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Privacy Policy — HolderEasy
Summary. HolderEasy only reads public blockchain data. We never ask for your private key. We never access your funds. This policy explains what personal data we collect when you use our platform, how we use it, and what rights you have under the GDPR.
01

Data Controller

The data controller responsible for processing your personal data is:

Studio Lafabrique
Operating under the brand HolderEasy
France
Email: contact@holdereasy.com

As a data controller established in France, Studio Lafabrique complies with the General Data Protection Regulation (EU) 2016/679 (GDPR) and the French Data Protection Act (Loi Informatique et Libertés).

02

Data We Collect

We collect only the data necessary to provide and improve HolderEasy. This includes:

Data Why we collect it Legal basis
Email address Account creation, authentication, and service communications Contract performance
Public wallet addresses To retrieve and display blockchain data in response to your queries Contract performance
Chat history To display your past conversations and power the personalized dashboard Contract performance
Usage data To understand how the platform is used and improve our service Legitimate interest
Technical data (IP address, browser, device) Security, fraud prevention, and service reliability Legitimate interest

We do not collect private keys, seed phrases, or any credentials that could grant access to your crypto assets.

03

How We Use Your Data

We use your personal data exclusively for the following purposes:

To provide the service — processing your questions, retrieving blockchain data, displaying your portfolio analysis, and maintaining your dashboard.

To manage your account — authentication, subscription management, and service-related communications (account updates, billing, security alerts).

To improve HolderEasy — analyzing aggregated, anonymized usage patterns to identify areas of improvement and develop new features.

To ensure security — detecting and preventing fraud, abuse, and unauthorized access.

We do not use your data for advertising purposes, and we do not sell your data to any third party.

04

Blockchain Data

HolderEasy reads only publicly available blockchain data. When you enter a wallet address, we query on-chain information (balances, transactions, DeFi positions) that is already publicly accessible to anyone via block explorers.

This data is not personal data in the traditional sense — it is public by the nature of the blockchain. However, a wallet address can potentially be linked to an individual. We treat it with the same level of care as personal data and use it solely to provide you with the service.

We do not store raw blockchain data beyond what is necessary to display your analysis and power your dashboard. We do not share individual wallet data with third parties.

05

Analytics & Cookies

HolderEasy uses analytics tools (such as Google Analytics) to understand how users interact with our platform. These tools may collect information such as pages visited, time spent on the platform, device type, and geographic region at a country level.

Cookies are small text files stored on your device. We use the following types:

Essential cookies — required for the platform to function (authentication, session management). These cannot be disabled.

Analytics cookies — used to understand usage patterns and improve the service. These are only set with your consent.

You can manage your cookie preferences at any time via your browser settings or our cookie consent banner. Withdrawing consent for analytics cookies will not affect your ability to use HolderEasy.

For more information on how Google Analytics processes data, please refer to Google's Privacy Policy.

06

Data Sharing

We do not sell, rent, or trade your personal data. We share data only with the following categories of trusted service providers, strictly for the purpose of operating HolderEasy:

Infrastructure & hosting — servers and cloud infrastructure used to run the platform.

Authentication — third-party services used to manage user accounts and secure logins.

Blockchain data providers — APIs used to retrieve on-chain data in response to your queries.

Analytics — tools used to understand platform usage (see Section 5).

Payment processing — secure payment providers used to manage Premium subscriptions. We do not store payment card information.

All service providers are contractually bound to process your data only on our behalf and in accordance with applicable data protection law.

We may also disclose data if required by applicable law, court order, or regulatory authority.

07

Data Retention

We retain your personal data for as long as your account is active or as necessary to provide the service. Specifically:

Account data (email, preferences) — retained for the duration of your account, plus up to 3 years after account deletion for legal and compliance purposes.

Chat history and dashboard data — retained for the duration of your account. You can delete individual conversations at any time within the platform.

Usage and technical data — retained for up to 13 months in line with CNIL guidelines for analytics data.

When you delete your account, we delete or anonymize your personal data within 30 days, except where retention is required by law.

08

Your Rights Under the GDPR

As a resident of the European Union, you have the following rights regarding your personal data:

Right of access
Request a copy of the personal data we hold about you.
Right to rectification
Request correction of inaccurate or incomplete data.
Right to erasure
Request deletion of your personal data ("right to be forgotten").
Right to restriction
Request that we limit the processing of your data.
Right to portability
Receive your data in a structured, machine-readable format.
Right to object
Object to processing based on legitimate interests.

To exercise any of these rights, contact us at contact@holdereasy.com. We will respond within 30 days. You also have the right to lodge a complaint with the French data protection authority, the CNIL (www.cnil.fr).

09

International Data Transfers

Some of our service providers may process data outside of the European Economic Area (EEA). When this occurs, we ensure that appropriate safeguards are in place — such as Standard Contractual Clauses (SCCs) approved by the European Commission — to protect your data in accordance with GDPR requirements.

10

Minors

HolderEasy is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us at contact@holdereasy.com and we will delete it promptly.

11

Policy Changes

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. When we make material changes, we will notify you via email or a prominent notice on the platform, and update the "Last updated" date at the top of this page.

Your continued use of HolderEasy after any changes constitutes your acceptance of the updated policy.

12

Contact

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data, please contact us:

Studio Lafabrique — HolderEasy
Email: contact@holdereasy.com
Website: holdereasy.com

We are committed to resolving any privacy concerns promptly and transparently.

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