Hazelbit

1. Who we are

Hazelbit SRL, registered at Str. Fântânilor 43, Bl. B14, Ap. B39, Iași, Romania (Trade register J22/1676/2024, CUI 50078499, EUID ROONRC.J22/1676/2024), is the data controller of your personal data when you use our website, apps, wallets, certificates, or NFT features (together, the "Services").

Contact: info@hazelbit.ro

Data Protection Officer (DPO): info@hazelbit.ro

2. What data we collect

We may collect and process:

Identity Data:name, surname, username, account ID.

Contact Data:email, phone number, address.

Payment Data:billing address, card/bank details (processed by secure payment partners), transaction identifiers.

Blockchain Data:wallet address, public keys, transaction IDs, NFT identifiers.

KYC/AML Data:ID documents, tax code, country of residence (if required for token/NFT purchase).

Usage Data:IP address, device info, browser, activity logs.

Cookies & Tracking:preferences, analytics, advertising IDs.

3. How we collect data

Directly from you (forms, registration, checkout, KYC upload).

Automatically (cookies, server logs, device).

From third parties (payment providers, blockchain partner, analytics).

4. How we use your data

We process your data for:

Service delivery— account creation, certificates, NFT issuance, wallet operations.

Payments & billing— to process transactions securely.

KYC/AML compliance— where legally required.

Communication— emails, notifications, customer support.

Analytics & performance— usage trends, product improvements.

Marketing— if you opted in, to send newsletters and promotions.

Legal & compliance— to respond to legal obligations or authorities.

5. Legal bases under GDPR

Contract performance (Art. 6(1)(b))— to provide Services you request.

Consent (Art. 6(1)(a))— for marketing, cookies, optional features.

Legal obligation (Art. 6(1)(c))— AML/KYC, tax reporting.

Legitimate interest (Art. 6(1)(f))— fraud prevention, security, analytics.

6. Cookies & tracking

We use cookies to:

• Remember login/session.

• Measure traffic and performance.

• Deliver personalized ads (Google Ads, Meta Ads, TikTok Ads).

You can manage preferences via the cookie banner and browser settings. See our Cookie Policy for details.

7. Sharing your data

We may share with:

• Payment processors (e.g., Stripe, PayPal).

• Blockchain partner (Commercio.network, notarization only).

• Cloud & IT providers (AWS, Cloudflare, hosting).

• Analytics & marketing tools (Google Analytics, Hubspot, TikTok Ads).

• Authorities (when legally required).

We do not sell your data.

8. International transfers

Some partners may be outside the EU/EEA. In such cases, we use:

• Adequacy decisions (e.g., UK, Switzerland).

• Standard Contractual Clauses (SCCs).

• Equivalent safeguards under GDPR.

9. Data retention

Account data:kept while your account is active + 5 years (legal retention).

KYC data:retained 5 years from end of relationship (AML law).

Payment records:10 years (tax law).

Cookies/analytics data:max 2 years.

Marketing data:until you unsubscribe.

10. Your rights (EU/EEA)

You have the right to:

• Access your data

• Correct inaccurate data

• Request deletion ("right to be forgotten")

• Restrict processing

• Data portability

• Object to processing (including marketing)

• Withdraw consent anytime

To exercise rights:info@hazelbit.ro

You also have the right to complain to ANSPDCP (Romanian Data Protection Authority).

11. US notices

California (CCPA/CPRA)

You have the right to request disclosure, correction, deletion, and opt-out of sale/sharing of personal data. Hazelbit does not sell personal data.

Virginia, Colorado, Connecticut, Utah

You may request access, correction, deletion, and appeal refusals. Contact: info@hazelbit.ro.

12. Brazil (LGPD)

For Brazilian users, you have rights of access, correction, deletion, anonymization, portability, and withdrawal of consent. Our legal basis may include contract, consent, or legal obligation.

13. Children's privacy

Hazelbit does not knowingly collect personal data of minors under 18 years. If we become aware, we will delete it.

14. Security

We implement technical and organizational measures:

• Encryption in transit and at rest

• Role-based access control

• Regular audits and penetration tests

• Hosted wallet protections

Important: No system is 100% secure, but we work to reduce risks.

15. Changes

We may update this policy. We will notify users of material changes via email or in-app notice.

16. Contact

Hazelbit SRL

Str. Fântânilor 43, Bl. B14, Ap. B39, Iași, Romania

Email:info@hazelbit.ro

Privacy inquiries:info@hazelbit.ro

Privacy Policy