Privacy Policy

Jordan Pobienski, operator of the TRITO platform ("we", "us", "our"), is committed to protecting your personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use the TRITO Token platform at tritotoken.eu.

This policy is designed to comply with the General Data Protection Regulation (GDPR) and applicable Bulgarian data protection laws.

3.1 Account Data (Required)

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  Email address

  Account creation and authentication

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  Display name / nickname

  Community identification

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  Account creation date

  Eligibility verification

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  Email verification status

  Security and eligibility

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  Password hash

  Authentication (never stored in plain text)

3.2 Blockchain Data (Optional — provided by user)

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  Ethereum wallet address

  Token gifts, staking, and reward distribution

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  Cryptographic wallet signature

  Proof of wallet ownership (no private keys collected)

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  On-chain activity reference

  CeR rank calculation and airdrop eligibility

3.3 Activity Data (Automatic)

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  Airdrop points and activity

  Airdrop reward calculation

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  Referral records

  Referral reward distribution

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  Login timestamps

  Security monitoring

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  Browser type and device info

  Platform optimization via Firebase Analytics (anonymized)

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  IP address and request logs

  Security, fraud prevention (processed by Vercel as hosting provider)

• ✓Account creation and authentication
• ✓Verifying eligibility for airdrop and registration gift
• ✓Calculating and distributing staking rewards
• ✓Computing CeR ranks and airdrop points
• ✓Processing referral rewards
• ✓Sending essential account notifications (security alerts, gift claims)
• ✓Preventing fraud, sybil attacks, and platform abuse
• ✓Improving platform performance and user experience
• ✓We do not send marketing emails without your explicit consent

Your account data is stored using Google Firebase (Firestore and Authentication). Firebase provides contractual and technical measures intended to support GDPR compliance.

Personal data is retained while your account remains active. Upon account deletion, personal data is removed from our systems. However, some records may be retained for a limited period thereafter where necessary for:

• •Security and fraud prevention
• •Dispute resolution
• •Legal compliance obligations
• •Protection of legitimate interests

Please note that wallet addresses, transactions, and other data already recorded on public blockchains cannot be deleted as blockchain data is immutable by design.

We do NOT sell your personal data. We share data only with:

• ▸Google Firebase — authentication and database provider (US company, EU data processing agreement in place)
• ▸Vercel — hosting provider, may process technical information such as IP addresses and request logs (US company, Standard Contractual Clauses apply)
• ▸Ethereum blockchain — wallet addresses and transaction data are public by blockchain design
• ▸Legal authorities — only when required by applicable law

Some service providers may process data outside the European Economic Area. Where this occurs, appropriate safeguards such as Standard Contractual Clauses (SCCs) are used.

As a data subject you have the following rights:

To exercise any of these rights, contact us at mr.pobienski@gmail.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Commission for Personal Data Protection (CPDP), Republic of Bulgaria, at cpdp.bg.

Where processing is based on your consent (such as marketing communications), you may withdraw consent at any time by contacting us at mr.pobienski@gmail.com or through your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

Certain rewards, rankings, eligibility determinations, and anti-abuse measures are processed automatically based on platform activity and blockchain data. This includes CeR rank calculation, airdrop point scoring, and referral qualification checks.

No decisions producing legal or similarly significant effects are made solely by automated means without the possibility of human review.

We use essential cookies for authentication and optional analytics cookies to improve the platform. See our Cookie Policy for full details. We use Firebase Analytics to understand platform usage and improve performance.

When you connect a wallet or perform on-chain transactions, certain data becomes permanently public on the Ethereum blockchain:

• ⚠️Your wallet address is publicly visible on-chain
• ⚠️All token transactions are permanently recorded
• ⚠️Staking activity and rewards are publicly visible
• ⚠️This data cannot be deleted — it is immutable by blockchain design

While we can delete wallet addresses stored in our systems upon request, we cannot remove wallet addresses, transactions, or other information already recorded on public blockchains.

Wallet ownership is verified through a cryptographic signature request. This proves you control the wallet address without revealing your private key. No private keys are ever collected or stored by the platform.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, we will comply with applicable GDPR notification obligations, including notifying the relevant supervisory authority within 72 hours where required, and notifying affected users where appropriate.

The TRITO Token platform is not directed at children under 18 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, contact us immediately at mr.pobienski@gmail.com and we will take steps to delete such information.

We may update this Privacy Policy from time to time. We will notify registered users of significant changes by email. The "Last updated" date at the top of this page will always reflect the most recent version.