Privacy Policy - CBTC Incentive Campaign

Privacy Policy

Last Updated: Dec 03, 2025

1. Introduction

This Privacy Policy ("Policy") explains how DLC.Link, Inc. ("DLC.Link," "we," "us," or "our"), the organizer of the BitSafe CBTC Incentive Campaign (the "Campaign"), collects, uses, and shares information about you when you participate in the Campaign. For marketing purposes, DLC.Link may use the "BitSafe" brand.

By participating in the Campaign, you agree to the collection, use, and sharing of your information as described in this Policy. If you do not agree, you must not participate.

This Policy should be read in conjunction with the BitSafe CBTC Incentive Campaign Terms & Conditions.

2. Information We Collect

We collect information necessary to operate the Campaign, ensure its integrity, and comply with legal obligations. The information we collect includes:

On-Chain Information: To verify your eligibility and distribute rewards, we collect and analyze public blockchain data associated with your participation. This includes:

  • Your wallet address.
  • Transaction hashes, amounts, and timestamps of Qualified Sends.
  • The wallet addresses you send CBTC to.

Information for Verification (if required): As stated in the Terms & Conditions, we may require you to complete Know Your Customer (KYC) or Anti-Money Laundering (AML) checks to confirm your eligibility. In such cases, we or our third-party service providers may collect:

  • Your full name, date of birth, and residential address.
  • Contact information, such as your email address or phone number.
  • Government-issued identification documents (e.g., passport, driver's license).
  • Other information required to verify your identity and check against sanctions lists.

3. How We Use Your Information

We use the information we collect for the following purposes:

  • To Administer the Campaign: To track your participation, verify Qualified Sends, and credit rewards to your wallet.
  • To Verify Eligibility: To confirm that you meet the eligibility criteria set out in the Terms & Conditions, including age and jurisdictional requirements.
  • To Prevent Fraud and Abuse: To monitor for prohibited conduct, such as Sybil attacks, multi-account farming, wash trading, and other abusive behaviors that violate the Terms & Conditions.
  • To Comply with Legal Obligations: To fulfill our legal and regulatory requirements, including AML and sanctions compliance, and to respond to lawful requests from government authorities.
  • To Communicate with You: To send you important notices about the Campaign, such as updates to the Terms or this Policy.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

  • With Service Providers: We may share your information with third-party vendors and service providers who assist us in operating the Campaign, such as KYC/AML verification providers and blockchain analytics firms.
  • For Legal Reasons: We may disclose your information if we believe it is required by applicable law, regulation, legal process, or governmental request. This includes sharing information with law enforcement or regulatory bodies to combat fraud and ensure compliance.
  • To Enforce Our Terms: We may share information to enforce our Terms & Conditions and protect the security and integrity of the Campaign.
  • With Your Consent: We may share your information for other purposes with your explicit consent.

Note that on-chain information is public by nature and is not subject to the privacy protections in this Policy.

5. Data Security and Retention

We implement reasonable security measures to protect your information from unauthorized access, use, or disclosure. However, no security system is impenetrable, and we cannot guarantee the absolute security of your information.

We will retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. On-chain information will remain publicly available on the blockchain indefinitely.

6. Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal information, such as the right to access, correct, or delete your data. Please note that it is not possible to alter or delete on-chain data, as it is immutable.

To exercise any applicable rights, please contact us using the information below.

7. Children's Privacy

The Campaign is not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have inadvertently collected information from a child, we will take steps to delete it.

8. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Policy on the Campaign page and updating the "Last Updated" date. Your continued participation in the Campaign after any changes constitutes your acceptance of the new Policy.

9. Contact Us

If you have any questions about this Privacy Policy, please contact us in our Telegram community.