Tookle.io | Privacy & Cookie Policy

About Us

This Privacy Policy explains how we process and protect your personal data when you use the Tookle.io technical software infrastructure (the "Website"), the Tookle.app interface, or any services provided therein (together, the "Services").

The Services are operated by NOMA - CH-550-1237598-6, trading as Tookle, registered in Switzerland (the "Provider", "we", "our", or "us").

Unless otherwise defined in this Privacy Policy or our Terms of Service, the definitions used in this Privacy Policy have the same meaning as in the Swiss Federal Act on Data Protection (FADP).

1. Personal Data We Collect (By User Role)

We collect different types of data depending on how you interact with our platform. We strictly differentiate between three categories of users:

A. Visitors (No Account)

Individuals who browse the public website without logging in or connecting a wallet.

What we DO NOT collect: We do not collect your name, email address, phone number, or any direct personal identifiers.
What we DO collect: Technical data required for system security and website functionality (IP Address, Browser type, Strictly Necessary Cookies).

B. Contributors / Participants (Registered Users)

Individuals who connect a wallet, create a user profile, or actively participate in a Deal Room.

Identity & Contact: Email address (required for notifications).
Wallet Data: Public wallet address (e.g., Ethereum/Polygon address).
Compliance Data: Residency and status flags (e.g., "Accredited Contributor," "KYC Verified").
Referral Data: Invite codes and commission history.
Participation Logs: Technical logs of your participation cached for display purposes.

C. Founders (Clients)

Individuals or entities who set up Deal Rooms to raise funds.

Full Account Data: Legal name, email, encrypted password, and entity details.
Project Data: Whitepapers, roadmaps, and Team Member Data.
Operational Data: Technical access control lists (Whitelists) and Deal Room configurations.

2. How We Collect Personal Data

Directly (Volunteered by You): When you connect your wallet, sign a message, register an organization, or pay software setup fees.
Indirectly (Automated): From public blockchains (indexing transaction status), from software operations (vesting calculations), and from third-party identity providers (KYC pass/fail status).

3. Legal Basis & Purposes

Contract

To perform obligations under the Service Agreement or ToS (Billing, SaaS access).

Legitimate Interests

System security, fraud prevention, and platform improvement.

Legal Obligation

Accounting records (10-year retention) and compliance enforcement.

4. Data on the Blockchain (Crucial Notice)

Transactions are Public & Immutable

When you interact with our Smart Contracts, your wallet address and transaction details are permanently recorded on the blockchain. While the blockchain does not store your name, linking your wallet to your real identity (e.g., via our KYC checks) creates a link between your on-chain history and your off-chain profile. Tookle protects this link in our secure database, but cannot control public analysis of the blockchain itself.

5. Data Retention

We retain personal data for so long as it is needed for the purposes for which it was collected or in line with legal and regulatory requirements or contractual arrangements.

6. Sub-Processors

We use third-party providers for: Cloud Hosting, Blockchain Nodes, and Email Services.

7. Your Rights

Under the Swiss FADP, you have the right to access, correct, or delete your off-chain personal data. To exercise these rights, contact us at the email below.

8. Cookie Policy

We use cookies strictly for Technical Necessity and Aggregated Statistics:

Authentication: Keeping you logged in.
Wallet Connection: Linking to Metamask/WalletConnect.
Referral Tracking: Ensuring fair commission attribution.
Anonymous Statistics: We may use cookies to collect anonymous, aggregated usage data to improve our platform performance and user experience.