🔐 Introduction
SPHERING³ LLC ("SPHERING³," "Company," "we," "us," or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy describes how we collect, use, disclose, and safeguard your information when you use the Thorium Marketplace, StoryHub Marketplace, and all related websites, applications, and services (collectively, the "Services").
Please read this Privacy Policy carefully. By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use the Services.
📊 1. Information We Collect
1.1 Information You Provide Directly
Account Information:
- Blockchain wallet addresses
- Username or display name (if chosen)
- Email address (if provided for notifications)
- Profile information (biography, avatar, social links)
Identity Verification Information (when required):
- Full legal name
- Date of birth
- Government-issued identification documents
- Proof of address
- Photographs for identity verification
- Tax identification numbers
Transaction Information:
- RADs you create, purchase, sell, or transfer
- Listing details and pricing
- Offer and bid history
- Payment information (processed by third-party providers)
Content:
- Files uploaded for rarification
- Metadata you provide (titles, descriptions, attributes)
- Communications with us (support requests, feedback)
1.2 Information Collected Automatically
Device and Browser Information:
- IP address
- Browser type and version
- Operating system
- Device type and identifiers
- Screen resolution
- Language preferences
Usage Information:
- Pages viewed and features used
- Time spent on pages
- Click patterns and navigation paths
- Search queries within the Services
- Referring websites
Blockchain Data:
- Public blockchain transaction data
- Wallet activity related to the Services
- Smart contract interactions
🔧 2. How We Use Your Information
2.1 Providing and Improving the Services
- Process rarification requests and mint RADs
- Facilitate marketplace transactions (listings, sales, offers)
- Display and promote content on the platform
- Verify your identity when required
- Provide customer support
- Send transactional notifications
- Improve and optimize the Services
- Develop new features and functionality
2.2 Security and Fraud Prevention
- Detect and prevent fraud, abuse, and security threats
- Monitor for terms of service violations
- Verify wallet ownership and authorization
- Protect the integrity of the marketplace
- Comply with legal obligations
2.3 Analytics and Research
- Analyze usage patterns and trends
- Measure the effectiveness of features
- Conduct research and development
- Generate aggregated, anonymized statistics
2.4 Communications
- Respond to your inquiries and support requests
- Send service-related announcements
- Provide marketing communications (with your consent where required)
- Notify you of policy changes
⚖️ 3. Legal Bases for Processing
If you are located in the European Economic Area (EEA), United Kingdom (UK), or a jurisdiction with similar data protection laws, we process your personal data based on the following legal grounds:
| Legal Basis | Purpose |
|---|---|
| Contract Performance | Processing necessary to provide the Services you requested; Account management and transaction processing |
| Legitimate Interests | Security and fraud prevention; Analytics and service improvement; Enforcing our terms |
| Legal Obligation | Tax reporting and compliance; Responding to legal process; Anti-money laundering requirements |
| Consent | Marketing communications where required; Optional data collection and sharing; Cookies and similar technologies |
🤝 4. How We Share Your Information
4.1 Public Information
The following information is publicly visible on the blockchain and/or the Services:
- Wallet addresses and transaction history
- RADs you own, create, or sell
- Public profile information
- Listing and sales data
4.2 Service Providers
We share information with third-party service providers who assist us in operating the Services:
| Provider Type | Purpose | Data Shared |
|---|---|---|
| Cloud hosting | Infrastructure | All data processed through Services |
| Payment processors | Transaction processing | Payment details, transaction amounts |
| Identity verification | KYC/AML compliance | Identity documents, verification data |
| Analytics | Usage analysis | Anonymized usage data |
| Storage providers (Arweave) | Permanent content storage | Content files, metadata |
4.3 Legal Requirements
We may disclose information if required by law or if we believe disclosure is necessary to:
- Comply with legal process (subpoena, court order)
- Protect our rights, privacy, safety, or property
- Prevent fraud or abuse
- Protect the rights of third parties
- Respond to government requests
🌍 5. International Data Transfers
Your information may be transferred to and processed in countries other than your country of residence, including the United States, where data protection laws may differ.
For transfers from the EEA, UK, or Switzerland to countries not deemed adequate by relevant authorities, we implement appropriate safeguards, including:
- Standard Contractual Clauses approved by the European Commission
- Data processing agreements with service providers
- Additional technical and organizational measures
⏰ 6. Data Retention
We retain your information for as long as necessary to:
- Provide the Services
- Comply with legal obligations
- Resolve disputes
- Enforce our agreements
| Data Type | Retention Period |
|---|---|
| Account information | Duration of account + 3 years |
| Transaction records | 7 years (tax/legal requirements) |
| Identity verification | 5 years after relationship ends |
| Support communications | 3 years |
| Analytics data | 2 years (then anonymized) |
| Marketing preferences | Until withdrawn |
🔗 Blockchain Data: Information stored on blockchain is permanent and cannot be deleted by us. Content stored on Arweave is designed for permanent storage (200+ years).
✋ 7. Your Rights and Choices
7.1 All Users
- Access: You may request a copy of the personal data we hold about you
- Correction: You may request correction of inaccurate personal data
- Deletion: You may request deletion of your personal data, subject to our legal retention obligations (Note: Blockchain and Arweave data cannot be deleted)
- Objection: You may object to processing based on legitimate interests
- Withdrawal of Consent: Where processing is based on consent, you may withdraw consent at any time
- Data Portability: You may request your data in a portable format
7.2 EEA, UK, and Swiss Residents
Under GDPR and equivalent laws, you have additional rights including:
- Right to lodge a complaint with your local data protection authority
- Right to restrict processing
- Right not to be subject to automated decision-making
7.3 California Residents
Under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA), California residents have the right to:
- Know what personal information is collected
- Know whether personal information is sold or disclosed and to whom
- Opt out of the sale of personal information
- Access personal information
- Request deletion of personal information
- Non-discrimination for exercising privacy rights
We do not sell personal information as defined under California law.
7.4 Communication Preferences
You may opt out of:
- Marketing emails: Click "unsubscribe" in any marketing email
- Push notifications: Adjust settings in your device or browser
- Promotional communications: Contact privacy@sphering3.com
🍪 8. Cookies and Similar Technologies
8.1 What We Use
We use cookies and similar technologies to:
- Remember your preferences
- Understand how you use the Services
- Improve user experience
- Provide security features
- Analyze traffic and performance
8.2 Types of Cookies
| Type | Purpose | Duration |
|---|---|---|
| Essential | Core functionality, security | Session |
| Functional | Preferences, settings | 1 year |
| Analytics | Usage statistics | 2 years |
| Performance | Site optimization | 1 year |
8.3 Your Choices
- Browser Settings: Most browsers allow you to refuse or delete cookies through settings
- Cookie Banner: Where required by law, we provide a cookie consent banner
- Do Not Track: We do not currently respond to "Do Not Track" browser signals
🔒 9. Security
We implement appropriate technical and organizational measures to protect your personal data, including:
- Encryption of data in transit and at rest
- Access controls and authentication
- Regular security assessments
- Employee training on data protection
- Incident response procedures
- Protect your wallet private keys
- Use strong, unique passwords
- Enable two-factor authentication where available
- Report suspected security incidents to security@sphering3.com
👶 10. Children's Privacy
The Services are not intended for individuals under the age of 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal data from children. If we learn that we have collected personal data from a child, we will take steps to delete such information.
If you believe we have collected information from a child, please contact us at privacy@sphering3.com.
🔗 11. Third-Party Links
The Services may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies before providing any personal data.
📝 12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated Privacy Policy on the Services
- Updating the "Last Updated" date
- Sending you an email notification (for significant changes)
Your continued use of the Services after changes become effective constitutes your acceptance of the updated Privacy Policy.
👨💼 13. Data Protection Officer
For EEA and UK residents, our Data Protection Officer can be contacted at:
📞 14. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at: