Privacy Policy

1. Introduction

AdPal Lab (“Company,” “we,” “us,” or “our”) operates the AdPal mobile application (the “App”), a permissionless application that enables users to cast images to e-ink phone case displays and, optionally, participate in advertising reward programs. This Privacy Policy describes our practices regarding the collection, use, disclosure, and protection of information in connection with your use of the App.

By accessing or using the App, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the App.

2. Permissionless Access

The App is designed to operate on a permissionless basis. Core functionality, including the casting of images to your e-ink display via NFC, does not require account registration, submission of personal information, or connection to our backend services. Images you cast to your e-ink display are processed locally on your device and are not transmitted to our servers.

Optional features, including participation in advertising reward programs, may require additional information as described in this Privacy Policy.

3. Information We Collect

3.1 Information Collected During Permissionless Use

When you use the App without participating in advertising programs, we collect minimal information necessary for App functionality.

Device and Technical Information. We may collect device type, operating system version, unique device identifiers, and NFC interaction logs solely for the purpose of ensuring proper functionality of the e-ink display casting feature.

Usage Analytics. We may collect anonymized usage statistics to improve App performance and user experience. Such data is aggregated and cannot be used to identify individual users.

3.2 Information Collected for Advertising Program Participation

If you elect to participate in our advertising reward programs, additional information may be collected.

Wallet Information. When you connect an external cryptocurrency wallet via the WalletConnect protocol, we receive your public wallet address. We do not collect, access, or store private keys, seed phrases, or any other credentials that control your wallet. Wallet custody and security remain solely with you and your chosen external wallet application.

Ad Interaction Data. We collect information regarding your interactions with advertisements, including impressions, clicks, task selections, and task completion status. For smart contract-based advertising, this includes records of image casting duration and compliance with campaign requirements.

Message Protocol Records. Our internal messaging protocol generates receipts in connection with advertising task completion and reward settlement. These records are retained to facilitate on-chain arbitration in the event of reward disputes.

Fiat Reward Information. If you elect to receive advertising rewards in fiat currency rather than cryptocurrency or points, you will be required to provide additional personal information, which may include your email address, phone number, name, and payment account details. This information is collected solely for the purpose of processing fiat payments and complying with applicable financial regulations.

3.3 Information We Do Not Collect

Locally Processed Images. Photos and images you cast to your e-ink display are processed entirely on your device. We do not upload, access, store, or transmit these images to any server or cloud infrastructure.

Private Keys and Wallet Credentials. We do not collect or have access to your cryptocurrency wallet private keys, seed phrases, passwords, or other security credentials. Your wallet is managed exclusively by your chosen external wallet application.

4. How We Use Your Information

We use the information we collect for the following purposes.

Providing Core Services. To enable the App’s e-ink display casting functionality and ensure proper technical operation.

Facilitating Advertising Programs. To deliver advertisements from third-party advertising partners and smart contract-based campaigns, track task completion, verify compliance with campaign requirements, and coordinate reward distribution.

Reward Settlement. To process and facilitate the distribution of advertising rewards, whether in cryptocurrency, points, or fiat currency, and to maintain records necessary for on-chain arbitration.

Compliance and Verification. To conduct compliance reviews of advertising content and, where applicable, to perform Know Your Business verification on advertisers in jurisdictions that require such procedures.

Service Improvement. To analyze usage patterns, diagnose technical issues, and improve App functionality and user experience.

Legal Compliance. To comply with applicable laws, regulations, and legal processes.

5. Advertising Programs

5.1 Third-Party Advertising Network

The App integrates with third-party advertising providers to deliver link-based advertisements. Advertisements are routed through our backend services. When you choose to interact with an advertisement, we share relevant interaction data with the applicable advertising partner to facilitate reward attribution. You retain full control over which advertisements, if any, you choose to engage with.

5.2 Smart Contract-Based Advertising

The App enables participation in decentralized advertising campaigns published on public blockchain networks. Advertisers publish campaign terms, creative assets, and reward allocations to smart contracts. When you participate in such campaigns, you agree to cast advertiser-provided images to your e-ink display for specified durations.

Our backend services review task completion for compliance with campaign requirements. Upon successful verification, rewards are settled through the applicable smart contract. We charge a service fee, deducted from advertiser allocations, for providing this advertising platform.

5.3 Advertiser Verification

In certain jurisdictions, applicable law requires us to conduct Know Your Business verification on advertisers before permitting them to publish advertisements. This verification process applies to advertisers and does not require submission of personal information by end users.

5.4 On-Chain Arbitration

In the event that you complete an advertising task and the applicable reward is not distributed, you may utilize message protocol receipts generated by the App to initiate automated arbitration through the applicable smart contract. This arbitration mechanism operates on-chain and enables you to claim earned rewards directly from the smart contract.

6. Information Sharing and Disclosure

We may share your information in the following circumstances.

Third-Party Advertising Partners. We share ad interaction data with our advertising partners as necessary to facilitate reward attribution and payment.

Blockchain Networks. Participation in smart contract-based advertising results in transactions recorded on public blockchain networks. Wallet addresses, transaction data, and reward claims are publicly visible and immutable once recorded on-chain. We have no ability to delete or modify blockchain data.

Service Providers. We engage third-party service providers to assist in operating the App, processing payments, and providing other services. Such providers are contractually obligated to use your information solely for the purposes of providing services to us and to maintain appropriate confidentiality and security measures.

Legal Requirements. We may disclose your information when required to do so by law, regulation, legal process, or governmental request, or when we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers. In the event of a merger, acquisition, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of such transaction. We will notify you of any such change by posting notice within the App.

We do not sell your personal information to third parties.

7. Blockchain Data and Immutability

Certain App features interact with public blockchain networks. You acknowledge and understand that blockchain technology operates on a decentralized and immutable basis, and that data recorded on a blockchain cannot be modified or deleted. Specifically, your public wallet address and all transactions associated with it, smart contract interactions including advertising task completions and reward claims, and arbitration proceedings and message protocol receipts submitted on-chain are permanently and publicly recorded.

We have no control over and bear no responsibility for blockchain data once it is recorded on a distributed ledger.

8. Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

Technical and Usage Data. Retained for the period necessary to ensure App functionality and improve services.

Ad Interaction and Task Completion Data. Retained for the duration necessary to complete reward settlement and for a reasonable period thereafter to address potential disputes.

Message Protocol Receipts. Retained for the period necessary to facilitate potential on-chain arbitration.

Fiat Payment Information. Retained as required by applicable financial regulations and tax laws.

Blockchain Data. Data recorded on public blockchains is immutable and cannot be deleted.

9. Data Security

We implement reasonable technical and organizational measures designed to protect your information against unauthorized access, alteration, disclosure, or destruction. These measures include encryption, access controls, and secure development practices.

Notwithstanding the foregoing, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the security of your external wallet application and any credentials associated therewith.

10. International Data Transfers

Your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have data protection laws that differ from the laws of your jurisdiction. By using the App, you consent to such transfers. We take reasonable steps to ensure that your information receives an adequate level of protection in the jurisdictions in which we process it.

11. Your Rights

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including the right to access the personal information we hold about you, the right to request correction of inaccurate information, the right to request deletion of your information subject to legal retention requirements and blockchain immutability, the right to object to or restrict certain processing activities, the right to data portability, and the right to withdraw consent where processing is based on consent.

To exercise any of these rights, please contact us using the information provided in Section 14 below. We will respond to your request in accordance with applicable law. Please note that we cannot modify or delete information recorded on public blockchains.

12. Children’s Privacy

The App is not directed to individuals under the age of eighteen (18) or the age of majority in your jurisdiction, whichever is higher. 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 promptly. If you believe we have collected information from a child, please contact us immediately.

13. Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes, we will provide notice by posting the updated Privacy Policy within the App and updating the “Last Updated” date above. Your continued use of the App following the posting of changes constitutes your acceptance of such changes. We encourage you to review this Privacy Policy periodically.

14. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

AdPal Lab, legal@adpal.xyz.

15. Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of Cayman Islands, without regard to its conflict of law provisions.

16. Severability

If any provision of this Privacy Policy is held to be invalid or unenforceable, such provision shall be struck and the remaining provisions shall continue in full force and effect.