Privacy Policy

Last updated: November 22, 2025

1. Introduction

This Privacy Policy describes how Dazzardo Investor Refund System ("we", "us", or "our") collects, uses, and protects your personal information when you use our investor refund questionnaire form.

2. Information We Collect

We collect the following types of information:

• Personal Information: First name, last name, address, email address, phone number
• Financial Information: Investment amount, investment date, IBAN, BIC, BTC wallet address
• Preferences: Your choice regarding refund or token participation, payment method
• Technical Information: IP address, browser type, access times (for security and audit purposes)
• Optional Information: Any additional remarks or notes you provide

3. How We Use Your Information

We use your information for the following purposes:

• Processing your refund or token participation request
• Verifying your identity and investment details
• Communicating with you about your request
• Generating confirmation documents
• Maintaining audit logs for security and compliance
• Improving our services

4. Legal Basis for Processing

We process your personal data based on:

• Your explicit consent when submitting the form
• Contract performance (processing your refund/participation request)
• Legitimate interests (fraud prevention, security, record-keeping)

5. Data Security

We implement appropriate technical and organizational security measures to protect your personal information:

• Encryption of data in transit (HTTPS)
• Secure database storage with access controls
• Regular security audits
• CSRF protection and input validation
• Limited access to personal data (need-to-know basis)

6. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes outlined in this policy, or as required by law. Typically, we keep records for:

• Active refund/participation requests: Until completion + 7 years (for legal/tax purposes)
• Unverified submissions: 30 days after submission
• Audit logs: 5 years

7. Data Sharing and Disclosure

We do not sell or rent your personal information to third parties. We may share your information only:

• With service providers who assist us (e.g., email service, hosting) under strict confidentiality agreements
• When required by law or to protect our legal rights
• With your explicit consent

8. Your Rights

You have the following rights regarding your personal data:

• Right to Access: Request a copy of your personal data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data (subject to legal obligations)
• Right to Restrict Processing: Request limitation of data processing
• Right to Data Portability: Receive your data in a structured format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw your consent at any time

9. Cookies and Tracking

Our website uses minimal cookies for essential functionality:

• Session Cookie: Maintains your session and CSRF protection (essential)
• We do not use advertising or tracking cookies

10. Third-Party Services

We may use the following third-party services:

• Email service providers (for sending confirmation emails)
• Hosting providers (for data storage)

These providers are carefully selected and bound by strict data protection agreements.

11. International Data Transfers

Your data is stored within the European Union. If data is transferred outside the EU, we ensure appropriate safeguards are in place (e.g., Standard Contractual Clauses).

12. Children's Privacy

Our service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page with an updated "Last updated" date.

14. Contact Information

If you have any questions about this Privacy Policy or wish to exercise your rights, please contact us at:

• Email: privacy@dazzardo.com
• Address: [Your Company Address]

15. Supervisory Authority

You have the right to lodge a complaint with your local data protection supervisory authority if you believe your data protection rights have been violated.