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Privacy Policy

Last updated: February 10, 2025

DeFi Labs GmbH operates Nudge.xyz (“we,” “Nudge.xyz”) and respects your right to privacy. This Privacy Notice explains who we are, how we collect, share, and use personal data about you, and how you can exercise your privacy rights. This Privacy Notice only applies to personal data that we collect directly when you access nudge.xyz and use Nudge.xyz’s services.

If you have any questions or concerns about our data protection practices after reading this Notice, then please contact us at: info@nudge.xyz. Our physical address is: DeFi Labs GmbH, Torstr. 42, 10119 Berlin.

What does Nudge.xyz do?

  • Nudge.xyz is a web-based interface for identifying and accessing opportunities to realize your user reallocation value. Users connect their wallet to the interface and generate a score showing them our view of their reallocation value and join campaigns to earn rewards. Projects or entities may use the interface to launch campaigns deployed as immutable smart contracts, whereby the project or entity offers rewards to users who take specified actions.

  • Nudge.xyz does not collect and store personal data, such as first name, last name, street address, or date of birth in connection with your use of our services. Nudge.xyz does collect email addresses as part of waitlist sign-ups, but does not link them with blockchain addresses. Nudge.xyz may collect non-identifiable data, such as limited off-chain data like device type, operating system, browser version, and country of access, among others. Nudge.xyz also may collect public, on-chain data. Any data collected is used to help drive product development, not to track users.

What personal data does Nudge.xyz collect and why?

Privacy is a core tenet of Nudge.xyz, and we endeavor to collect as little personal information about you as possible while satisfying our regulatory obligations and ensuring excellent product development. We are committed to transparency about what little data we do collect. Nudge.xyz does not maintain user accounts directly, and we do not directly collect and store personal data, such as your name or IP address. When you interact Nudge.xyz, we may collect the following:

  • Website/App Visitors: We rely on Vercel and Plausible Analytics to provide website analytics related to Nudge.xyz. Vercel and Plausible Analytics provide a privacy-friendly experience for visitors — we do not use cookies or collect personally identifiable information based on your mere usage of Nudge.xyz. We collect information like unique visitors, total visits (sessions), total pageviews, views per visit, bounce rate, visit duration, top pages, top referrers, and demographics like country, operating system, and browser information. You can view Vercel’s documentation here, and Plausible Analytics’ documentation here.

  • Publicly available blockchain data: When you connect your non-custodial blockchain wallet to Nudge.xyz and/or create a campaign, we may collect and log your publicly available blockchain address to learn more about your use of Nudge.xyz. Please note that blockchain addresses are publicly available data that are not created or assigned by Nudge.xyz and, by themselves, are not personal information.

  • Information you specifically provide us: If you specifically provide us with personal information — such as by communicating with us via email, Discord, or social media — we may use that information for the purposes described when you provided it to us.

Who does Nudge.xyz share my personal data with?

Nudge.xyz does not collect or unilaterally share your personal information with anyone as a routine part of your use of our services. If you correspond with us and request us to access or share information with a partner, we may do so with your consent. If you join a campaign using Nudge.xyz’s interface, the campaign will have access to your publicly available blockchain wallet address.

What is the legal basis for processing personal data?

Consent. Nudge.xyz processes your information when you have corresponded with us, asked us to do so, and provided your consent. At any time, you have a right to withdraw your consent.

Security. We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect Nudge.xyz and its users.

Legal Obligations. Nudge.xyz may also process your information when required to fulfill our legal obligations.

International data transfer

Nudge.xyz is based in Germany. Your use of Nudge.xyz may require your data to be transferred to and processed outside the European Economic Area (EEA) in order for Nudge.xyz to satisfy its legal obligations, but Nudge.xyz does not routinely collect personal information or transfer personal information outside the EEA.

Any data transfers outside the EEA are subject to appropriate safeguards including European Commission adequacy decisions, binding corporate rules, standard contractual clauses, and the Trans-Atlantic Data Privacy Framework.

Data retention

Nudge.xyz does not intentionally retain personal information, and acquires it only when it comes into our possession through our direct interactions with you. Personal information that may come into our possession is destroyed in the ordinary course of business

Your data protection rights

We respect data protection rights and individual privacy no matter where our users are located. Under the General Data Protection Regulation, all of our users generally have the following data protection rights:

If you wish to access your personal data, you can do so at any time by contacting us using the contact details provided at the beginning of this notice.

If you wish to correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided at the beginning of this notice.

You have the right to object to processing of your personal data, ask us to restrict processing of your personal data, or request portability of your personal data. You can exercise these rights by contacting us using the contact details provided at the beginning of this notice.

If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Please know that withdrawing your consent will not affect the lawfulness of any processing we conducted before your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent.

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority.

We respond to all requests we receive from people wishing to exercise their data protection rights in accordance with applicable data protection laws. We encourage you to contact us with any concerns, as we would be happy to try to resolve it directly.

Jurisdiction-specific disclosures

We apply the General Data Protection Regulation to all users, but recognize there are many other jurisdiction-specific data protection and privacy requirements. We believe in transparency and maximum user knowledge about their rights, even when we do not believe the jurisdiction-specific rules apply or require us to take a different action than the General Data Protection Regulation. Additional jurisdiction-specific information may be added over time.

  1. Privacy information for California residents

    The California Consumer Privacy Act (CCPA) gives California residents the right to opt out of the sale of personal information. We do not "sell" information that directly identifies you such as your name, telephone number, mailing address or email address — we do not routinely collect nor provide user personal information to third parties for monetary or other valuable consideration.

    If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

    • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
    • Provide access to and/or a copy of certain personal information we hold about you.
    • Delete certain personal information we have about you.
    • Provide you with information about the financial incentives that we offer to you, if any.

    Please note that certain information may be exempt from such requests under California law. For any requests that are received, we will take reasonable steps to verify your identity before responding to a request.

    You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent's request.

    Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests. The reporting information required by the California Consumer Privacy Act Regulations § 999.317 is available here.

    The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not provide user personal information to third parties for marketing purposes.

  2. Privacy information for Nevada residents

    We do not believe that our information sharing as disclosed in this policy would qualify as a sale under Nevada law.

    That said, under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the "sale" of "covered information" (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. "Covered information" includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by emailing us at info@nudge.xyz. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

Cookie Policy

Nudge.xyz uses cookies and may use similar technologies to operate and administer the interface and campaign builder. These cookies are strictly necessary to provide critical features — these cookies are essential to Nudge.xyz’s operation, and without these cookies, basic functionalities would not be possible. Because these cookies are strictly necessary, users are unable to refuse them under applicable law. We do not use cookies for purposes of analytics.

Where required by law, we will ask for your consent prior to storing cookies on your computer and will place the cookies only if you consent.

Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical, or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws.

You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.