Privacy Policy

Last Updated Jan 16, 2024 

1. INTRODUCTION

ADD MGH and its affiliates (hereinafter referred to as “ADD MGH”, the “Association”, “we”, “us” or “our”) are committed to protecting and respecting your privacy.

This privacy policy (hereinafter referred to as “Privacy Policy”) together with our Terms of Use (hereinafter referred to as “TOU”) explains how ADD MGH operates and how it may - from time to time - use your personal information (hereinafter referred to as “Personal Information”) when users access the website: dirac.finance (hereinafter referred to as the “Platform”).

ADD MGH is a software development Association which has developed a technical system based on smart contracts, more specifically, an institutional grade decentralized options vault that allows investors to earn yield through options, structured products, and principal-protected coupon notes’ strategies by providing liquidity to dirac.finance platform in a decentralized manner (hereinafter referred to as “Protocol” or “Application”).

The Protocol is open source, operates as a decentralized autonomous organization (hereinafter referred to as “DAO”) and is to be maintained by the community. The Association owns and operates the Platform which acts as a front-end only to the decentralized Protocol, giving the users an access point to the Protocol (hereinafter referred to as “Access”). In this context, this Privacy Policy describes why and how we may collect and use Personal Information and provides information about individuals’ rights in relation to Personal Information.

2. PURPOSE OF PRIVACY POLICY

The purpose of this Privacy Policy is to set out in an accountable and transparent way the collection and use of information by ADD MGH.

3. PERSONAL INFORMATION

Personal Information is information which identifies you personally or by which your identity can reasonably be ascertained:

• Content, within any messages you send to us via our contact address: info@dirac.finance, (such as feedback, questions, job applications, etc.)
• Worldwide web-related information, including but not limited to IP Addresses, operating systems, and browser type may be received by ADD MGH as a result of your interactions with Dirac Finance Platform and social media networks (Discord, X, Telegram,etc).

Notwithstanding the above-mentioned situations, the Association does not receive, save, or collect, personal data from the users of the Application, to which ADD MGH gives Access to, as neither we nor any affiliated entity is a party to any transaction on the blockchain networks underlying the Protocol.

Blockchains provide transparency into transactions and ADD MGH  is not responsible for preventing or managing information broadcasted on a blockchain.

Important notice: Given the use of services offered via the Platform, the Personal data of users may be processed and stored within the blockchains used for the processing of digital asset transactions. Therefore, the user is informed that, in any event, such processing is not the responsibility of ADD MGH, which does not manage nor control said blockchains, and as such does not have any power of determination nor control over the possible processing of Personal data which may be implemented in connection with said blockchains.

4. PURPOSE OF PERSONAL INFORMATION COLLECTION

Personal Information may be collected in order to:

• provide Access to the Protocol efficiently and effectively;
• inform you about supplying and financing features;
• provide information to you about developments and new products, including changes and enhancements to the Platform;
• conduct surveys and get feedback from you;
• establish and maintain a responsible commercial relationship with you;
• provide you with news and other matters of general interest to you as ADD MGH customer;
• meet ADD MGH’s legal and regulatory requirements.

5. SECURITY, PROTECTION AND USE OF PERSONAL INFORMATION

ADD MGH  is committed to protecting your privacy. Internally, only a specified number of employees within our business have access to your Personal Information. ADD MGH’s systems and data are constantly under review to ensure that you are getting the best Access and that market borrowing and lending security features are in place.

ADD MGH reserves the right to retain and share certain Personal Information in order to meet our regulatory and statutory requirements. In addition, ADD MGH reserves the right to retain and share certain Personal Information with our corporate partners, and third parties acting on behalf of ADD MGH.

Personal Information and other related data may be exported outside of the jurisdiction in which you reside. Your Personal Information may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement, or regulatory agencies of that country or those countries may be able to obtain access to your Personal Information through foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside.

6. PURPOSE OF THE PROCESSING - LEGAL BASIS

We may process the Personal Information of users, prospects, and in general contacts for the purposes of carrying out our communication operations by email, as mentioned in Section 3 of this Privacy Policy.  

For this purpose, the processed data is limited to your email address. Such processing is carried out based on our legitimate interests to make our products and services known on the market, and more generally to carry out communication operations in the broadest sense of the term. 3

7. ACCESS AND CHANGING OF PERSONAL INFORMATION

You have the right to access the Personal Information we hold about you, and to require the correction, updating, and blocking of inaccurate and/or incorrect data by sending an email to us.

We will aim to respond to your request within 14 days. You may also request the deletion or destruction of your Personal Information, your Account details, or your Transaction details by sending an email to us at: info@dirac.finance

ADD MGH will act on your request only when it is not inconsistent with its legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Information.

Important notice: The exercise of these rights is nevertheless limited, with regard to Personal data that may be necessary for the operation of a blockchain. Indeed, this Data required for the operation of blockchains cannot be modified or erased during the lifetime of the blockchain in question.

In addition, the retention/storage of said Data in said blockchains is not the responsibility of ADD MGH, which does not manage nor control said blockchains, and therefore has no power to determine or control the processing of Personal data which may be implemented in connection with said blockchains, nor to pass on the exercise by data subjects of their rights to said blockchains.

8. SECURITY

We take reasonable steps to protect your Personal Information from misuse, loss, unauthorized access, modification, or disclosure, including implementing appropriate security measures. The security measures in place will, from time to time, be reviewed in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorized access, modification, or disclosure will not occur. There are protective measures that you should take which as well include but are not limited to changing passwords regularly, and not sharing your Personal Information with others unless you clearly understand the purpose of their request and you know with whom you are dealing.

9. RETENTION OF PERSONAL INFORMATION

We will hold your Personal Information only for as long as we must do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements.

In general, Personal Information relating to you shall be deleted after five (5) years after your account is closed. Similarly, we usually retain information about transactions on your account for five (5) years from the date of the transaction.

10. LINKS

There may be links from our Platform to other Platforms and resources provided by third parties. This Privacy Policy applies only to our Platform. Accessing those third-party Platforms or sources requires you to leave our Platform.

We do not control those third-party Platforms or any of the content contained therein and you agree that we are in no circumstances responsible or liable for any of those third-party Platforms, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those Platforms.

We encourage you to review all policies, rules, terms, and regulations, including the privacy policies, of each Platform that you visit.

11. CHANGES

Our policies, content, information, promotions, disclosures, disclaimers, and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of the Association. If we change this Privacy Policy, we will take steps to notify all users by a notice on our Platform and will post the amended Privacy Policy on the Platform.

12. COMPLAINTS TO THE SUPERVISORY AUTHORITY

If you consider that we have not responded adequately to your request or your questions, you are entitled to lodge a complaint with the competent authority in matters of Personal Data Protection, the National Commission for Informatics and Liberties (CNIL), at the following Internet address:

- https://www.cnil.fr/fr/plaintes;

- or to the following postal address: CNIL - 3 PLACE DE FONTENOY - TSA 80715 - 75334 PARIS CEDEX 07.

13. CONSULTATION OF APPLICABLE TEXTS

The text of the General Data Protection Regulation (GDPR) is freely accessible at the following Internet address: https://eur-lex.europa.eu/legal-content/FR/TXT/?uri=CELEX:32016R0679;or on the CNIL webPlatform at the following internet address: https://www.cnil.fr/fr/reglementeuropeen-protection-donnees as well as all applicable texts on the protection of Personal Data and protection of rights and freedoms on the Internet ( https://www.cnil.fr ).

To understand your rights, you can also refer to the explanations provided by the Cnil here: https://www.cnil.fr/fr/les-droits-pour-maitriser-vos-donnees-personnelles.

We point out that in application of articles L.223-1 et seq. Of the Consumer Code, you can, if you are a consumer, object at any time to being canvassed by telephone, by registering for free on www.bloctel.gouv.fr 

14. CONTACT US

If you have any questions, comments, or concerns regarding our Privacy Policy, please contact us at info@dirac.finance

ADD MGH is a French law governed association organized under the law of July 1, 1901 and the decree of August 16, 1901, having its registered office located at 231 rue Saint Honoré, 75001 Paris, registered with the Répertoire National des Associations under number W751264414, represented by its Chairman (Président) Reg Innov Consulting, itself represented by Omar Mehdi Roustoumi