PRIVACY POLICY

Last Updated: 9 June 2026
Version: 1.5

1. GENERAL INFORMATION

1.1 Scope

This Privacy Policy explains how Tastenkunst GmbH ("we," "us," or "our") collects, uses, and protects personal data when you use:

• The Eternl crypto wallet (Mobile App, Browser Extension, Web App).
• Optional paid Eternl Pro plans, license activation, and business seat-management features.
• The websites eternl.io, tastenkunst.com, and titanstaking.io.
• Our Titan Staking pools.
• Our social media profiles (X/Twitter, Telegram, Discord).
• When you contact us via email or other channels for business or support inquiries.

1.2 Data Controller

The responsible party (Controller) for data processing under the General Data Protection Regulation (GDPR) is:

Tastenkunst GmbH
Hainstraße 11
04109 Leipzig
Germany
Email: info@tastenkunst.io

1.3 Core Privacy Principle (Self-Custody)

Eternl is a self-custody wallet.

• We do not create user accounts.
• We do not store your private keys or seed phrases.
• We do not have access to your funds.

Most data generated by your use of the Software is stored locally on your device or on the respective blockchain network. We do not maintain traditional user accounts. For paid Pro Plans, we process limited license, activation, seat, payment-reference, and support data as described below; payment and billing details are handled by Dodo Payments as Merchant of Record unless the checkout states otherwise.

2. DATA COLLECTION AND PROCESSING

2.1 Access to Terminal Equipment (TDDDG)

The Eternl Software stores data (e.g., encrypted private keys, settings, address books, local license files, activation state, and installation identifiers) locally in the storage of your end device (Local Storage, IndexedDB, Keychain). This storage is necessary for the telemedia service explicitly requested by you, including wallet functionality and, where applicable, Pro license activation.

Legal Basis: § 25 Para. 2 No. 2 TDDDG (Telekommunikation-Digitale-Dienste-Datenschutz-Gesetz). No consent (Cookie Banner) is required for strictly necessary functional storage.

2.2 Infrastructure and Hosting

To provide our services, we use third-party infrastructure providers.

• Hosting (Frontend/Backend): We use Salesforce (Heroku) and Dedicated Bare Metal Servers to host the Eternl frontend and backend services. Servers are located in Germany and the United States.
• Content Delivery & Security (CDN): We use Cloudflare to optimize load times and protect our infrastructure against attacks (DDoS). Cloudflare acts as a reverse proxy; traffic passes through Cloudflare's network.

Data Processed: IP address, request metadata, user agent, app version, timestamps, security logs, and technical request data.

Legal Basis: Art. 6(1)(f) GDPR (Legitimate Interest in availability, performance, and security) and, where necessary for requested services, Art. 6(1)(b) GDPR (Performance of Contract).

2.3 RPC Nodes and Wallet Interaction

To display balances, synchronize wallet state, and broadcast transactions, the Software communicates with blockchain nodes and backend services.

• Data Processed: IP address, metadata (User Agent, App Version), public wallet addresses, public credentials, transaction hashes, and transaction data required to provide the requested wallet function.
• Purpose: Reading blockchain state, building or relaying requested data, and broadcasting transactions.
• Storage: We do not permanently store IP addresses linked to wallet addresses. Server logs used for technical debugging and security monitoring (e.g., DDoS prevention) are retained for a maximum of 14 days and then automatically deleted unless longer retention is required to investigate abuse, security incidents, or legal claims.

Legal Basis: Art. 6(1)(b) GDPR (Performance of Contract) and Art. 6(1)(f) GDPR (Legitimate Interest in network integrity and security).

2.4 Blockchain Data and License Metadata

For public blockchains supported by the Software (e.g., Cardano and Apex Fusion Prime Mainnet), transactions you sign are broadcast to a public ledger.

• Public Nature: Data written to these blockchains (wallet addresses, transaction amounts, metadata, NFTs, license metadata, and transaction hashes) is public, immutable, and distributed globally.
• No Deletion: Due to the nature of public blockchains, Tastenkunst cannot change or delete this data after it has been recorded. The GDPR "Right to Erasure" may be technically impossible for public blockchain data (Art. 17(3)(b) GDPR).
• License Metadata: Pro license metadata is intended not to directly identify a natural person, but wallet identifiers, payment credentials, transaction hashes, timestamps, product references, and seat references may still be linkable to other information by you or third parties.

Note regarding Privacy-Preserving Networks (e.g., Midnight):
If the Software supports privacy-focused partner chains, different rules regarding visibility apply. Tastenkunst does not have access to encrypted transaction data unless you explicitly choose to disclose it to us, but encrypted ledger data may still be immutably stored on the relevant network.

2.5 Pro License, Activation, and Business Seat Data

Eternl does not use traditional logins for Pro access. License flows use wallet signatures and public blockchain references.

Data Processed: Depending on your use of Pro features, Tastenkunst may process public payment credentials or wallet references, signData challenge metadata and signature verification results, purchase-session references, product or plan identifiers, license identifiers, public license transaction hashes, entitlement status, activation counts, activation timestamps, installation or device binding references, local license-file validation status, business seat counts, seat assignment status, business administrator references, support flags, fraud-prevention flags, and related technical status information.

Purpose: To prove wallet control, create or recover a purchase session, verify and index license transactions, create local license files, enforce activation limits, manage business seats, prevent abuse or fraud, troubleshoot activation issues, and provide support.

Legal Basis: Art. 6(1)(b) GDPR (Performance of Contract for requested Pro services), Art. 6(1)(f) GDPR (Legitimate Interests in license verification, fraud prevention, support, and service security), and Art. 6(1)(c) GDPR where processing is necessary for legal obligations.

Retention: License and activation references are retained for the duration of the license relationship and afterward for as long as reasonably necessary for support, abuse prevention, accounting reconciliation, legal claims, and statutory retention obligations. We minimize retained data and do not store seed phrases, private keys, spending passwords, or full payment card data.

Automated Controls: Activation limits and anti-abuse checks may be applied automatically. If a license is blocked or deactivated by such controls, you may contact support to request human review.

2.6 Payment and Billing Data Handled by Dodo Payments

Dodo Payments acts as Merchant of Record for Pro checkout unless the checkout expressly states otherwise. Dodo Payments collects and processes customer, billing, tax, payment, fraud-prevention, invoicing, refund, chargeback, and payee-identification information required for the checkout transaction. This may include email address, billing or postal address, VAT or tax information, payment method data, payment status, and related compliance data.

Tastenkunst does not store your full payment card data, postal address, or payee-identification data in its own license database. Tastenkunst may receive limited payment references and status information from Dodo Payments, such as checkout references, payment status, product or plan identifiers, license identifiers, seat quantities, timestamps, refund or chargeback status, and technical reconciliation data.

Purpose: To reconcile purchases, activate or revoke licenses, handle support, prevent fraud, and comply with legal obligations.

Legal Basis: Art. 6(1)(b) GDPR (Performance of Contract), Art. 6(1)(f) GDPR (Legitimate Interests in payment reconciliation, fraud prevention, and support), and Art. 6(1)(c) GDPR where processing is required by law.

2.7 Contact and Communication (Support & Business)

If you contact us via email, social platforms, or mail (whether for user support, payment or license support, business inquiries, job applications, or general contact):

• Data: We process your contact details (e.g., email address, name), metadata of the communication, license or payment references you provide, and the content of your message.
• Purpose: To process your inquiry, provide support, identify the relevant license or purchase, or initiate/fulfill business relationships (B2B).
• Retention: We retain this data until the request is resolved. However, commercial and business correspondence (e.g., emails regarding transactions, invoices, partnership agreements) is archived for 6 or 10 years in accordance with statutory retention periods (§ 257 HGB, § 147 AO).

Legal Basis:

• User Support: Art. 6(1)(b) GDPR (Performance of Contract).
• Business Inquiries: Art. 6(1)(b) GDPR (Pre-contractual measures) or Art. 6(1)(f) GDPR (Legitimate Interest in effective business communication).
• Retention: Art. 6(1)(c) GDPR (Legal Obligation).

2.8 Push Notifications (planned for 2026)

If we introduce optional push notifications (e.g., transaction alerts), we will process a device token (e.g., an Apple Push Notification Service (APNs) token or Firebase Cloud Messaging (FCM) token) and the notification content needed to deliver the notification. The legal basis will generally be your consent (Art. 6(1)(a) GDPR) and, where applicable, § 25 TDDDG for storing/accessing information on your device. You can withdraw consent at any time in the app settings or in your device settings.

We will use push notification providers only as processors under Art. 28 GDPR and only to transmit the notification to your device.

2.9 Delegate Messaging (planned for 2026)

If we introduce an optional messaging system that allows DReps and stake pool operators (SPOs) to send messages to their delegates, we expect messages to be published on the Cardano blockchain as transaction metadata (i.e., public, immutable ledger data). In that case, Tastenkunst processes this data to display, filter, and search messages in the app and (where applicable) to route message-related requests through our backend.

Please note:

• (a) Public and immutable: message content and associated addresses may be publicly visible on the blockchain and cannot be deleted from the ledger.
• (b) Personal data: depending on context, public addresses and message content may still constitute personal data under GDPR (e.g., if linked to an identifiable person).
• (c) Roles: The sender (DRep/SPO) is typically the controller for the decision to publish specific message content. Tastenkunst is a controller for the processing performed by the Software and our backend to retrieve, index, and present messages.

If we introduce additional off-chain features (e.g., message delivery preferences, opt-outs, or push alerts), we will update this Privacy Policy and, where required, request your consent.

3. THIRD-PARTY SERVICES AND INTEGRATIONS

3.1 On-Ramp/Off-Ramp Providers

Features linking to third parties (e.g., Transak, Guardarian, Mercuryo) involve a direct relationship between you and the provider. We do not receive sensitive financial data or KYC documents. We may view pseudonymized transaction summaries for commission purposes.

3.2 DEX Aggregators (MonsterSwap)

If you use the Swap feature, the app uses third-party DEX aggregators. Your device sends quote and transaction-build requests to our backend service, and our backend forwards requests to the integrated aggregator APIs. This means the aggregators generally see the IP address of our server (not your personal IP address).

Data Shared: Depending on the swap and the aggregator, we forward technical trade parameters (e.g., assets, amounts, slippage settings) and your public wallet address (required for transaction construction). The selected aggregator returns an unsigned transaction (or transaction data), which is relayed back to your device for your review and signature.

Roles: The third-party aggregators and underlying DEX protocols act as independent controllers for their own processing. Tastenkunst acts as a controller for the relay/selection processing performed by our backend (e.g., selecting the best quote and relaying the unsigned transaction).

3.3 Affiliate Links

Clicking affiliate links (e.g., Ledger, Trezor) redirects you to the vendor. We do not receive personal purchase details, only aggregated commission statistics.

3.4 Platform Providers and App Stores (Apple, Google, Microsoft, Browser Stores)

Where you obtain or use the Software via a platform provider (such as Apple App Store, Google Play, Microsoft Store, browser extension stores, or a mobile/desktop operating system), the platform provider may process certain information independently under its own privacy policy. Examples can include device identifiers, installation and update information, store diagnostics, and billing or subscription records for in-app purchases.

Tastenkunst does not control such processing by platform providers. Depending on the platform and your settings, Tastenkunst may receive limited information (for example, a purchase confirmation, refund status, or aggregated download metrics) to operate paid features and provide customer support.

You can consult the relevant platform provider's privacy documentation and, where offered, adjust platform privacy/diagnostics settings; however, we cannot opt you out of processing that the platform provider performs as an independent controller.

3.5 Dodo Payments and Checkout Providers

If you purchase a Pro Plan, checkout is handled by Dodo Payments unless the checkout states otherwise. Dodo Payments acts as Merchant of Record for the checkout transaction and processes payment, billing, tax, fraud-prevention, invoice, refund, chargeback, and compliance data under its own privacy terms. Tastenkunst receives only limited payment and license references needed to activate, reconcile, support, or revoke the Pro license.

4. TITAN STAKING

If you delegate to our TITAN stake pools, your stake address and delegation amount are publicly visible on the blockchain. We do not process this data off-chain to identify natural persons unless you voluntarily disclose your identity.

5. SOCIAL MEDIA PRESENCE

We maintain profiles on social media platforms such as X (Twitter), Discord, and Telegram to communicate with the community.

5.1 Independent Controllers

When you visit or interact with our social media profiles, the respective platform provider processes personal data under its own responsibility and according to its own privacy rules (independent controller). We have limited influence over the platform's processing (e.g., tracking, analytics, or advertising).

5.2 Joint Controllership (only where applicable)

For certain platform features (for example, analytics/insights tools provided by the platform operator), the platform operator and we may be considered joint controllers within the meaning of Art. 26 GDPR for those specific processing operations. Where such joint controllership applies, the platform operator typically provides the primary information about data processing and offers the relevant rights mechanisms. In such cases, you may exercise your rights either with us or with the platform operator.

5.3 Data We Process

If you contact us via social media (e.g., direct message, mention), we process the content of your message and your publicly visible profile information to respond and for documentation purposes. The legal basis is Art. 6(1)(b) GDPR (pre-contractual/contractual communication) or Art. 6(1)(f) GDPR (legitimate interests in communication and support).

6. INTERNATIONAL TRANSFERS

Some of our providers (including hosting, CDN, support, and checkout providers) may be based outside the European Economic Area or may process data in third countries.

• Adequacy Decisions / Data Privacy Framework: To the extent providers are certified under the EU-US Data Privacy Framework (DPF) or covered by another adequacy decision, transfers may be based on that adequacy mechanism.
• Standard Contractual Clauses: Where required, we use Standard Contractual Clauses (SCCs) or other appropriate safeguards to ensure a level of data protection comparable to EU standards.
• Public Blockchains: Public blockchain data may be globally accessible by design and is not controlled by Tastenkunst after publication.

7. YOUR RIGHTS (GDPR & EU DATA ACT)

You have the following rights, subject to statutory conditions and limitations:

• Access (Art. 15 GDPR): Request information about data we hold.
• Correction (Art. 16 GDPR): Request correction of inaccurate data.
• Deletion (Art. 17 GDPR): Request deletion, subject to blockchain immutability, statutory retention laws, and other legal limits.
• Restriction (Art. 18 GDPR): Request restriction of processing in certain cases.
• Data Portability (Art. 20 GDPR & EU Data Act): Receive data you provided to us where legally applicable. Under the EU Data Act, you may also have rights to access and use certain data generated by your use of a product or related service. Much Eternl wallet data is stored locally on your device or publicly on-chain, so you often already control it directly.
• Objection (Art. 21 GDPR): Object to processing based on legitimate interests, such as certain server logs or anti-abuse processing.
• Withdraw Consent (Art. 7 GDPR): Withdraw consent where processing is based on consent, without affecting prior lawful processing.
• Human Review: If an automated activation-limit or anti-abuse control blocks or deactivates a Pro license, you may contact support to request human review.

To exercise these rights, please contact: info@tastenkunst.io

Right to Lodge a Complaint:
If you believe that our processing of your personal data violates data protection laws, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence. The supervisory authority responsible for us is:
Sächsischer Datenschutzbeauftragter (Saxon Data Protection Commissioner), Dresden, Germany.

8. NOTICE TO US RESIDENTS (CCPA/CPRA)

Although we are a German company, for users in the United States, the following applies:
We do not sell your personal information. We do not share your personal information for cross-context behavioral advertising. We collect data solely for the functionality of the Software (Business Purpose). You have the right to request access to or deletion of your specific personal information, subject to the technical limitations of the blockchain.

9. DATA SECURITY

We implement technical and organizational measures (TOMs), including:

• Local encryption of private keys.
• TLS/SSL encryption for data in transit.
• Strict minimization of data collection ("Privacy by Design").

10. CHANGES TO THIS POLICY

We may update this Privacy Policy to reflect changes in our processing, the Software, Pro Plans, checkout providers, license activation, seat management, or legal requirements. The current version will always be available on our website and, where appropriate, in the Software.

If we make material changes, we will provide appropriate notice before the changes take effect and, where required by law, request consent or another legally required acknowledgement.