Privacy Policy

1. Introduction

Dlicom Labs Ltd (“Dlicom,” “we,” “us,” or “our”), a company established in the British Virgin Islands, operates the Dlicom application and related services (the “Platform”).

This Privacy Policy explains how we collect, use, process, and disclose information in connection with your access to and use of the Platform, including our web application and mobile applications.

For the purposes of this Privacy Policy, “personal data” means any information relating to an identified or identifiable individual, including information that may be associated with a device, wallet address, username, or other online identifier.

Dlicom is committed to protecting your privacy and has designed the Platform with a privacy-first and data minimization approach. The Platform operates as a non-custodial, wallet-based system, and does not require traditional account registration such as email addresses or passwords.

Dlicom does not require users to provide personally identifiable information such as names, email addresses, or government-issued identification in order to access core functionalities of the Platform.

However, in order to operate, maintain, and improve the Platform, certain information may still be collected or processed, including technical data, usage data, and content that you voluntarily provide.

You acknowledge that blockchain networks are public by nature, and any transactions, wallet interactions, or on-chain activities may be publicly visible and traceable independently of Dlicom.

While the Platform is designed to minimize the collection of personal data, Dlicom does not guarantee anonymity or complete privacy, particularly where data may be inferred from blockchain activity, device identifiers, or user behavior.

The Platform should not be considered an anonymous or privacy-guaranteed system.

By accessing or using the Platform, you confirm that you have read, understood, and agreed to this Privacy Policy.

If you do not agree with this Privacy Policy, you must not access or use the Platform.

1.1 Scope of This Privacy Policy

This Privacy Policy applies to:

  • your access to and use of the Platform;
  • interactions with features such as messaging, social content, wallet functionalities, and communities;
  • any information collected through the Platform or in connection with its operation.

This Privacy Policy does not apply to:

  • blockchain networks or decentralized protocols that operate independently of Dlicom;
  • third-party services, applications, or websites that are not owned or controlled by Dlicom.

1.2 Privacy-First Design

The Platform is designed with a privacy-first architecture, meaning:

  • no mandatory collection of personally identifiable information such as names, email addresses, or government-issued identification;
  • no KYC (Know Your Customer) requirements for accessing core features;
  • user identity is based on wallet addresses and user-defined identifiers such as usernames;
  • usernames are created and controlled by users and may be modified at any time.

Dlicom does not maintain historical records of username changes as part of its standard data processing practices.

However, you acknowledge that:

  • certain data may still be collected automatically (e.g., device information, usage data, and logs);
  • information you choose to share (including content, messages, or media) may be processed and stored;
  • interactions with blockchain networks may involve publicly visible data that is outside the control of Dlicom.

1.3 Relationship with Terms and Conditions

This Privacy Policy forms an integral part of, and should be read together with, the Dlicom Terms and Conditions.

In the event of any inconsistency between this Privacy Policy and the Terms and Conditions, this Privacy Policy shall govern with respect to data protection and privacy matters.

1.4 Updates to This Privacy Policy

Dlicom reserves the right to modify or update this Privacy Policy at any time to reflect changes in legal requirements, technology, or the Platform.

Any updated version will be made available through the Platform, and your continued use of the Platform after such updates constitutes acceptance of the revised Privacy Policy.

2. Data Controller

2.1 Identity of the Data Controller

For the purposes of applicable data protection laws, including the General Data Protection Regulation (GDPR) where applicable, the data controller responsible for the processing of personal data in connection with the Platform is:

Dlicom Labs Ltd

A company established in the British Virgin Islands

2.2 Contact Information

For any questions, requests, or concerns relating to this Privacy Policy or the processing of personal data, you may contact:

Email: [email protected]

2.3 Strictly Limited Role as Data Controller

Dlicom acts as a data controller only to the extent strictly necessary for the operation, maintenance, security, and improvement of the Platform.

You expressly acknowledge and agree that:

  • Dlicom does not act as a data controller or processor for blockchain networks, decentralized protocols, or public distributed systems;
  • Dlicom does not determine the purposes or means of processing data on blockchain networks;
  • any personal data that may be associated with blockchain activity is processed independently of Dlicom;
  • Dlicom’s role is limited to providing an interface that enables interaction with such systems.

3. Information We Collect

3.1 Overview

Dlicom collects and processes limited categories of data necessary to operate, maintain, secure, and improve the Platform.

3.2 Account and Profile Information

We process account-related information required to create and manage user profiles, including:

  • wallet address (used as a unique identifier);
  • username and profile details (such as profile picture and bio);
  • account configuration (e.g., visibility settings);
  • network-related information (e.g., supported blockchain network);
  • account status and activity state;
  • import status (whether a wallet is externally imported).

4. How We Use Information

Dlicom processes information strictly for operational, technical, and security purposes necessary to provide the Platform.

5. Legal Basis for Processing

Where the General Data Protection Regulation (GDPR) or similar laws apply, Dlicom processes personal data only where it has a valid legal basis to do so.

6. Data Sharing and Disclosure

Dlicom does not sell, rent, or commercially exploit personal data. Personal data is shared only where strictly necessary for Platform operation.

7. Data Storage and Retention

Dlicom uses a hybrid storage model combining decentralized and centralized systems.

8. Data Security

Dlicom implements reasonable and appropriate technical and organizational measures designed to protect personal data.

9. User Rights

Where applicable under data protection laws, you may have certain rights in relation to your personal data.

10. International Data Transfers

Dlicom operates on a global basis, and your information may be processed, stored, or accessed in jurisdictions outside of your country of residence.

11. Children’s Privacy

The Platform is not intended for use by individuals under the age of 18 years.

12. Cookies and Tracking Technologies

Dlicom may use limited tracking technologies to support the operation of the Platform.

For any questions regarding this Privacy Policy, please contact [email protected].