PRIVACY POLICY

1. Introduction

This Privacy Policy describes how Titan Protocol collects, processes, stores, and protects data in connection with the Genesis Key concession and the distributed trading infrastructure. Titan Protocol is committed to operating with minimal data collection consistent with the protocol's design philosophy.

2. Data Collected

2.1 Wallet Address

Titan Protocol collects and processes Solana wallet addresses provided by Holders and prospective Holders. Wallet addresses are publicly available on the Solana blockchain. This data is used for:

1. Genesis Key issuance and on-chain verification;
2. Node association and license validation;
3. On-chain activity analysis using publicly available blockchain data;
4. Compliance screening (sanctions lists, risk assessment).

2.2 Telegram User Identifier

For Holders and prospective Holders who interact via Telegram, the Protocol collects:

1. Telegram user ID (numeric identifier);
2. Telegram username (if publicly available);
3. Message content exchanged with Protocol representatives.

This data is used exclusively for communication regarding the Genesis Key concession and node operations.

2.3 On-Chain Activity

The Protocol analyzes publicly available blockchain data associated with Holder wallet addresses, including:

1. Transaction histories on the Solana blockchain;
2. Token holdings and transfer patterns;
3. DeFi protocol interactions;
4. Trading volume, frequency, and behavioral patterns.

This analysis uses data that is already publicly available on the blockchain. No additional surveillance or monitoring beyond publicly accessible on-chain data is performed.

2.4 Technical Data

When Holders access Protocol dashboards or web interfaces, standard technical data may be collected:

1. IP address (for security and rate limiting only, not stored long-term);
2. Browser type and version;
3. Access timestamps.

3. Data Not Collected

Titan Protocol does not collect:

1. Personal names, legal identities, or biographical information;
2. Email addresses or phone numbers;
3. Physical addresses or location data;
4. Government-issued identification documents (unless required by future KYC regulations);
5. Financial account information (bank accounts, credit cards);
6. Biometric data;
7. Social media profiles beyond Telegram identifiers used for communication.

4. Third-Party Sharing

4.1 No Sale of Data

Titan Protocol does not sell, rent, lease, or transfer personal data to third parties for monetary or other consideration.

4.2 Infrastructure Providers

The Protocol interacts with blockchain infrastructure providers (RPC nodes, validators) in the normal course of Solana network operations. Wallet addresses and transaction data are inherently visible on the public blockchain.

4.3 Legal Requirements

Data may be disclosed when required by law, regulation, court order, or to comply with regulatory examinations or investigations.

5. Data Retention

5.1 Wallet and Blockchain Data

Wallet addresses and on-chain analysis are retained for the duration of the concession relationship. Since blockchain data is publicly available and immutable, on-chain records persist independently of Protocol retention practices.

5.2 Communication Data

Telegram conversation histories are retained for twelve (12) months from the last interaction, after which they are purged.

5.3 Technical Data

IP addresses and access logs are retained for a maximum of thirty (30) days for security monitoring purposes.

6. Cookies and Tracking

Titan Protocol does not use:

1. Tracking cookies;
2. Advertising pixels;
3. Third-party analytics services;
4. Cross-site tracking mechanisms.

Essential session cookies may be used for web dashboard authentication. These are strictly functional and do not track behavior across sites.

7. Security Measures

Titan Protocol implements the following security measures to protect data:

1. Encryption at rest using industry-standard algorithms;
2. Encryption in transit using TLS 1.3;
3. Role-based access controls with multi-factor authentication;
4. Regular security audits and vulnerability assessments;
5. Incident response procedures for security breaches;
6. Network-level protections including firewalls and intrusion detection.

8. Holder Rights

Holders may exercise the following rights regarding their data:

8.1 Access

Request confirmation of what data is held and obtain a copy.

8.2 Correction

Request correction of inaccurate data.

8.3 Deletion

Request deletion of data, subject to legal retention requirements and the immutable nature of blockchain records.

8.4 Communication Cessation

Holders may request cessation of all Protocol communications via the /stop command in Telegram or through their designated communication channel.

8.5 Data Portability

Request a structured export of data held by the Protocol, where technically feasible.

8.6 Exercise Process

Rights requests may be submitted through the Holder's designated communication channel. Identity verification via wallet signature may be required. Requests will be processed within thirty (30) days.

9. Blockchain Data Limitations

Holders should understand that:

1. Data recorded on the Solana blockchain is immutable and cannot be deleted;
2. Wallet addresses and transaction histories are publicly visible to anyone;
3. The Protocol cannot control how third parties access or analyze public blockchain data;
4. On-chain cNFT metadata is permanently stored and publicly accessible.

10. Future KYC Requirements

Regulatory developments may require implementation of Know Your Customer (KYC) and Anti-Money Laundering (AML) verification. If implemented:

1. Identity verification will be processed through a designated third-party provider;
2. KYC data will be subject to regulatory retention periods (typically 5-7 years);
3. On-chain enforcement will be limited to verification status (pass/fail) without personal data;
4. This Privacy Policy will be updated to reflect any new data collection practices.

11. Policy Updates

This Privacy Policy may be updated to reflect changes in data practices or regulatory requirements. Material changes will be communicated through the Holder's designated channel with thirty (30) days notice.

12. Contact

Privacy-related inquiries and rights requests may be directed through the Holder's designated communication channel with Titan Protocol.