PRIVACY POLICY

1. Introduction

This Privacy Policy ("Policy") governs the collection, use, and protection of personal data in the context of the Anglium Network's ("Anglium," "we," "us," "our") activities. Anglium is a decentralized DePIN project that operates on the Solana blockchain and combines elements of distributed infrastructure, tokenized rewards, DAO mechanisms, and NFT access to create a transparent and innovative ecosystem.

Anglium's goal is to enable users to join a decentralized proxy network that allows them to efficiently use unused internet bandwidth, contribute to infrastructure development, and receive rewards in the form of internal points during the testing phases or $ANG tokens after the public launch.

As part of the Anglium Services (hereinafter referred to as "Anglium Services"), users are provided with access to the following features and platforms:

Official website (angliumnetwork.com and related subdomains), where basic information about the project, documentation, and materials for the community are published.
Dashboard Application – a web interface for users that allows them to track the performance of their own nodes, view earned rewards, analyze metrics, and participate in the ecosystem.
NFT Node Passes – special digital tokens that provide access to private test launches, grant voting rights in the DAO, and unlock additional bonuses in farming and management.
Farming and Rewards System – a mechanism for distributing points (during the closed test phase) or $ANG tokens (during the public launch phase) that users receive for their contribution to the development of the network.
DAO Governance Layer – a decentralized management layer within which users can participate in voting and decision-making that affects the future of Anglium.

At Anglium, we take privacy very seriously. We understand that user trust is a key value for the long-term development of decentralized networks, so we are committed to:

collecting only the minimum amount of personal data necessary for the functioning of the Services;
using the collected data exclusively for clearly defined and transparent purposes;
never selling, renting, or monetizing user data in a way that violates their rights or expectations;
ensuring an adequate level of technical and organizational protection of information in accordance with modern security standards.

This Policy is designed to help you understand what data we may collect, how and for what purpose it is used, what rights you have under applicable law (in particular, the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), and how you can exercise those rights.

By using Anglium Services, you confirm that you have read this Policy and agree to its terms. If you do not agree with the terms of the Policy, we recommend that you refrain from using Anglium Services.

2. Consent from Users (GDPR / CCPA Notice)

By using Anglium Services and participating in the Anglium Network, you give your direct and informed consent to the collection, use, and processing of your personal data within the scope described in this Privacy Policy. We strive to ensure maximum transparency and clarity in our approaches so that you can make informed decisions about how and to what extent you wish to interact with our services.

2.1. Users from the EU, the UK, and Switzerland (GDPR)

If you are located in the European Economic Area (EEA), the United Kingdom, or Switzerland, the processing of your personal data is governed by the provisions of the General Data Protection Regulation (GDPR). This means that:

you have a number of rights under the law, including the right to access, correct, or delete data ("right to be forgotten"), the right to restrict processing, transfer data, and the right to object to certain types of processing;
any data processing is carried out by us only on legal grounds (e.g. performance of a contract with you, your consent, or our legitimate interests that do not conflict with your rights);
you have the right to withdraw your consent at any time, without any negative consequences for the services already provided to you, except in cases where further use of the service without such data is technically or legally impossible.

2.2. Users from the United States (California) (CCPA)

If you are a resident of California (USA), you are subject to the provisions of the California Consumer Privacy Act (CCPA). In particular, you have the right to:

know what categories of data we collect, how we use them, and for what purpose;
request the deletion of your personal data from our systems (except where the retention of such data is necessary to comply with legal obligations or for technical support of the blockchain);
prohibit the transfer of your data to third parties for commercial purposes;
not be discriminated against when exercising your privacy rights (we do not restrict access to services if you refuse to provide certain information, except for information that is critical to their functioning).

2.3. Right to Withdraw Consent

You have the right to withdraw your consent to data processing at any time by contacting us using the contact details provided in Section 16 of this Policy. It is important to understand that withdrawing consent may affect your ability to continue using some or all of the features of Anglium Services. For example, we will not be able to provide you with access to farming or the dashboard without processing certain technical data (IP address, public Solana address, etc.).

2.4. Legal Restrictions

We reserve the right to retain certain categories of data even after you withdraw your consent if such retention is necessary for:

compliance with applicable law;
fulfilling legal obligations;
preventing fraud or abuse on the network;
ensuring the integrity of blockchain records, which are by nature irreversible and immutable.

3. What is Personal Information

Within the scope of this Policy, the term "personal data" or "personal information" refers to any information that directly or indirectly allows the identification of a specific individual, device, or user account. In accordance with international standards (GDPR, CCPA, and other acts), personal information may be considered any information that allows you to be identified individually or in combination with other data.

3.1. Examples of personal data in the context of Anglium

When using Anglium Services, you may provide us with or automatically share with us the following types of personal data:

Identification information: email address, login, username (if you create one), password (in cases where centralized access is used, for example, for private testing).
Digital wallet data: public Solana address linked to your account in the system (private keys or seed phrases are never collected or stored by us).
Technical data: IP address, device data (operating system, browser, connection type), as well as node performance metrics (node uptime, bandwidth, traffic transferred).
Service usage data: number of points or $ANG tokens earned through farming, information about participation in DAO votes, and use of an NFT Node Pass.
Communication data: any messages you send to our support team or publicly within the integrated community tools.

3.2. Data that is not considered personal

Certain categories of information processed by Anglium are not considered personal:

Aggregated statistical data that does not allow a specific user to be identified (e.g., the number of active nodes in a particular region or the average bandwidth per country).
Anonymised data from which any identifying features have been removed (e.g., analytical usage graphs without IP addresses).
Public blockchain data, as transactions on Solana are inherently transparent and accessible to all users.

3.3. Sensitive data

Anglium does not collect or process sensitive categories of personal data, such as:

biometric data (fingerprints, facial recognition, etc.);
health data;
financial information beyond the public wallet address;
information about political or religious views.

3.4. Important clarification regarding blockchain

Due to the decentralised nature of the Solana blockchain, any transactions made on the network (including transactions related to $ANG or NFT Node Passes) are public and immutable. This means that information about your public wallet and interactions with Anglium may be accessible to third parties, and Anglium does not have the technical ability to delete or hide this data.

4. Information we collect

Anglium strives to collect only the minimum amount of data necessary to ensure the operation of our platform, conduct private testing, support farming functionality, and enable participation in the DAO. All categories of data we collect can be divided into several main groups.

4.1. Account Information

When you create or use an account with Anglium, we may store the following data:

Email address – used for registration, authorization, and access recovery.
Username – displayed in your profile and dashboard.
Solana wallet address – required for integration with NFT Node Pass, receiving $ANG rewards, and DAO voting.
Password/login – only in cases of private testing; in the final version, authentication will take place via Web3 wallets.

4.2. Technical Data

For security and proper network operation, we automatically collect technical parameters of your device and connection:

IP address (used to assess connection quality and ensure the operation of the DePIN node).
Device information: operating system, browser type, client version.
Geolocation at the country level (determined only by IP, without exact coordinates).
Node performance metrics: status (online/offline), uptime, connection stability.

4.3. Usage Data

In order for users to track their progress and earnings in the system, we process the following metrics:

Bandwidth Shared – the amount of bandwidth transferred (in GB).
Uptime – continuous node operation time.
Rewards – number of points in farming or $ANG earned (in the future).
Activity history – data on actions performed in the dashboard (e.g., adding a new node).

4.4. Optional Information

When you contact our support service or send us feedback, we may receive additional data that you provide voluntarily, including:

message text, screenshots or files illustrating the problem,
contact details for a reply.

4.5. Non-personal Data

In addition to personal data, we also collect and process information that does not identify a specific user. Such data may be used for analytics, DAO decisions, and network optimisation:

Aggregated statistics: number of active nodes, average bandwidth in the region, total farming volumes.
Anonymised graphs: service usage per week/month, without linking to specific accounts.
Ecosystem metrics: data that helps the DAO make decisions about network development.

5. Use of your information

We collect and use personal and technical data solely to ensure the operation of the Anglium Network, improve the user experience, and support decentralised infrastructure. We do not sell or transfer data to third parties for commercial purposes. The use of information covers the following areas:

5.1. Network Operations

Distribution of rewards: data about your uptime, bandwidth, and participation in farming is used to calculate and allocate points/$ANG.
Node verification: technical information (IP address, status, uptime) helps to confirm that the node is working correctly and meets the requirements.
NFT Node Pass integration: wallet addresses are used to verify access to private functions and DAO.

5.2. Analytics & Optimisation

We collect aggregated data on traffic, uptime, and node usage for:

load balancing between different regions,
determining the value of unique IP addresses,
improving the efficiency of the Dynamic Pricing Engine,
optimising security and routing algorithms.

Such data is always anonymised and used for statistical purposes only.

5.3. User Communication

We use your email address and username to:

send service messages (account confirmation, password recovery, node status changes),
inform you about news, feature updates, and new farming opportunities,
send DAO notifications (voting announcements and proposals).

You can opt out of receiving promotional messages at any time, but service messages remain mandatory.

5.4. Fraud & Abuse Prevention

We may use technical data (IP address, uptime, bandwidth) to detect:

multi-accounting and attempts to artificially increase rewards,
the use of prohibited bots or scripts,
any attempts to attack the network (DDoS, exploits).

This is necessary to ensure the fairness of rewards and protect the community.

5.5. Legal Compliance

In cases where required by applicable law, we may store or provide information to regulatory authorities. Examples include: compliance with data protection requirements (GDPR, CCPA), AML/KYC in cases of integration with financial services, as well as resolution of legal disputes.

6. Promotional and transactional communication

As part of Anglium Network's operations, we may send you various types of messages. They are divided into transactional (mandatory) and promotional (voluntary, only with your consent).

6.1. Transactional Messages

These are service messages without which the account or node would not be able to function. They are sent automatically after certain events and do not require separate user consent. Examples of such messages:

confirmation of account creation and/or login;
notification of a change to password or security settings;
node status (active/offline/synchronising);
accrual of points/ANG rewards;
system messages about updates (e.g., protocol changes or smart contract updates).

You cannot opt out of these messages as they are an integral part of the service.

6.2. Promotional Messages

These messages are purely informational and promotional in nature and are sent only after your explicit consent (opt-in). Examples of promotional messages:

updates on new dashboard features and additional services;
news about partnerships, investments, or DAO decisions;
announcements about NFT drops, bonuses, or special promotions;
announcements of upcoming public launches, testnets, and events;
marketing campaigns from Anglium partners (only with your consent).

You always have the right to opt out of promotional messages at any time by using the "Unsubscribe" option in the email or by changing your account settings.

6.3. Mailing Principles

We never sell your contact details to third parties.
All messages are sent in accordance with the law (GDPR, CCPA, the CAN-SPAM Act).
We use technical measures (DKIM, SPF, TLS) to protect emails from forgery.

7. Disclosure of information

At Anglium, we adhere to the principle of minimising data transfer and never sell your personal data to third parties. However, within the scope of our network and services, we may in certain cases transfer or provide limited access to your information to specific categories of recipients.

7.1. Hosting & Infrastructure Providers

To ensure the stable operation of the website, dashboard, and network nodes, we work with reliable cloud service providers and data centres. They may receive limited access to the following data:

technical information (IP addresses, node uptime, traffic metrics);
service log files;
error and diagnostic information.

All such providers are required to comply with security and privacy policies that meet the requirements of the GDPR, CCPA, and other applicable laws.

7.2. Partners and Analytics Services (Analytics & Performance Tools)

We may share anonymised and aggregated data with analytics services that help us improve our network and interface. Examples of such data include:

number of active users;
geography of use (by country);
bandwidth;
overall reward statistics.

None of these analytics systems receive personal data that directly identifies the user.

7.3. DAO and Internal Community (DAO Governance & Community)

As part of the transparency of the network's operation, we may share aggregated metrics (e.g., total traffic volume or number of active nodes) with the DAO and community members. This is done solely for the purposes of network governance and community decision-making. No individual personal data is disclosed.

7.4. Legal and Regulatory Requirements (Legal Obligations)

We may disclose personal data in cases where it is expressly required by law, or if such disclosure is necessary for:

complying with court or regulatory decisions;
complying with applicable law;
protecting our rights, the safety of our users, and the interests of the Anglium network;
preventing fraud, abuse, or cybercrime.

In such cases, we limit the scope of disclosure to only the information that is necessary.

7.5. Business Transactions

In the event of a reorganisation, merger, sale of assets, or engagement of strategic partners, we may transfer data to new authorised entities. In doing so, the new parties must adhere to the same data protection standards as Anglium.

7.6. Principle of Transparency

We never sell your personal data to any third parties.
All data transfers are made solely for the purpose of operating the network and in accordance with the law.
You can always contact us for details about who your data may have been transferred to and in what circumstances.

8. Aggregated data

At Anglium Network, we pay special attention to the protection of personal information and separate it from statistical and technical data that does not allow the identification of a specific user.

8.1. What is Aggregated Data

Aggregated data is information that is generated based on collected metrics but presented in an anonymised and generalised form, without reference to a specific person or device. Examples of such data include:

the number of active nodes in a particular country or region;
average bandwidth provided by the network per day/week;
total number of transactions or rewards distributed by the network;
connection statistics in different time zones.

8.2. Use of Aggregated Data

Aggregated data is used for:

optimising network performance (traffic balancing, load forecasting);
improving user experience (identifying regions where additional nodes are needed);
public reports and DAO decisions (ecosystem transparency, joint network management);
analytics for partners (providing general statistics without transferring personal data).

8.3. DAO and Community

Anglium DAO participants can only access aggregated metrics. This allows the community to make informed decisions, such as:

voting on changes in rewards;
determining network scaling strategies;
assessing the overall level of user activity.

No personal data (e-mail, IP, account, or specific financial indicators of an individual user) is disclosed in the DAO.

8.4. Principle of Transparency

We guarantee that aggregated data always remains anonymous and cannot be used to identify individual users. Its main purpose is to develop and improve the Anglium network in a transparent manner.

9. Data Retention

At Anglium Network, we adhere to the principle of minimal storage: all personal data is stored only as long as necessary to ensure the operation of the network, provide services to users, and fulfil legal obligations.

9.1. General Principle

We do not store data longer than necessary to achieve the purposes described in this Privacy Policy.
Once the data is no longer needed, it is deleted or anonymised.
In cases where there are legal or regulatory requirements (e.g., financial records, tax reports), we may store the relevant data for longer, but only for the periods specified by law.

9.2. Account Data

Email, login, Solana wallet, IP address – stored as long as your account is active. If you decide to delete your account, we will delete this data within a reasonable period of time, except for data that we are required to retain in accordance with the law.

9.3. Logs and Technical Data

Log files, diagnostic information, and node metrics are stored for a short period of time (e.g., 30–90 days) solely for security, optimisation, and troubleshooting purposes. After that, they are automatically deleted or stored in an anonymised form.

9.4. Data on the Solana Blockchain

Important: Any transactions, hashes, and metrics stored on the Solana blockchain are immutable and irreversible. This means that once recorded on the blockchain, this data cannot be deleted, corrected, or changed. This limitation is a technical feature of decentralised networks and is beyond the control of Anglium.

9.5. DAO and Aggregated Data

Aggregated statistics may be stored for longer periods, as they do not contain personal identifiers. Such data is used for analytics, research, and strategic decisions by the DAO.

9.6. Principle of Transparency

We ensure that users can always obtain information about the storage periods for their data. If you would like to learn more, you can contact us through our official support channels.

10. Security & Protection

10.1. Technical Protection Measures

Encryption: All data transmitted between the user and Anglium services (website, dashboard, API) is protected using modern cryptographic protocols (TLS 1.3+).
Database Protection: Personal data (accounts, email, logins, IP addresses) is stored in encrypted form using reliable algorithms (AES-256 or equivalent).
Access Control: Only authorised employees or service systems have access to data, and the level of access is limited by the principle of least privilege.
Monitoring: We use intrusion detection systems (IDS/IPS), audit logs, and protection against DDoS attacks.

10.2. Organisational Measures

All our partners and contractors are required to comply with confidentiality policies and enter into non-disclosure agreements (NDAs).
We conduct regular security checks and internal audits to ensure compliance with our standards.
We use the principle of least privilege: no employee has more rights than necessary to perform their duties.

10.3. Security Limitations

We do everything possible to protect your data, but no system in the world can guarantee 100% security. Factors that are not entirely under our control include:

Vulnerabilities in third-party software;
Compromise of users' devices (viruses, malware);
Attacks at the level of Internet service providers or global infrastructure.

10.4. Your Role in Security

Security also depends on user actions. We recommend:

Using strong passwords and not sharing them with third parties;
Using 2FA (two-factor authentication) if available;
Regularly updating the software on your devices;
Avoiding suspicious links or phishing attempts.

11. User Rights under GDPR & CCPA

At Anglium Network, we respect your privacy rights and the processing of your personal data. If you live in the European Union, the United Kingdom, Switzerland (under the GDPR), or California (under the CCPA), you have specific rights regarding your data.

11.1. Right of Access

You have the right to obtain confirmation as to whether we are processing your personal data and to access it. We will provide you with a copy of your data in a convenient format within a reasonable time after your request.

11.2. Right to Rectification

If your data is inaccurate or incomplete, you have the right to request that it be corrected or supplemented. We will promptly update the information in our systems.

11.3. Right to Erasure / "Right to be Forgotten"

You have the right to request the deletion of your personal data in the following cases:

The data is no longer necessary for the purposes for which it was collected;
You have withdrawn your consent to processing;
The data is being processed unlawfully.

Important: Data stored on the Solana blockchain is immutable and irreversible, and cannot be deleted or changed. We can only delete data stored in our centralised systems (account, email, IP address, etc.).

11.4. Right to data portability

You may request the transfer of your personal data in a structured, commonly used, and machine-readable format (e.g., JSON or CSV) for use in another service.

11.5. Right to restrict processing

In some cases, you may request that the processing of your data be temporarily restricted, for example, if you contest its accuracy or lawfulness.

11.6. Right to opt-out of marketing

You may opt out of receiving promotional or marketing communications at any time by clicking the "Unsubscribe" button in the email or by changing the settings in your account

11.7. Right to lodge a complaint

If you believe that your rights have been violated, you have the right to lodge a complaint with a supervisory authority:

For users from the EU – your local data protection authority;
For users from the United Kingdom – the ICO (Information Commissioner's Office);
For users from Switzerland – the FDPIC (Federal Data Protection and Information Commissioner);
For users from California – the California Privacy Protection Agency (CPPA).

11.8. How to exercise your rights

To exercise any of the above rights, you can contact us using the contact details provided in Section 16. Contact Information. We will respond to your request within the time limits provided by law (usually within 30 days).

12. Consent & Withdrawal

At Anglium Network, we respect your right to control your personal data. Consent is the legal basis for the collection and processing of certain types of data, and you have the ability to grant or withdraw it at any time. This section explains how consent is obtained, what it covers, your rights to withdraw it, and the potential consequences for your access to Anglium Services.

12.1. Granting consent

By using Anglium Network services (website, dashboard, NFT access, farming, DAO), you consent to the processing of your personal data within the limits described in this Privacy Policy. This consent includes:

Collection of minimal technical data (IP address, node uptime, traffic volume);
Use of your contact information (email, account, wallet) for communication;
Processing of anonymised statistical data for analytics and DAO purposes.

12.2. Right to withdraw consent

You have the right to withdraw your consent at any time by contacting us via the contact details provided in Section 16. Contact Information. After you withdraw your consent, we will stop collecting and processing your personal data (except for data stored on the Solana blockchain, which is irreversible).

12.3. Consequences of withdrawing consent

It is important to understand that if you withdraw your consent, some Anglium services may become unavailable. In particular:

Farming and the reward system will not function, as we will not collect data about your traffic and nodes;
Participation in the DAO may be limited, as voting rights are based on account and NFT verification;
Access to NFT Node Pass and closed tests may be lost if your identity cannot be verified on the network;
Communication (updates, technical support, announcements) will be impossible, as we will not store your email or other contact details.

12.4. Restrictions

Withdrawal of consent does not affect the lawfulness of data processing that took place prior to withdrawal.

13. Links to third-party resources

Anglium Network services (website, dashboard, NFT access, DAO) may contain links to third-party websites, applications, or services that are not controlled or operated by us. These third-party resources may include wallets, exchanges, authentication services, or external analytics platforms.

13.1. Policy independence

Clicking on any link to a third-party service means that the privacy policies and terms of use of those services apply to you. We do not control their actions, data collection, or processing practices.

13.2. Responsibility

Anglium is not responsible for how third-party services collect, store, or use your personal data.
We recommend that users carefully review the privacy policies of each third-party service before using it.
If you provide your data to third-party resources (e.g., email, wallet, or account information), this is governed solely by their rules, not Anglium's policy.

13.3. Examples of third-party integrations

Using the Phantom or Solflare wallet to verify NFT Node Pass.
Integration with Solana blockchain explorers to view transactions.
Using third-party services to connect to DAO voting.

14. Changes to this Privacy Policy

Anglium Network reserves the right to update or modify this Privacy Policy periodically to reflect changes in our services, legal requirements, security measures, or third-party integrations.

14.1. Reasons for updates

Updates to this Policy may occur due to:

Changes in our services (website, dashboard, DAO, NFT access, farming system).
New legislative or regulatory requirements.
Introduction of additional security, analytics, or functional features.
Changes in partnerships or integrations with third parties.

14.2. Publication of updates

Each updated version of the Policy will be made available on our official website (angliumnetwork.com) in the relevant section.
The date of the last update ("Last Modified") will be clearly indicated at the top of the document.

14.3. User notifications

In the event of significant changes, we may additionally notify you via:

Email (if you have provided your address).
Dashboard notifications.
Official communication channels (Twitter/X, Discord, GitBook).

Your continued use of the services after the updated Policy is published constitutes acceptance of the new terms.

14.4. Your actions

We recommend that users periodically check this page to stay informed of updates.
If you do not agree with the new version, you may stop using Anglium services and contact us to delete your data (to the extent technically possible).

15. Contact information

If you have any questions, comments, or requests regarding this Privacy Policy or the processing of your personal data within the Anglium Network, you can contact us through the following channels:

Email: [email protected]
Telegram: @AngliumNetWork
DAO address for inquiries: Will be added after the full launch of Anglium DAO, allowing users to directly submit proposals, requests, or complaints in a decentralized format.

15.1. Format of requests

When sending a request, please include:

Your name or nickname in the system.
Contact details for a reply.
A description of your question or the right you wish to exercise (e.g., access to data, account deletion, marketing opt-out, etc.).

We will respond to your request within a reasonable time, but no later than required by applicable law (usually within 30 days).

16. Additional Information for Users in the EU, UK, and California

This section applies to users residing in the European Economic Area (EEA), the United Kingdom, or the State of California (USA). It contains additional explanations in accordance with the requirements of the GDPR (General Data Protection Regulation) and the CCPA (California Consumer Privacy Act).

16.1. Additional rights of EU/UK users (GDPR)

In addition to the basic rights described in Section 11 (User Rights), users from the EU and the UK have the following rights:

Right to restriction of processing: You may request that the use of your data be suspended in certain cases.
Right to object: You may object to the processing of your data based on legitimate interests or for marketing purposes.
Right to complain to a regulator: You can complain to your local data protection authority (e.g., the ICO in the UK).

We only process EU/UK user data when there is a legitimate basis for doing so:

Performance of a contract (e.g., creating an account and accessing the dashboard).
Compliance with legal obligations.
Our legitimate interest (e.g., improving network performance, combating fraud).
Your explicit consent.

16.2. Additional rights for California users (CCPA)

Users in California have the following rights:

Right to Know: You may obtain information about the categories and specific pieces of data we collect and use.
Right to Delete: You may request the deletion of your personal data, except for data that is necessary for legitimate purposes or that is technically impossible to delete from the Solana blockchain.
Right to Opt-Out of Sale: Anglium does not sell users' personal data or monetize it.
Right to Non-Discrimination: We do not restrict access to services or reduce the quality of service if you exercise your rights.

16.3. Transfer of data outside the EU/UK

As Anglium Network is a decentralized project, data may be processed and stored on servers located outside the European Economic Area or the United Kingdom. In such cases, we apply the following protection mechanisms:

Standard Contractual Clauses (SCCs) approved by the European Commission.
Use of service providers certified to international security standards.
Storage of a minimum amount of personal data outside the EU/UK.