Legal
Privacy Policy
Last updated:
1. Who we are
This Privacy Policy explains how Boxwind SRL, a company incorporated in Costa Rica (Co. No. 3-102-887839) with its registered office at San Jose-San Jose Mata Redonda, Sabana Norte, CLS Business Center, Noveno Piso, Bufete Aria, San Jose, Costa Rica ("Boxwind", "Hygentra", "we", "us" or "our") collects, uses, shares, stores, and otherwise processes personal data in connection with the Hygentra Services.
If you have questions about this Privacy Policy, you can contact us at access@hygentra.ai.
2. Scope of this Policy
This Policy applies to personal data we collect when you visit our website, use our applications or dashboards, create an account, connect a wallet, interact with support, receive marketing, or otherwise use the Services. It also explains how we process certain public on-chain or otherwise publicly accessible account data used for TraderDNA and related analytics.
3. Data we collect
— Information you provide to us: name, email address, account credentials, support messages, preferences, eligibility information, and any other information you choose to submit.
— Technical and usage data: IP address, browser type, device information, pages viewed, session activity, log data, referral source, approximate location derived from IP, and interactions with features, prompts, or settings.
— Wallet and account-linked data: wallet addresses, connected-account identifiers, transaction signatures or approvals, and records of linked or authorised actions within the Services.
— Public trading and market data: public on-chain trading activity, public account history, fills, market conditions, and other publicly accessible trading data used to generate TraderDNA and related analytics.
— Cookie and similar-technology data: cookies, pixels, local storage, SDK signals, and similar identifiers as described in our Cookie Policy.
4. How we use personal data
— To provide, operate, secure, and improve the Services.
— To create and manage your account, authenticate you, and maintain your settings and preferences.
— To analyse public or linked trading activity and generate TraderDNA, Copilot, and related outputs.
— To process payments, subscriptions, or billing-related actions where applicable.
— To respond to support requests, investigate complaints, prevent misuse, enforce our Terms and policies, and protect the security and integrity of the Services.
— To comply with legal obligations, sanctions controls, geofencing or regional availability rules, and other compliance requirements.
— To send service messages and, where permitted, marketing communications. You can opt out of marketing messages at any time.
5. Legal basis
Depending on the context, we process personal data because: (a) it is necessary to provide the Services and perform our contract with you; (b) it is necessary for our legitimate interests in operating, securing, improving, and defending the Services; (c) we need it to comply with legal obligations; or (d) you have given consent, including for certain cookies or marketing where required.
6. Public-account and TraderDNA processing
TraderDNA may analyse public on-chain or otherwise publicly accessible trading activity associated with users and non-users alike. We use that data to generate model-based behavioural analytics, scores, labels, rankings, and benchmarking outputs.
Where TraderDNA is based on public data, we process that data on the basis of our legitimate interests in operating an analytics product, improving our models, and providing market-wide behavioural insights, subject to applicable law and any rights available to affected individuals.
TraderDNA outputs are directional analytics under ongoing validation, not statements of fact about a person. We may update scoring methodologies, labels, benchmarks, or displays from time to time.
7. Sharing of personal data
We may share personal data with service providers and processors who help us operate the Services, such as hosting providers, analytics vendors, customer support tools, communications providers, payment processors, identity or sanctions-screening providers, bug-reporting providers, and infrastructure partners.
We may share data with third-party venues, wallets, bridges, exchanges, or integrations where needed to enable a feature you choose to use.
We may disclose data where required by law, regulation, court order, or lawful request, or where reasonably necessary to enforce our rights, protect users, detect fraud, or address security issues.
We may share data in connection with a merger, acquisition, sale of assets, financing, or corporate reorganisation, subject to appropriate confidentiality measures.
8. International transfers
We and our service providers may process and store data in countries other than the country where you reside. Where required, we take reasonable steps to use appropriate safeguards for international transfers.
9. Data retention
We retain personal data for as long as reasonably necessary for the purposes described in this Policy, including to provide the Services, maintain records, resolve disputes, comply with legal obligations, defend claims, and prevent misuse. Retention periods may vary depending on the type of data and legal requirements.
10. Your rights
Subject to applicable law, you may have rights to request access to, correction of, deletion of, portability of, or restriction of your personal data, or to object to certain processing. You may also have the right to withdraw consent where processing is based on consent.
To make a request, contact us at the email above. We may need to verify your identity and may not be able to fulfil every request where exemptions or overriding legal grounds apply.
11. Security
We use reasonable technical and organisational measures designed to protect personal data, but no system is completely secure. You should also protect your own credentials, wallet access, and devices.
12. Children
The Services are not intended for children. You must not use the Services if you are under 18 or under the age of majority in your jurisdiction, if higher.
13. Changes to this Policy
We may update this Privacy Policy from time to time. If we make material changes, we will post the updated version and may provide additional notice where appropriate. The "last updated" date on the published version will show when changes took effect.