Privacy Policy

Last Updated: 06 June 2025

This Data Protection and Privacy Policy ("Privacy Policy") describes how we collect, use, protect, and disclose any Personal Data or data we receive when providing our services to you through our website, www.inkfnd.com, and its subdomains ("Services").

For the purposes of this Policy, "Company", "we", "us" or "our" means the Ink Foundation, a Cayman Islands Foundation Company, and our personnel, affiliates, and related companies. "You" and "your" refers to you as the user of the Services. Capitalised terms have the meanings provided in the Definitions section of this Policy, elsewhere in this Policy, or in the Website Terms.

Please read this Privacy Policy carefully. By using, accessing, connecting to, or using any of the Services, you agree and consent to the collection, use, disclosure, retention, and security of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use, access, or connect to any of the Services.

OUR COMMITMENT TO YOUR PRIVACY

We are committed to respecting the privacy of the users of our Services and minimising the collection of personal information.

As a general principle, we do not collect or store Personal Data about users of the Services, except where necessary to ensure the usability and functionality of our Services, to communicate with you, to maintain security, or to comply with legal obligations. This Privacy Policy sets out the limited categories of Personal Data we may collect, the purposes for which it is used, and the measures we take to safeguard your data.

Our goal is to provide transparency and uphold your privacy at every step.

CHANGES TO THIS POLICY

Please note that we may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will update the "Last Updated" date at the top of this Notice.

If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you by posting notice of such changes on the Services or by other means consistent with applicable law.

You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

DEFINITIONS

For the purposes of this Privacy Policy, the following terms have the following meanings:

  • "Appropriate Safeguards" means such legally enforceable mechanism(s) for transfers of Personal Data as may be permitted under Data Protection Laws from time to time.
  • "Data Controller" has the meaning given in applicable Data Protection Laws from time to time.
  • "Data Protection Laws" means, as binding on either party:
    • the Cayman Islands Data Protection Act as revised ("DPA");
    • any laws that replace, extend, re-enact, consolidate, or amend any of the foregoing;
    • any binding decision of the courts and tribunals of the British Virgin Islands that relate to the application or interpretation of any of the foregoing;
    • any other Data Protection Laws as may be applicable to you.
  • "Data Subject" has the meaning given in applicable Data Protection Laws from time to time.
  • "Personal Data" has the meaning given in applicable Data Protection Laws from time to time.
  • "Processing" (or to "Process") means, in relation to personal data, collecting, recording, holding, or storing the personal data or carrying out any operation or set of operations on the personal data, including the:
    • (a) organisation, adaptation, or alteration of personal data;
    • (b) retrieval, consultation, or use of personal data;
    • (c) disclosure of personal data by transmission, transfer, dissemination or otherwise making available; or
    • (d) alignment, combination, correction, erasure, or destruction of personal data.

PERSONAL DATA WE COLLECT

The categories of Personal Data we collect depend on how you interact with us, our Services, and the requirements of applicable Data Protection Laws. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services, as described below.

A. Information We Collect

We do not collect, store, or process any personal data through this website. This means:

  • No contact or registration forms are present.
  • No analytics tools are used.

B. Personal Data Collected Automatically

Third-party service providers such as our hosting provider and content delivery/security partner may automatically collect certain information about your interaction with the Services ("Usage Data") for the purpose of ensuring the website functions properly and securely.

Usage Data may include:

  • Device information, such as device type, operating system, unique device identifier, internet protocol (IP) address, and geographical location information.
  • Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Services, navigation paths between pages or screens, and whether you have opened our emails or clicked links within them.
  • Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, and ad impressions.

C. Personal Data from Other Sources

These services may process information under their own privacy policies:

We do not control how these services use your data, but they are used solely for website delivery and security.

USE OF PERSONAL INFORMATION

We may Process and use Personal Data for the following purposes or as otherwise described at the time of collection:

  • Service delivery and operations: Provide the Services; enable security features; communicate with you about updates or alerts; support and respond to your feedback.
  • Service improvement and analytics: Analyse usage and performance; develop new features and improve current ones.
  • Compliance and protection: Comply with laws and legal processes; audit internal procedures; prevent fraud or malicious activity.
  • Further uses: Any other uses compatible with the initial collection purpose or with your consent.

LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION

We consider it necessary to collect and use Personal Data for the purposes described above and rely on the following legal bases:

  • Consent: You have agreed and consented to the Processing of your Personal Data.
  • Contractual Necessity: Required to fulfill or enter into a contract.
  • Compliance with Legal Obligations: Required by law.
  • Vital Interests: To protect your vital interests or those of another.
  • Public or Legitimate Interests: Our legitimate interests, unless outweighed by your rights.

HOW WE DISCLOSE YOUR PERSONAL INFORMATION

We may disclose your Personal Data to third parties, including:

  • Third-party blockchain networks and wallet providers;
  • Service providers (e.g., payment processors, analytics, cloud storage);
  • Our affiliates or related entities;
  • Advisors (e.g., auditors, legal counsel);
  • Buyers in the event of a business transaction;
  • Any third party where you request or enable disclosure (e.g., social login).

We may also disclose information to comply with laws or protect rights and safety.

THIRD PARTY PLATFORMS, WEBSITES AND LINKS

Our Services may contain links or integrations with third-party websites and services. These do not imply endorsement or affiliation. We are not responsible for the privacy practices of these third parties. Please review their privacy policies before use.

RETENTION OF PERSONAL DATA

We retain Personal Data only for as long as necessary to:

  • Deliver our Services;
  • Meet legal, contractual, or business obligations;
  • Enforce our rights or respond to claims.

Retention is based on legal obligations, data sensitivity, purpose, and risk.

SECURITY OF PERSONAL DATA

We use technical and organisational safeguards to protect your Personal Data. Despite these measures, no system is completely secure. Avoid sending sensitive information via insecure channels.

If a data breach is likely to result in a material risk to your rights and freedoms, we will notify you and applicable authorities within five days, unless otherwise required.

YOUR RIGHTS AS A DATA SUBJECT

You have the right to:

  • Be informed about processing;
  • Request access, rectification, restriction, or deletion of your Personal Data;
  • Object to direct marketing;
  • Contact the Controller to exercise rights under GDPR if you're an EU/UK resident.

To exercise these rights, contact us at the Notice Address below.

CONTACT US

The Company is the Controller of the Personal Data we process under this Privacy Policy.

Email: [email protected]
Address: Ink Foundation
Leeward Management Limited
Suite 3119, 9 Forum Lane, Camana Bay
PO Box 144, George Town,
Grand Cayman, KY1-9006
Cayman Islands