1. Purpose and status of this Notice

This Notice explains how and what information about you and your transactions becomes publicly and permanently visible on a public blockchain when you use the Bleap service. This Notice supplements, and must be read together with, the Bleap Privacy Policy and the Bleap Terms of Service. 

2. The nature of self custody and transacting on blockchain

Your Bleap wallet is self-custodial. The cryptographic signature required to authorise a transaction is generated and managed or held by the user using integrated multi-party computation, such that no other single party (including Bleap) ever holds a complete private key and no transfer of your assets can be made without your authorisation. A transfer you authorise is final. An address you disclose cannot be withdrawn from the public blockchain record. These are structural characteristics inherent to the technology, not limitations of our service or of our willingness to assist you.

3.What is published to a public blockchain

When you transact, the following categories of information are written to the Blockchain and are publicly accessible permanently:

1. your wallet address;
2. the wallet address of every counterparty with whom you transact;
3. the amount, the token type and the direction of each transfer;
4. the date and time of each transfer, to the second;
5. the complete transaction history of your wallet address, from its creation onwards;
6. any smart contract with which your wallet interacts, and the parameters of that interaction;
7. fees paid and associated technical metadata, including transaction identifiers, event logs and receipts.

This information is replicated across every node participating in the relevant Blockchain network worldwide, including nodes located outside the European Economic Area. Neither Bleap nor any other party is able to recall it, restrict it geographically, or prevent access to them.

The European Data Protection Board has confirmed that wallet addresses and associated transaction data constitute personal data within the meaning of Article 4(1) GDPR where they can be associated with an identified or identifiable natural person. We proceed on that basis, and so should you.

4.Who can see this information, and how you may be identified

Blockchain data is pseudonymous, not anonymous. Your wallet address does not, by itself, display your name. It nonetheless functions as a persistent identifier to which your entire transaction history is attached.

Your wallet address and its history may be viewed by, among others:

1. any person to whom you have disclosed your address, including for the purpose of receiving a payment - that person can thereafter monitor your balance and every transaction you make, indefinitely, without your knowledge and without any further action by you;
2. any person with whom you have transacted on blockchain, whether or not you disclosed your address to them, since your address is recorded on their side of the transaction;

5.What Bleap does not publish

Bleap does not disclose and will not disclose to the public:

1. your name, date of birth, nationality or address;
2. identity documents, biometric data or the results of identity verification;
3. your email address, telephone number or account credentials;
4. your bank account details or IBAN;
5. any other identity information you provide to us.

That information is processed off-chain in systems under our control, and is disclosed only as set out in the Privacy Policy. The decision to keep identity data off-chain is deliberate and is intended to ensure that your rights under Articles 15 to 22 GDPR remain capable of being exercised in respect of the data we hold.

6. Permanence, and the limits of erasure and rectification

Records written to a public Blockchain are immutable by design. They cannot be deleted, amended, corrected or restricted by Bleap, by you, or by any other person, including in response to a request made under Articles 16, 17 or 18 GDPR.

In respect of personal data held by Bleap off-chain, your rights of access, rectification, erasure, restriction, portability and objection apply in full and will be honoured in accordance with the Privacy Policy;

In respect of data recorded on-chain, we cannot give effect to erasure or change because we have no ability to alter the ledger. Where the law permits and it is technically meaningful, we will act on the off-chain data that enables an on-chain record to be attributed to you, so as to reduce the prospect of future identification;

For the avoidance of doubt: closing your Bleap account does not remove any record from a Blockchain. Data written before closure remains public and permanent.

7.Bleap's role under data protection law

Bleap is the controller, within the meaning of Article 4(7) GDPR, of the personal data it processes off-chain in order to provide the service, including identity verification data, account data, transaction records held in our systems, and support correspondence.

Bleap does not operate the Blockchains on which your wallet exists, does not determine the purposes and means of their operation, and does not control the nodes that replicate and store the ledger. Publication to the ledger results from a transaction you authorise.

Where you use your wallet exclusively for your own personal purposes, your own processing of personal data may fall outside the scope of the GDPR by reason of Article 2(2)(c). This does not affect Bleap’s obligations to you.

We have assessed the data protection implications of the service, including by way of a data protection impact assessment under Article 35 GDPR where required, and we apply data protection by design and by default under Article 25 GDPR (in particular by keeping identity data off-chain).

8.Steps you can take

We cannot make Blockchain data private or alter its contents.  You can  limit your exposure:

1. treat your wallet address as public information, and disclose it only where necessary;
2. do not publish your address on social media, forums, websites or public profiles;
3. consider whether a transaction, once linked to you, would reveal more than you intend (including your balance, your income pattern and your counterparties);
4. where your circumstances warrant it, keep activity you wish to keep separate at separate addresses, to the extent the service supports this;
5. remember that a counterparty may retain and share your address and transaction details independently of you and of us.

9.Changes to this Notice

We may amend this Notice to reflect changes to the service, to the Blockchains we support, or to applicable law. We will publish the amended version on our website and, where the change is material, notify you in advance through the Bleap application or by email. The version and effective date appear at the head of this Notice.