delivery and milestone information

5.2 Service Providers

We share information with third-party service providers who assist us:

• Cloud hosting providers (AWS, Vercel)
• Database services (Supabase)
• Analytics providers (Mixpanel, PostHog)
• Email service providers
• Payment processors (for fiat transactions)
• Security and fraud prevention services
• Customer support tools

All service providers are contractually bound to protect your information and use it only for specified purposes.

5.3 Legal Requirements

We may disclose your information when required by law or to:

• Comply with legal process or government requests
• Enforce our Terms and Conditions
• Protect the rights, property, or safety of the Company, users, or the public
• Detect, prevent, or address fraud or security issues
• Comply with AML/KYC regulations

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the acquiring entity. You will be notified of any such change in ownership.

5.5 With Your Consent

We may share information with third parties when you provide explicit consent.

6. International Data Transfers

6.1. Your information may be transferred to and processed in countries outside the United Kingdom, including the United States.

6.2. We ensure adequate protection through:

• Standard Contractual Clauses approved by the UK authorities
• Privacy Shield frameworks (where applicable)
• Adequacy decisions by the UK government

6.3. Blockchain data is inherently international and distributed across global networks.

7. Data Security

7.1 Security Measures

We implement appropriate technical and organizational measures to protect your information:

• Encryption of data in transit (TLS/SSL)
• Encryption of sensitive data at rest
• Row Level Security (RLS) policies in databases
• Regular security audits and penetration testing
• Smart contract audits by reputable firms
• Access controls and authentication systems
• Employee training on data protection

7.2 Limitations

While we strive to protect your information:

• No method of transmission over the Internet is 100% secure
• You are responsible for securing your private keys
• Blockchain transactions are irreversible
• You should use strong passwords and enable two-factor authentication where available

7.3 Breach Notification

In the event of a data breach, we will:

• Notify affected users within 72 hours (as required by UK GDPR)
• Report to the Information Commissioner's Office (ICO) when required
• Take immediate steps to mitigate harm
• Provide guidance on protective measures

8. Data Retention

8.1 Retention Periods

We retain your information for as long as necessary to:

• Provide services to you
• Comply with legal obligations (typically 6–7 years for financial records)
• Resolve disputes
• Enforce our agreements

8.2 Specific Retention

• Account Data: Retained while your account is active, plus 7 years after closure for legal compliance
• Transaction Records: 7 years for tax and AML purposes
• Communications: Deleted after 2 years unless part of an ongoing dispute
• Analytics Data: Aggregated and anonymized after 2 years

8.3 Blockchain Data

Please note: Blockchain transaction data is permanent and cannot be deleted from public ledgers.

8.4 Deletion Requests

You may request deletion of your personal data. We will comply unless:

• Legal obligations require retention
• Data is needed for legitimate business purposes
• Information is stored on immutable blockchain ledgers

9. Cookies and Tracking Technologies

9.1 What We Use

Essential Cookies:

• Authentication and session management
• Security features
• Platform functionality

Analytics Cookies:

• Usage statistics and patterns
• Performance monitoring
• User behavior analysis

Preference Cookies:

• Language preferences
• Display settings
• User interface customization

9.2 Your Choices

You can control cookies through:

• Browser settings (disabling or deleting cookies)
• Our cookie consent manager
• Opting out of analytics (see Section 11)

Note: Disabling essential cookies may affect platform functionality.

9.3 Third-Party Tracking

We use:

• Google Analytics (with IP anonymization)
• Mixpanel for product analytics
• PostHog for user behavior analysis

These services have their own privacy policies.

10. Your Rights Under UK GDPR

You have the following rights regarding your personal data:

10.1 Right of Access

Request a copy of the personal data we hold about you.

10.2 Right to Rectification

Request correction of inaccurate or incomplete information.

10.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data (subject to legal exceptions).

10.4 Right to Restriction of Processing

Request that we limit how we use your data.

10.5 Right to Data Portability

Receive your data in a structured, machine-readable format.

10.6 Right to Object

Object to processing based on legitimate interests or for marketing purposes.

10.7 Rights Related to Automated Decision-Making

You have the right not to be subject to decisions based solely on automated processing that significantly affects you.

10.8 How to Exercise Your Rights

To exercise any of these rights, contact us at: privacy@webounties.com

We will respond within 30 days (as required by UK GDPR).

10.9 Right to Complain

You have the right to lodge a complaint with the Information Commissioner's Office (ICO):

• Website: https://ico.org.uk
• Phone: 0303 123 1113
• Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

11. Marketing and Communications

11.1 Types of Communications

Transactional (you cannot opt out):

• Order confirmations
• Payment notifications
• Security alerts
• Important platform updates

Marketing (you can opt out):

• New features and updates
• Platform news and tips
• Special offers and promotions
• DAO governance announcements

11.2 Opting Out

You can unsubscribe from marketing communications by:

• Clicking "unsubscribe" in emails
• Updating preferences in your account settings
• Contacting privacy@webounties.com

11.3 Analytics Opt-Out

To opt out of analytics tracking:

• Use browser "Do Not Track" settings
• Install privacy browser extensions
• Contact us to disable analytics for your account

12. Children's Privacy

12.1. Our Platform is not intended for users under 18 years of age.

12.2. We do not knowingly collect information from children under 18.

12.3. If we discover we have collected information from a child under 18, we will delete it immediately.

12.4. Parents or guardians who believe we may have information about a child should contact us immediately.

13. Changes to This Privacy Policy

13.1. We may update this Privacy Policy from time to time to reflect:

• Changes in our practices
• Legal or regulatory requirements
• New features or services

13.2. Material changes will be notified via:

• Email to your registered address
• Prominent notice on the Platform
• At least 30 days before changes take effect

13.3. Continued use after changes constitutes acceptance of the updated Privacy Policy.

13.4. The "Last Updated" date at the top indicates when changes were made.

14. Third-Party Links and Services

14.1. Our Platform may contain links to third-party websites or services.

14.2. We are not responsible for the privacy practices of third parties.

14.3. We encourage you to read the privacy policies of any third-party sites you visit.

14.4. Third-party integrations (GitHub, Figma, Slack) are governed by their respective privacy policies.

15. Contact Us

For questions, concerns, or requests regarding this Privacy Policy or your personal data:

Data Protection Officer:

• Email: privacy@webounties.com
• Address: To be confirmed

General Inquiries:

• Email: support@webounties.com

Postal Address:

• Webounties
• Address to be confirmed
• United Kingdom

16. Consent and Acceptance

By using our Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your information as described herein.

For processing activities requiring explicit consent, we will obtain such consent separately through clear opt-in mechanisms.