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Coin District
Draft — to be validated by legal counsel

Privacy Policy

How Coin District collects, uses and protects your personal data, in line with the General Data Protection Regulation (GDPR).

Not yet in force

In short

  • We collect what the law requires to verify your identity, plus what we need to run your account.
  • We never sell your data. The cookies we use are listed in our Cookie Policy.
  • You can access, correct, export or delete your data at any time — within the limits of our legal retention duties.

1.Data controller

The controller of your personal data is Coin District, [Legal form], registered under [RCS number], whose registered office is at [Registered office address].

Coin District has appointed a Data Protection Officer (DPO), who can be reached at [DPO email address].

2.Data we collect

Identity

Name, date and place of birth, nationality, ID document, selfie for liveness check.

Contact

Email address, phone number, postal address, communication preferences.

Financial

Qualification answers, declared net worth and income, subscriptions and holdings.

Technical

Wallet addresses, IP address, device and browser data, login history, cookies.

3.Purposes and legal bases

We only process your data for specific purposes, each based on one of the legal grounds provided by the GDPR.

PurposeLegal basisRetention
Opening and managing your accountPerformance of the contract[Retention period]
Identity checks, anti-money launderingLegal obligation[Retention period]
Investor qualificationLegal obligation[Retention period]
Executing your subscriptionsPerformance of the contract[Retention period]
Security and fraud preventionLegitimate interest[Retention period]
NewsletterConsent[Retention period]
CNDT airdrop and referral program (email, wallet address, referral code)Performance of the contract[Retention period]
Free tools and resources: sending your result or document, follow-up of your request, qualification of your project (scoring), optional pitch deck uploadConsent[Retention period]
Marketing e-mails after a free tool or resource (optional, can be withdrawn at any time)Consent[Retention period]
Audience measurement (PostHog)[Legal basis][Retention period]
Audience measurement (Google Analytics)Consent[Retention period]
Measurement of free tool usage (steps reached, completion), only if you accept audience measurementConsent[Retention period]

4.Who receives your data

Your data is accessible only to authorized Coin District staff, and to the following categories of recipients, strictly for the purposes above:

  • our identity verification provider (Shufti Pro);
  • our payment service provider (Stripe);
  • Issuers in which you invest, limited to what is needed to register you as a shareholder;
  • our providers for wallet connection (Dynamic), the newsletter (Brevo), file storage (EdgeStore), audience measurement (PostHog), database and hosting [Hosting providers];
  • Google (Google Analytics), for audience measurement, only if you accept it; data may be transferred to the United States under the EU-US Data Privacy Framework;
  • for the free tools and resources: the Coin District lead management service, which stores your requests in Airtable and sends e-mails through our e-mail sending provider [E-mail provider];
  • public authorities, where required by law.

5.International transfers

Your data is stored in [Storage location]. If a provider processes data outside the European Economic Area, the transfer is covered by an adequacy decision of the European Commission or by the Commission’s standard contractual clauses, together with additional safeguards where necessary.

6.How long we keep your data

We keep your data only as long as necessary for each purpose (see the table in section 3). At the end of these periods, data is deleted or irreversibly anonymized. Data we must keep for legal reasons is archived with restricted access.

7.Data recorded on a blockchain

Token transactions are recorded on a blockchain. We never write your name or identity documents on-chain: only wallet addresses and token movements are recorded, and the link between an address and your identity is kept off-chain, in our systems.

Because blockchain records cannot be modified, on-chain transaction data cannot be erased. When you exercise your right to erasure, we delete the off-chain link between your identity and your wallet addresses.

8.Your rights

Under the GDPR, you have the following rights. We answer within one month of receiving your request.

  • Access

    Get a copy of your data.

  • Rectification

    Correct inaccurate data.

  • Erasure

    Ask us to delete your data.

  • Restriction

    Limit how we use your data.

  • Portability

    Receive your data in a reusable format.

  • Objection

    Object to processing based on our legitimate interest or to direct marketing.

Where processing is based on your consent, you can withdraw it at any time — for cookies, from the cookie preferences; for the newsletter, from the link in each email.

9.Security

We protect your data with encryption in transit and access controls. If a data breach is likely to put your rights at risk, we will inform you and the competent authority without undue delay.

10.Contact our DPO

To exercise your rights, write to [DPO email address] or by post to Data Protection Officer, Coin District, [Registered office address]. We may ask for proof of identity.

If you believe your rights have not been respected, you can lodge a complaint with the CNIL, the French data protection authority, or with the supervisory authority of your country of residence.

Send a privacy request

Questions about this document?

Write to us from the contact form.