← Back to home

Privacy Policy

DRAFT — Requires legal review before publication. Last updated: March 2026.

1. Introduction

This Privacy Policy explains how [ENTITY NAME] ("FM", "we", "us") collects, uses, stores, and protects personal data in connection with the FM Coin community platform. We are committed to processing your data in compliance with the GDPR (EU 2016/679) and the Belgian Data Protection Act of 30 July 2018.

2. Data We Collect

On-chain data (Base blockchain):

Wallet address, FM Coin balance, display name, city, location sharing preference, reward points, event registrations, and event details. On-chain data is public, permanent, and cannot be deleted.

Off-chain data:

Chat messages (stored in PostgreSQL), wallet signatures for authentication (session-only, never persisted), and analytics data (only with your consent via the cookie banner).

Data we do NOT collect:

GPS coordinates, email addresses (unless provided for support), phone numbers, government IDs (unless KYC is legally required), browsing history, device fingerprints, or social media accounts.

3. Legal Basis (GDPR Art. 6)

ProcessingBasis
Profile dataContractual necessity — Art. 6(1)(b)
Chat messagesContractual necessity — Art. 6(1)(b)
Location sharingExplicit consent — Art. 6(1)(a)
Analytics cookiesExplicit consent — Art. 6(1)(a)
Transaction recordsLegal obligation — Art. 6(1)(c)

4. Your GDPR Rights

You have the right to: access your data (Art. 15), rectify it (Art. 16), erase off-chain data (Art. 17), restrict processing (Art. 18), data portability (Art. 20), object to processing (Art. 21), and withdraw consent (Art. 7). On-chain data cannot be erased due to blockchain immutability — your profile can be deactivated but historical records persist.

To exercise your rights, contact [DPO/PRIVACY EMAIL]. We will respond within 30 days. You may also lodge a complaint with the Belgian supervisory authority (APD/GBA).

5. Data Retention

DataRetention
On-chain dataPermanent (blockchain immutability)
Chat messagesUntil deleted or 24 months inactivity
Event metadata90 days after event date
Auth signaturesSession only

6. Cookies and Analytics

We use Google Analytics with anonymized IP addresses to understand platform usage. Analytics cookies are only loaded after you explicitly consent via the cookie banner. If you reject cookies, no analytics data is collected. You can change your preference at any time by clearing your browser's local storage.

7. Contact

Data Protection contact: [DPO/PRIVACY EMAIL]
Entity: [ENTITY NAME], [ADDRESS]
Belgian supervisory authority: APD/GBA — www.dataprotectionauthority.be

The full privacy policy is available at docs/legal/privacy-policy.md. This page is a summary for your convenience.