KEEPER← Back to KeeperPrivacy Policy
This Privacy Policy explains how Keep Ventures OÜ (“Keeper”, “we”, “us” or “our”) processes personal data when you visit Keeper Exchange, join the waitlist, create an account or use our services.
1. Who is responsible for your data
Controller: Keep Ventures OÜ, registered in Tallinn, Estonia.
Registered address: Veskiposti tänav 14-8, 10138 Tallinn, Estonia.
Privacy contact: legal@keeper.exchange.
We have not appointed a Data Protection Officer (DPO). Please direct privacy questions and requests to the contact above.
2. Personal data we process
- Waitlist and communications: your email address, signup time and the source of your signup, so we can administer the waitlist and send the messages you requested.
- Account and service data: where you create an account or use a service, account details such as your email and profile information, public wallet address, and information needed to provide the requested service. For Airdrop participation through the Mini App, this may include your Telegram UID and its link to your Keeper Exchange account for eligibility checks and crediting distributions.
- Transaction and blockchain data: transaction identifiers and related information needed to process or verify an action you initiate. Public blockchain records, including wallet addresses and transactions, may be visible to anyone and generally cannot be changed or deleted by Keeper.
- Technical and security data: information generated when you access the service, which may include IP address, device and browser details, timestamps, and security or diagnostic logs.
Please do not send us special-category personal data unless we specifically ask for it and explain why it is needed.
3. Purposes and legal bases
We process personal data for the purposes below, using the legal basis that applies to the relevant activity under Article 6 of the GDPR.
| PURPOSE | LEGAL BASIS |
|---|---|
| Account and service delivery, including wallet setup and transaction execution when available, and administering Airdrop eligibility and distributions through the Mini App | Performance of a contract and applicable Airdrop terms (Article 6(1)(b)) |
| Security, fraud prevention and network integrity | Our legitimate interests in protecting users and the service (Article 6(1)(f)) |
| Product development, analytics and performance monitoring | Our legitimate interests in developing and improving the service (Article 6(1)(f)); where consent is required, we obtain it first |
| Marketing and product updates | Your consent (Article 6(1)(a)); you may withdraw consent at any time |
| Compliance with legal requirements and responding to lawful requests | Compliance with a legal obligation (Article 6(1)(c)) |
| Establishing, exercising or defending legal claims | Our legitimate interests in protecting and enforcing our legal rights (Article 6(1)(f)) |
We do not make decisions producing legal effects or similarly significant effects about you based solely on automated processing, including profiling.
4. How we share personal data
We share personal data only as needed for the purposes described in this Policy, including with:
- Cloudflare, Inc.: website and application delivery, security services, and the Workers/D1 platform used to operate the service and store waitlist data. Processing may take place through Cloudflare’s global network.
- Amazon Web Services (AWS), eu-west-1 (Ireland): infrastructure and hosting services.
- Wallet providers and public blockchain networks: when you choose to connect a wallet or initiate a blockchain transaction. Those providers and networks may process data under their own terms and privacy notices; public blockchain data is not controlled by Keeper.
- Professional advisers, regulators, law-enforcement authorities or courts: where disclosure is required by law or necessary to protect rights, safety or the integrity of the service.
Our service providers are subject to a Data Processing Agreement or equivalent contractual safeguards where required. We do not sell personal data to third parties and do not share it for third-party advertising purposes.
5. International data transfers
Yes. Personal data may be transferred to or accessed from countries outside the European Economic Area (EEA). Where a destination does not benefit from an applicable adequacy decision, we use an appropriate transfer safeguard under GDPR Chapter V, such as Standard Contractual Clauses, and apply supplementary measures where required. You may contact us for further information about the safeguards relevant to your data.
6. Retention and security
- Account data (email and profile): for the duration of your account and for 364 days after account closure to support the recovery grace period and address accidental deletion.
- Waitlist data: while you remain subscribed or until the relevant waitlist or launch communication ends. If you unsubscribe, we stop marketing messages and may retain a minimal suppression record so we can respect that choice.
- Transaction, security and legal records: for as long as needed for the relevant service, security, dispute resolution or legal obligation, after which they are deleted or anonymised where practicable. Public blockchain records are not within Keeper’s control and may remain permanently available.
We use technical and organisational measures designed to protect personal data. No online service can guarantee absolute security. If a personal data breach is likely to create a risk to people’s rights and freedoms, we will notify the competent supervisory authority within 72 hours of becoming aware of it where feasible. If the breach is likely to result in a high risk, we will also notify affected individuals without undue delay, as required by GDPR Articles 33 and 34.
7. Your rights
Subject to applicable law, you may ask us to access, correct or delete your personal data; restrict or object to processing; receive data you provided in a portable format; and withdraw consent at any time where processing is based on consent. You also have the right to lodge a complaint with a data protection supervisory authority, including the authority in your place of habitual residence, place of work or the place of an alleged infringement. In Estonia, this is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon).
To exercise a right, email legal@keeper.exchange. We may ask for information needed to verify your identity and will respond within the period required by law. Some rights are subject to exceptions. Data recorded on public blockchains may not be capable of correction or erasure by Keeper.
8. Waitlist emails and marketing choices
If you join the waitlist, we use your email to record your request and send the launch or product updates you requested. Welcome emails are currently disabled. Marketing updates are sent only where you have opted in. You can withdraw consent or unsubscribe using the link in an email, or by contacting us at legal@keeper.exchange. We may still send service or legally required messages where necessary.
9. Children
Keeper’s services are intended for adults aged 18 or older and are not directed to children. We do not knowingly collect personal data from anyone under 18. If you believe a person under 18 has provided personal data to us, contact legal@keeper.exchange and we will take appropriate steps.
10. Changes and contact
We may update this Policy from time to time to reflect changes in our services, processing or legal requirements. We will publish the current version on this page and update the “Last updated” date above. If a change materially affects how we use personal data, we will provide additional notice where required by law.
For privacy questions or requests, contact Keep Ventures OÜ at legal@keeper.exchange, Veskiposti tänav 14-8, 10138 Tallinn, Estonia.
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