Privacy Policy

1. Purpose of This Privacy Policy

1.1 This Policy describes the types of personal information we collect, how we use it, with whom we share it, and the measures we take to protect it. By using the Site or engaging with our Services, you agree to the collection, use, and sharing of your personal information as described in this Policy. Lightyear Technologies Limited is registered in England and Wales (Company Number: 15225286) and serves as the data controller for personal information collected through our Services.

1.2 This Policy applies only to information collected by Lightyear through the Site and Services. It does not apply to information collected by third parties, including through any third-party websites, applications, services, or blockchain networks that may be linked to or integrated with our Services.

2. Information We Collect

2.1 Information You Provide

We may collect information that you provide directly to us, including:

• Contact information: name, email address, phone number, organization name, job title
• Project information: details about NFT projects, cultural programs, partnership proposals, and technical requirements
• Communications: information you provide when you contact us, submit inquiries, or request information about our Services
• Payment information: billing details and payment method information (processed by third-party payment processors)
• Professional information: portfolio materials, creative works, organizational background, and partnership histories

2.2 NFT and Blockchain Information

In connection with providing NFT infrastructure and services, we may collect:

• Wallet addresses associated with your NFT projects or activities
• Public blockchain data related to NFT deployments, transactions, and smart contracts
• Smart contract specifications and deployment parameters
• Digital asset metadata and content information
• Integration credentials for NFT marketplaces, blockchain networks, and related platforms

We do not have access to or store your private keys or seed phrases. You retain full custody and control of any digital assets or NFTs.

2.3 Automatically Collected Information

When you access or use the Site, we automatically collect:

• Device information: IP address, browser type, operating system, device identifiers
• Usage information: pages viewed, content accessed, time spent on the Site, clickstream data
• Log data: access times, error logs, performance data
• Cookie and tracking technology data: information collected through cookies and similar technologies

2.4 MCP Gateway-Specific Information

When you use the Lightyear MCP gateway (mcp.lightyear.build) we additionally collect:

• Sign-In With Ethereum (SIWE) message and signature, used solely to authenticate your wallet to the dashboard and to track free-credit accrual per wallet
• Tool call metadata: tool name, request timestamp, latency, success/failure code, the wallet address that made the call, an x402 receipt reference where applicable. Tool inputs and outputs are NOT persisted by the gateway
• Billing records: USDC payment receipts (transaction hash, network, payer address, settlement timestamp) generated via the x402 facilitator
• Operational backups: a daily WORM (write-once-read-many) export of the billing-receipts table to encrypted Google Cloud Storage for audit and reconciliation

Data processors used by the MCP gateway include: Vercel (hosting + edge runtime), Google Cloud Platform (Cloud SQL Postgres for billing records; Cloud Storage for WORM exports), Coinbase Developer Platform (x402 facilitator on mainnet), the public x402.org facilitator (testnet only), Alchemy (Base RPC + on-chain CryptoPunks reads), Reown / WalletConnect (wallet-connect protocol), and our upstream data partner Cultural Data Indexer (CDI) for indexed NFT analytics. Some of these processors are located outside the UK; transfers occur under the relevant Standard Contractual Clauses or equivalent adequacy mechanisms.

3. How We Use Your Information

We use the information we collect to:

• Provide, maintain, and improve our Services
• Develop and deploy NFT infrastructure, smart contracts, and digital experiences
• Manage client relationships and partnerships
• Communicate with you about projects, proposals, and Services
• Process transactions and send related information
• Respond to inquiries, questions, and support requests
• Monitor and analyze usage patterns to improve our Site and Services
• Detect, prevent, and address technical issues, fraud, and security vulnerabilities
• Comply with legal obligations and enforce our Terms of Use
• Send updates about our Services, cultural programs, and industry developments (with your consent where required)
• Showcase completed projects in our portfolio and case studies (with client permission)

Any use of project information for portfolio displays, case studies, or promotional purposes will be subject to applicable contractual agreements and client permissions.

4. How We Share Your Information

We may share your information in the following circumstances:

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf, including cloud hosting, blockchain infrastructure providers, smart contract auditors, payment processors, and technical support services. These providers are contractually obligated to protect your information and use it only for the purposes we specify.

4.2 Blockchain Networks and NFT Platforms

When deploying NFT infrastructure or smart contracts, certain information (such as wallet addresses, contract addresses, and transaction data) becomes publicly visible on blockchain networks. This is inherent to blockchain technology and is not within our control.

4.3 Partner Organizations

With your permission, we may share project information with cultural institutions, artists, platforms, and other partners involved in collaborative projects.

4.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction.

4.5 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by government authorities, including to meet national security or law enforcement requirements.

4.6 Protection of Rights

We may disclose information to protect our rights, property, or safety, or the rights, property, or safety of our clients, partners, or others, including to enforce our Terms of Use.

4.7 With Your Consent

We may share information with third parties when you give us consent to do so, such as for portfolio showcases, case studies, or promotional materials.

5. Data Security

5.1 We implement reasonable administrative, technical, and physical security measures to protect your personal information from unauthorized access, use, disclosure, alteration, or destruction.

5.2 However, no security system is impenetrable, and we cannot guarantee the absolute security of your information. Blockchain networks and smart contracts may have inherent vulnerabilities that are beyond our control.

5.3 You are responsible for maintaining the security of any credentials, private keys, or sensitive information related to your NFT projects or digital assets.

6. Data Retention

6.1 We retain your personal information for as long as necessary to provide the Services, fulfill project commitments, comply with legal obligations, resolve disputes, and enforce our agreements.

6.2 Project-related information may be retained for archival and portfolio purposes, subject to any confidentiality agreements or client preferences.

6.3 Information published to blockchain networks is permanent and immutable. We cannot delete or modify blockchain data after it has been deployed.

7. Your Rights and Choices

Depending on your location, you may have certain rights regarding your personal information:

• Access: You may request access to your personal information
• Correction: You may request correction of inaccurate personal information
• Deletion: You may request deletion of your personal information (subject to legal and contractual obligations)
• Portability: You may request a copy of your personal information in a portable format
• Restriction: You may request restriction of processing of your personal information
• Objection: You may object to processing of your personal information

To exercise these rights, please contact us at hello@lightyear.build. We will respond to your request within a reasonable timeframe as required by applicable law. Note that we cannot delete or modify information that has been published to blockchain networks.

7.1A European Economic Area and United Kingdom Residents

If you are located in the United Kingdom or the European Economic Area, the following additional provisions apply:

Legal Basis for Processing. Lightyear processes your personal information based on one or more of the following lawful bases under the UK General Data Protection Regulation (UK GDPR) and EU GDPR: (a) performance of a contract with you; (b) compliance with legal obligations; (c) our legitimate interests in operating, securing, and improving our Services; and (d) your consent, where required by law.

Your Rights. You have the right to: (i) withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing prior to withdrawal; (ii) request access to, correction of, or deletion of your personal data; (iii) restrict or object to processing; (iv) data portability; and (v) lodge a complaint with the Information Commissioner's Office (ICO) in the UK (ico.org.uk) or with your local supervisory authority in the EEA if you believe our processing violates applicable data protection laws.

Data Transfers. Where we transfer personal data outside the UK or EEA, we implement appropriate safeguards such as Standard Contractual Clauses or ensure the recipient is in a country with an adequacy decision.

8. Cookies and Tracking Technologies

8.1 We use cookies and similar tracking technologies to collect information about your use of the Site. Cookies are small data files stored on your device that help us improve the Site and personalize your experience.

8.2 Types of cookies we use:

• Essential cookies: Required for the Site to function properly
• Analytics cookies: Help us understand how users interact with the Site
• Functional cookies: Remember your preferences and settings

8.3 You can control cookies through your browser settings. However, disabling certain cookies may affect the functionality of the Site.

9. International Data Transfers

9.1 As a UK-based company, Lightyear may transfer your personal information to countries outside the United Kingdom and the European Economic Area, including to the United States and other jurisdictions where our service providers, partners, or infrastructure are located. These countries may have data protection laws that differ from UK and EU laws.

9.2 When we transfer personal information internationally, we implement appropriate safeguards to protect your information in accordance with UK GDPR and EU GDPR requirements. These safeguards may include Standard Contractual Clauses approved by the UK Information Commissioner's Office and the European Commission, ensuring the recipient is located in a country with an adequacy decision, or other legally approved transfer mechanisms.

9.3 You may request information about the safeguards we have implemented for international data transfers by contacting us at hello@lightyear.build.

10. Children's Privacy

The Site and Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child, we will take steps to delete such information.

11. Third-Party Websites and Services

The Site may contain links to third-party websites or integrate with third-party services, including NFT marketplaces, blockchain explorers, and cultural platforms. This Policy does not apply to those third parties. We are not responsible for the privacy practices of third parties, and we encourage you to review their privacy policies.

12. Changes to This Privacy Policy

We may update this Policy from time to time. We will notify you of material changes by posting the updated Policy on the Site or by email. Your continued use of the Site or Services after such changes constitutes your acceptance of the updated Policy.

13. Other Rights

Lightyear Technologies Limited is registered with the UK Information Commissioner's Office (ICO). Our ICO registration number is ZB395720.

For UK data protection inquiries or to exercise your UK GDPR rights, please contact us at hello@lightyear.build.

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), including the right to know what personal information we collect, the right to delete your personal information, and the right to opt-out of the sale of your personal information. We do not sell your personal information. To exercise your rights, please contact us at hello@lightyear.build.

14. Contact Information

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Email: hello@lightyear.build

Data Protection Inquiries: hello@lightyear.build

Postal Address:

Lightyear Technologies Limited
c/o Hivemind Capital Partners Llp
1 King William Street
London, EC4N 7AF
England

UK ICO Registration: ZB395720

For UK GDPR-related matters, you may also contact the Information Commissioner's Office at ico.org.uk.