This Privacy Policy is a legally binding agreement between you (“you” or “your”) and Tools for the Commons LLC, including its officers, agents, delegates, subsidiaries, and affiliates (collectively, “TftC”, “we”, “our”, or “us”), as well as its platform, Digital Access Zone (“DAZ”). This Policy describes how we collect, use, share, and protect your personal information when you access or use the DAZ Services via the Platform.By registering for a DAZ Account, accessing the Platform, and/or using the DAZ Services, you confirm that you have read, understood, and accepted this Privacy Policy. You further declare that you have had sufficient opportunity to become informed about the legal framework governing data protection in your applicable jurisdiction. You also agree to be bound by this Privacy Policy as it may be updated or amended from time to time.This Privacy Policy is to be read in conjunction with our DAZ Platform Terms of Use [link here]. In the event of any conflict or ambiguity between this document and the Terms of Use, this Privacy Policy shall take precedence with respect to the processing of your personal data.By agreeing to the DAZ Platform Terms of Use, you also accept this Privacy Policy and consent to the processing of your personal data, in the manner and under the applicable circumstances described herein.You acknowledge that the operations described in this Policy are essential for the use of the DAZ Services, and that your refusal to accept the contents of this document will prevent the initiation or continuation of the DAZ Services

‍1. Legal Basis for Data Processing

‍We collect and process your personal data only when we have a legal basis to do so, in accordance with global data protection regulations, including the EU General Data Protection Regulation (GDPR), the Brazilian Lei Geral de Proteção de Dados (LGPD), and the California Consumer Privacy Act (CCPA), where applicable. Our legal bases include:

‍Performance of a Contract: We process your data to fulfill our contractual obligations to you, such as providing you with access to the DAZ Services and managing your DAZ Account.

‍Compliance with a Legal Obligation: We process your data to comply with our legal duties, including those related to anti-money laundering (AML), counter-terrorist financing (CTF), identity verification (KYC/KYB), and other Applicable Regulations.

‍Legitimate Interests: We may process your data for our legitimate interests or those of a third party, provided your fundamental rights and freedoms do not override those interests. This includes improving and securing our services, preventing fraud, and conducting analytics.

‍Consent: Where required by law, we will obtain your explicit consent to collect and process your personal data for a specific purpose. You have the right to withdraw your consent at any time.

‍2. Types and Categories of Personal Data Collected

‍In order to provide the DAZ Services, we collect and process various categories of personal data, which may include:Identity Data: Full name, date of birth, nationality, government-issued identification numbers (e.g., passport, ID card), and other information required for identity verification.

‍Contact Data: Email address, physical address, and telephone number.

‍Financial Data: Wallet addresses, transaction history, and information related to your use of fiat currency and Digital Assets on the Platform.

‍Technical Data: IP address, browser type and version, device information, operating system, and other technical information related to your use of our Platform.

‍Usage Data: Information about how you use the DAZ Services, including access times, pages viewed, and your interactions with the Platform.

‍Public Blockchain Data: Certain transactional data, including cryptographic identifiers or hashes linked to your identity, may be recorded on public blockchains as part of your use of the Platform. This data is permanent, immutable, and publicly accessible. DAZ cannot alter or delete this information.

‍Compliance Data: Information collected as part of our AML, KYC, and KYB procedures, including background checks, sanctions list screening, and other due diligence records.

‍3. Purposes of Data Collection and Processing

‍We collect and process your personal data for the following purposes:

‍Account Registration and Management: To create, verify, and maintain your DAZ Account and your Digital Residency or Entity, and to provide you with access to the DAZ Services.

‍Compliance and Security: To perform identity verification (KYC/KYB), monitor transactions for fraud, money laundering, and other illicit activities in accordance with our AML Policy and Applicable Regulations.

‍Service Provision: To enable you to execute Transactions, manage your assets, use financial tools, and access other features of the Platform.

‍Communication: To send you important notices, updates, security alerts, and other official communications.

‍Platform Improvement: To analyze and understand how our services are used, to debug issues, and to improve the functionality, user experience, and security of the Platform.

‍Legal Proceedings: To respond to valid legal requests, court orders, or governmental investigations, and to protect our rights, property, and safety, as well as the rights, property, and safety of our users or others.

‍4. Sharing of Data with Third Parties, including International Transfers

‍We may share your personal data with third parties in the following circumstances:

‍Third Party Providers: We share data with trusted third-party service providers who assist us in providing the DAZ Services. This includes providers for identity verification (KYC/AML), payment processing, data analytics, and cloud hosting.

‍Competent Authorities: We may share your personal data with governmental entities, agencies, or regulatory bodies to comply with our legal and regulatory obligations.

‍Affiliates and Business Partners: Your data may be shared with our affiliates and partners to provide you with integrated services and support.

‍International Data Transfers: As our operations are global, your personal data may be transferred to and stored in jurisdictions outside of your country of residence. When we transfer your data internationally, we take appropriate measures to ensure that your data is protected in accordance with the applicable laws, such as using standard contractual clauses or other legal mechanisms.

‍Public Blockchain: As noted above, certain data may be permanently and publicly recorded on blockchains as part of your use of the Platform, and we have no control over this.

‍5. Users’ Data Protection Rights and How to Exercise Them

‍In accordance with applicable data protection laws, you have the following rights regarding your personal data:

‍Right to Access: You have the right to request a copy of the personal data we hold about you.

‍Right to Rectification: You have the right to request that we correct any inaccurate or incomplete personal data we hold about you.

‍Right to Erasure (Right to be Forgotten): You have the right to request the deletion of your personal data, subject to certain legal obligations, such as data retention requirements for AML/CTF compliance.

‍Right to Data Portability: You have the right to request that we transfer your personal data to another organization, or directly to you, in a structured, commonly used, and machine-readable format.

‍Right to Withdraw Consent: Where we rely on your consent to process your data, you have the right to withdraw that consent at any time.To exercise any of these rights, please contact us using the contact details provided in Section 9 of this Privacy Policy. We may need to verify your identity before processing your request.

‍6. Security and Data Protection Measures

‍We are committed to protecting your personal data. We implement a range of technical and organizational security measures to protect your information from unauthorized access, loss, misuse, or alteration. These measures include data encryption, access controls, secure network architectures, and regular security audits.The personal data we collect will have restricted access, with information security measures in place to ensure that each piece of personal data is accessed only by the professional or department that genuinely requires it to carry out the declared purposes of data processing. Security procedures and data access permissions are reviewed periodically.While we strive to use commercially acceptable means to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. You acknowledge and accept this inherent risk and understand that we cannot guarantee the absolute security of your data. You are also responsible for taking appropriate security measures to protect your Access IDs and hardware, as detailed in our Terms of Use.Even though we employ various measures to ensure data protection and security, you are also responsible for the security of your account. Therefore, you must keep your information safe by protecting your passwords, login credentials, cryptographic keys, and other account-related data, as well as using only secure and trusted connections and devices when accessing the system.

‍7. Use of Cookies and Tracking Technologies​​

We use cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to enhance your experience on our Platform, analyze usage patterns, personalize content, deliver targeted advertisements, and improve the overall quality of our services.Cookies are small text files that are stored on your device (computer, smartphone, or other) by your web browser when you visit a website. These files allow us to recognize your browser and store preferences and other information to improve your future interactions with our Platform.We use different types of cookies, including:

‍Essential Cookies – These are necessary for the Platform to function properly and cannot be switched off in our systems.

Performance and Analytics Cookies – These allow us to measure and analyze how users interact with our Platform to improve its performance.

Functionality Cookies – These are used to remember your preferences and settings to provide a more personalized experience.

Advertising and Targeting Cookies – These may be set by us or third-party partners to deliver relevant advertisements and measure the effectiveness of our marketing campaigns.

We use both session cookies, which expire when you close your browser, and persistent cookies, which remain on your device for a specified period or until deleted manually.By continuing to use our Platform, you consent to our use of cookies and similar technologies in accordance with this Privacy Policy. You can manage, block, or delete cookies at any time through your browser settings or other available tools. However, please note that disabling certain cookies may affect the functionality or performance of some parts of the Platform.

‍8. Data Storage and Retention Periods

‍We store your personal data for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, and to comply with our legal and regulatory obligations.Specifically, we will retain your data for the lifetime of your DAZ Account and for any additional period required by Applicable Regulations, such as for tax and accounting purposes or for compliance with anti-money laundering laws. Once the data is no longer required, we will securely delete or anonymize it in accordance with our data retention policy.

‍9. Contact Information for the Data Controller and DPO

‍If you have any questions, concerns, or complaints about this Privacy Policy or our data processing practices, or if you wish to exercise your data protection rights, please contact:TftC Prospera LLCEmail: contact@toolsforthecommons.com

‍10. Applicable Jurisdiction and Governing Law

‍This Privacy Policy, including all data protection and processing activities carried out under it, shall be primarily governed by and construed in accordance with the laws and regulations of the Zone for Employment and Economic Development (ZEDE) of Próspera, Honduras.However, to the extent applicable and not inconsistent with the foregoing, the laws of other jurisdictions in which you hold a recognized Entity or Digital Residency may apply on a supplementary basis. By accepting this Policy, you acknowledge that you have had a reasonable opportunity to become informed about the legal frameworks of any such applicable jurisdictions.