Privacy Policy

Diffusion Labs Privacy Policy

updated 28.2.2023



Diffusion Labs and its affiliates (hereinafter, “Diffusion”, “we”, “us” or “our”) are committed to protecting and respecting your privacy. This Privacy Policy together with our Terms of Use governs our collection, processing and use of your Personal Data when you access our website (“Website” or “Websites”). By accessing the Website, you are confirming to know the contents of the Privacy Policy and consenting to the information collection and specific purposes described in this Privacy Policy.

Diffusion is the data controller responsible for processing Your Information. This Privacy Policy conforms to the best practises and gives you rights by operation of the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, “GDPR”).

The purpose of this Privacy Policy is to set out in an accountable and transparent way the collection and use of information by Diffusion. Information will only be collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes.  

What does “Personal Data” mean?

“Personal Data” means any information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity.

World Wide Web related information, including but not limited to IP Addresses, operating system and browser type may be received by Diffusion as a result of your interactions with our Website.


Which is the Purpose of the processing of Personal Data ?

Data is only processed in order to:

  • Provide our services efficiently and effectively;

  • Develop and deliver products and services to you;

  • Understand your needs and your eligibility for products and services;

  • Establish and maintain a responsible commercial relationship with you;

  • Meet Diffusion’s legal and regulatory requirements.

Which is the legal basis for the Data Processing and when we will require a specific consent?

The Data Processing related to the use of our Website is necessary for the offering of our services. If for a certain type of processing the applicable law requires a specific consent, we will request your specific consent before starting the processing of your Personal Data.

Which is the scope of our Data Processing?

When using the Websites for information purposes only, we only collect the personal data that your browser transmits to our server. When this data is stored, it is not assigned to a specific person. When you view our Website, we collect the following data, which are technically necessary for us to display our Website to you and to guarantee stability and security:

  • IP address;

  • date and time;

  • time zone difference to Greenwich Mean Time (GMT) time zone;

  • access status/http status code;

  • amount of data transferred in each case;

  • website from which the request comes;

  • browser (incl. language and version);

  • operating system and version of the browser software.

Security, Protection and Use of Personal Data

Diffusion is committed to protecting your privacy. Diffusion constantly implements appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including: (a) the pseudonymization and encryption of Personal Data; (b) the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services; (c) the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident.

The security measures in place will, from time to time, be reviewed in line with legal and technical developments. However, we give no guarantee that such misuse, loss, unauthorised access, modification, or disclosure will not occur. There are protective measures that you should take which as well include but are not limited to changing password regularly, not sharing your Personal Data with others unless you clearly understand the purpose of their request and you know with whom you are dealing. This affects particularly the use of the private wallet cryptographic keys that need to be safely protected and stored.

Diffusion reserves the right to retain and share certain personal data in order to meet our regulatory and statutory requirements. In addition, Diffusion reserves the right to retain and share certain Personal Data with our partners, and third parties acting on behalf of Diffusion.

Personal Data may be exported outside of the jurisdiction in which you reside. Your Personal Data may be processed and stored in a foreign country or countries. Under those circumstances, the governments, courts, law enforcement or regulatory agencies of that country or those countries may be able to obtain access to your Personal Data according to foreign laws. You need to be aware that the privacy standards of those countries may be lower than those of the jurisdiction in which you reside. You should note that you are not obliged to give your Personal Data to Diffusion, but if you choose not to do so, we may not be able to provide our services, or your access to our services may be limited.


Disclosure of Personal Data

We use the Personal Data for the purposes indicated at the time you provide us with such information, and/or otherwise for the purposes set out in this Privacy Policy and/or as otherwise permitted by law. We may make available the Personal Data that you provide to us to our affiliates, agents, representatives, service providers and contractors for these purposes. We also reserve the right to disclose Personal Data that Diffusion believes, in good faith, is appropriate or necessary to enforce our Terms of Use, take precautions against liability or harm, to investigate and respond to third-party claims or allegations, to respond to a court order or official requests, to protect security or integrity of Diffusion and to protect the rights, property or safety of Diffusion, our uses or others.

If you request it in writing, we may share your Personal Data with your nominated advisors. Except where disclosure of your Personal Data is required by law or requested by you, we will generally require any third party which receives or has access to Personal Data to protect such Personal Data and to use it only to carry out the services they are performing for you or for us, unless otherwise required or permitted by law. We will ensure that any such third party is aware of our obligations under this Privacy Policy and we will take reasonable steps to ensure that contracts we enter with such third parties binds them to terms no less protective of any Personal Data disclosed to them than the obligations we undertake to you under this Privacy Policy or which are imposed on us under applicable data protection laws.

If Diffusion is involved in a merger, acquisition, sale, bankruptcy, insolvency, reorganisation, receivership, assignment or the application of laws or change of control, there may be a disclosure of your information to another entity related to such an event.


Access and Changing of Personal Data

You have the right to access the Personal Data we hold about you, and to require the correction, updating and blocking of inaccurate and/or incorrect data by sending an email to us. We will aim to respond to your request within 14 days. You may also request the deletion or destruction of your Personal Data or your Transaction details by sending an email to us. 

Diffusion will act on your request only when it is not inconsistent with its legal and regulatory obligations and compliance procedures. Upon your written request, we will inform you of the use and general disclosure of your Personal Data.

Retention of Personal Data

We will hold your Personal Data only for as long as it is necessary for us to do so, having regard to the purposes described in this Privacy Policy and our own legal and regulatory requirements. In general, we usually do not retain any Personal Data and strictly comply with the data minimisation principle.  

Users Under Age 

Diffusion does not knowingly collect or store any Personal Data about children under 13 without verifiable prior parental consent. If you believe such information has been inadvertently processed, we will take necessary steps to remove such information from our database. Users under 13 must seek and obtain parental consent to use this website.


There may be links from our Site to other sites and resources provided by third parties. This Privacy Policy applies only to our Site. Accessing those third-party sites or sources requires you to leave our Site. We do not control those third party sites or any of the content contained therein and you agree that we are in no way responsible or liable for any of those third party sites, including, without limitation, their content, policies, failures, promotions, products, services or actions and/or any damages, losses, failures or problems caused by, related to or arising from those sites. We encourage you to review all policies, rules, terms and regulations, including the privacy policies, of each site that you visit.


Our policies, content, information, promotions, disclosures, disclaimers and features may be revised, modified, updated, and/or supplemented at any time and without prior notice at the sole and absolute discretion of the Company. If we change this Privacy Policy, we will take steps to notify all Users by a notice on our website and will post the amended Privacy Policy on the website.



If you have any questions, comments, or concerns regarding our Privacy Policy and/or practises, please contact us at