Privacy Policy

Surge Privacy Policy

Last Updated: [2025-8-8]


1. Introduction

Surge ("we", "our", or "Platform") respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect your information when you use our blockchain-based services, including website, APIs, and mobile applications (collectively, "Services"). By accessing Surge, you consent to the practices described herein.


2. Information We Collect

a) Directly Provided Data:

  • Account Information: Email address, username, password (hashed).

  • Verification Data: Government ID (if required for KYC/AML).

  • Communications: Support tickets, feedback, survey responses.

b) Automatically Collected Data:

  • Technical Data: IP address, device ID, browser type, operating system.

  • Usage Data: Pages visited, session duration, transaction history, wallet interactions.

  • Blockchain Data: Public wallet addresses, transaction hashes, token balances (derived from public chains).

c) Third-Party Sources:

  • Wallet Providers: Public wallet address when you connect (e.g., MetaMask).

  • Analytics Tools: Google Analytics, Mixpanel (anonymized usage patterns).


3. How We Use Your Information

Purpose
Legal Basis

Provide & maintain Services

Contractual necessity

Process transactions

User consent + Legal compliance

Security & fraud prevention

Legitimate interest

Compliance (KYC/AML, taxes)

Legal obligation

Improve Services & user experience

Legitimate interest

Marketing communications

User consent (opt-in)


4. Data Sharing & Disclosure

We never sell your personal data. Limited sharing occurs only with:

  • Regulators/Law Enforcement: To comply with legal requests.

  • Service Providers: Cloud hosting (AWS), KYC vendors, auditors (bound by strict confidentiality).

  • Affiliates: Within our corporate group for operational needs.

  • Public Blockchains: Your wallet transactions are inherently public and immutable.


5. Data Security

  • Encryption: TLS/SSL for data transmission; AES-256 for storage.

  • Access Controls: Strict role-based permissions.

  • Blockchain Risks: We cannot secure assets in your self-custodied wallet.


6. User Rights

Depending on your jurisdiction, you may:

  • Access/export your personal data.

  • Correct inaccuracies.

  • Delete account data (subject to legal retention).

  • Opt out of marketing emails.Submit requests via: [[email protected]]


Services may link to external sites (e.g., DEXs, explorers). We are not responsible for their privacy practices.


8. International Data Transfers

Data may be processed globally. We use EU Standard Contractual Clauses (SCCs) for cross-border transfers.


9. Policy Updates

We will notify users of material changes via email or in-app alerts. Continued use = acceptance.


10. Contact Us

For privacy inquiries or complaints:

Email: [[email protected]]


Key Compliance Notes for Surge:

  1. Blockchain Transparency:

    • Explicitly state that wallet addresses/txns are public and irreversible.

  2. Self-Custody Disclaimer:

    • "Surge does not custody user assets. You alone control private keys and bear security responsibility."

  3. No Financial Data:

    • We do not collect bank accounts or credit cards (crypto-native platform).

  4. Cookie Policy:

    • Add a separate cookie banner linking to detailed preferences.

Last updated