Gatu — Privacy Policy
Last Updated: January 26, 2025
This Privacy Policy (“Policy”) for Gatu describes the basis on which Gatu Corp. (“Company,” “we,” “us,” or “our”) will process personal data we may collect from users of the interface available at app.gatu.ai, including any subdomains (“Website”), and all related services (“Services”), in accordance with applicable law. For purposes of applicable data protection laws, the Company is the data controller. Capitalized but undefined terms have the meaning given in our Terms of Use at app.gatu.ai/terms.
Personal Data We Collect, Why, and Legal Basis
Information you provide to us may include (i) IP Address; (ii) wallet, smart-contract, or protocol address information, associations, and identifiers; and (iii) geolocation data. It may also include your social media handle, transaction data/history, information needed to transfer or allocate tokens, marketing preferences, token holdings, and the content of any communications with us. We process this to perform our contract with you.
Information we collect automatically: our servers may log (i) the IP Address; (ii) date and time of access; (iii) the country of access; (iv) any API endpoint; (v) user-agent details; (vi) operating system and browser (provider, version, language); and (vii) the transmission protocol. We process this to (i) facilitate your connection to the Website; (ii) identify if you are likely a Prohibited Person or subject to prohibitions; and/or (iii) verify your identity and location to determine eligibility — to perform our contract and in our legitimate interests, including system security, troubleshooting, analytics, testing, and to maintain safety and security.
Cookies and tracking: we may use cookies, web beacons/clear gifs, geolocation and tracking technologies, and collect Usage Data, potentially integrated with third-party providers. With your consent, we may tailor features and content and, if you opt in, use data for marketing.
Third-party wallet connections: governed by the applicable wallet provider’s privacy policy; we disclaim liability for third-party wallets.
Your Rights
Subject to applicable law, you may have rights of: access; correction; deletion; objection; restriction of processing; portability; objection to marketing communications; breach notification; complaint to the data protection supervisory authority in your EEA country, or to the UK Information Commissioner’s Office (ICO); and withdrawal of consent. We will respond without undue delay and, where required, within one month (extendable by a further two months in certain circumstances).
Automated Decision-Making
We will not take decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing unless it meets applicable requirements. Requests: support@gatu.ai.
Sharing of Personal Data
We may share your data with: service providers and vendors (including IP-based geolocation providers such as IPdata, analytics providers such as Mixpanel, blockchain analysis, KYC and screening providers, developers, content delivery, and data analytics providers, who may help determine eligibility); professional advisors; for legal and security reasons; with law enforcement and regulatory authorities; with our affiliates; and in connection with a merger, sale, bankruptcy, or reorganization.
Your personal information may be transferred to and processed in countries outside your jurisdiction, including outside the EEA and the UK and including the U.S. For transfers out of the EEA/UK we seek to put in place appropriate safeguards, including the EU Standard Contractual Clauses (SCCs) and/or the UK ICO international data transfer agreement/addendum, unless an adequacy decision applies.
Retention
We retain personal data only as long as necessary for the purposes for which it was collected, including to satisfy any legal, accounting, or reporting requirements.
Children’s Privacy
Persons under the age of majority in their jurisdiction may not use the Services. We do not knowingly collect data about children under thirteen (13) years of age (or sixteen (16) in the EEA/UK), and will make commercially reasonable efforts to delete such data if discovered.
Security
Despite our efforts, we cannot guarantee “perfect security.” Any information transmitted is at your own risk.
Usage Data Collection
When you access or interact with the Services, we and our third-party service providers may receive and record personal data including your IP Address, digital signature, and wallet-related information.
Social Media and Third-Party Links
We may link to third-party sites and Social Media Platforms (e.g., X, Medium) which we do not own or control; review their policies. Opening such a link may establish a direct connection sharing your IP Address and visit with that platform, and if you are logged in, may link your visit to your profile.
Periodic Reviews and Updates
This Policy takes into account Panama’s Law No. 81 of 2019 and general privacy principles. Individuals in the EU and UK may have GDPR rights and may complain to their supervisory authority or the UK ICO. We may update this Policy; updates apply only to information collected after the change.