Privacy Policy

This Privacy Policy describes how VITADIGITAL LTD (Registration No. HE 459277), Peiraios 30, Floor 1, Flat/Office 1, Strovolos 2023, Lefkosia, Cyprus ("we", "us", or "our") collects, uses, stores, and shares information when you use the Premium NFT marketplace platform ("Platform").

As a Cyprus-registered company operating within the European Union, we are subject to the General Data Protection Regulation (GDPR) and the Cyprus Law on Personal Data Processing. We are committed to protecting your privacy and processing your data lawfully, fairly, and transparently.

1. Data We Collect

1.1 Information you provide directly:

• Your cryptocurrency wallet address (public, on-chain identifier);
• Email address (if you contact us or subscribe to updates);
• Any content you submit through the Platform, including NFT descriptions, profile information, or support messages.

1.2 Information collected automatically:

• IP address and approximate geolocation derived from it;
• Browser type, operating system, and device information;
• Pages visited, time spent on each page, and referring URLs;
• Session tokens (stored in secure, HTTP-only cookies) used for authentication;
• On-chain transaction data associated with your wallet address (publicly visible on the Polygon blockchain).

1.3 Information from third parties:

• Blockchain data from public nodes and indexers (e.g., transaction history, token ownership);
• Analytics data from service providers (where applicable).

2. Legal Basis for Processing (GDPR)

We process your personal data on the following legal bases:

• Contract performance: to provide the marketplace services you have requested;
• Legitimate interests: to prevent fraud, ensure platform security, and improve our services;
• Legal obligation: to comply with applicable laws including anti-money laundering (AML) requirements;
• Consent: for optional communications such as newsletters (you may withdraw consent at any time).

3. How We Use Your Data

We use collected information to:

• Authenticate users and maintain secure sessions;
• Process and display NFT listings, sales, and activity;
• Detect and prevent fraudulent or illegal activity;
• Respond to support requests and legal inquiries;
• Comply with applicable laws and regulatory requirements;
• Analyse usage patterns to improve Platform features and performance;
• Send transactional notifications related to your activity on the Platform.

4. Cookies & Similar Technologies

We use strictly necessary session cookies to maintain authenticated sessions. These cookies are deleted when you disconnect your wallet or close your browser. We do not use third-party advertising cookies or tracking pixels. You may configure your browser to refuse cookies, but this will prevent you from using authenticated features of the Platform.

5. Data Sharing & Disclosure

We do not sell, rent, or trade your personal data. We may share data in the following limited circumstances:

• Service providers: hosting, analytics, and infrastructure providers acting as data processors under appropriate data processing agreements;
• Legal requirements: when required by a court order, governmental authority, or applicable law;
• Safety & security: to investigate fraud, enforce our Terms, or protect the rights of users or third parties;
• Business transfers: in the event of a merger, acquisition, or sale of assets, subject to the acquirer honouring this Policy.

Note: your wallet address and on-chain transaction history are inherently public and visible to anyone on the Polygon blockchain.

6. International Transfers

We primarily process data within the European Economic Area (EEA). Where data is transferred outside the EEA (e.g., to cloud infrastructure providers), we ensure appropriate safeguards are in place, such as Standard Contractual Clauses approved by the European Commission.

7. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes outlined in this Policy, or as required by law. Session tokens are deleted upon logout. IP logs are retained for up to 90 days for security purposes. Transaction records linked to your wallet may be retained for up to 7 years to comply with financial record-keeping obligations.

8. Your Rights (GDPR)

As a data subject under GDPR, you have the following rights:

• Access: request a copy of the personal data we hold about you;
• Rectification: request correction of inaccurate data;
• Erasure: request deletion of your data ("right to be forgotten"), subject to legal retention obligations;
• Restriction: request restriction of processing in certain circumstances;
• Portability: receive your data in a structured, machine-readable format;
• Objection: object to processing based on legitimate interests;
• Withdraw consent: where processing is based on consent, you may withdraw it at any time.

To exercise any of these rights, contact us at privacy@pnmarketplace.com. We will respond within 30 days. You also have the right to lodge a complaint with the Cyprus Commissioner for Personal Data Protection.

9. Security

We implement industry-standard technical and organisational measures to protect your data, including encrypted connections (HTTPS/TLS), access controls, and regular security reviews. However, no system is completely secure, and we cannot guarantee the absolute security of data transmitted over the internet.

10. Children's Privacy

The Platform is not directed at children under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, contact us and we will promptly delete the information.

11. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify users of material changes by posting the revised Policy on the Platform with an updated effective date. Continued use of the Platform after changes become effective constitutes your acceptance of the revised Policy.

12. Contact & Data Controller

VITADIGITAL LTD (Data Controller)
Peiraios 30, Floor 1, Flat/Office 1
Strovolos 2023, Lefkosia, Cyprus
Registration No. HE 459277
Privacy enquiries: privacy@pnmarketplace.com
General enquiries: legal@pnmarketplace.com