Privacy Policy

Last Updated: February 22, 2025

Chunk Works (“we,” “us,” or “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our website or use our Services. This policy is designed to be transparent about our non-custodial architecture and data minimization principles.

1. Information We Collect

Information You Provide

We collect information you provide directly to us, including:

• Account Information: Name, email address, company name, and billing details provided during registration or purchase.
• Communication Data: Content of messages you send us via support tickets, contact forms, or email.
• Feedback: Comments, suggestions, or other feedback regarding our Services.

Information Collected Automatically

When you access our website or use our Services, we automatically collect:

• Log Data: IP address, browser type, operating system, access times, and pages viewed.
• Usage Data: Metrics regarding service utilization, such as storage volume, bandwidth consumption, and API request frequency.
• Device Information: Hardware model, operating system version, and unique device identifiers.

Data We DO NOT Collect

Due to our non-custodial architecture, we do not have access to or collect:

• Your Private Credentials: We never possess your private encryption keys, master passwords, or seed phrases.
• Unencrypted Content: We cannot access the plaintext content of the files or data you store via our Services, as encryption occurs client-side before transmission.

2. How We Use Your Information

We use the information we collect to:

• Provide, operate, and maintain our Services.
• Process transactions and send related information, including confirmations and invoices.
• Monitor and analyze trends, usage, and activities in connection with our Services to improve functionality and performance.
• Detect, prevent, and address technical issues, fraud, or security breaches.
• Communicate with you about updates, security alerts, and support messages.
• Comply with legal obligations and enforce our Terms & Conditions.

3. How We Share Your Information

We do not sell your personal information. We may share your information with:

Service Providers

Third-party vendors who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, and customer service. These providers are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Business Transfers

In connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Legal Requirements

When required by law, court order, or other governmental authority, or if we believe that disclosure is necessary to protect our rights, users, or the safety of others.

With Your Consent

When you explicitly consent to sharing your information with a third party.

4. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest where applicable.
• Strict access controls and authentication mechanisms for our internal systems.
• Regular security assessments and vulnerability scanning.
• Data minimization practices to limit the amount of personal data we store.

However, no method of transmission over the internet is 100% secure. While we strive to protect your information using commercially acceptable means, we cannot guarantee absolute security. You are responsible for maintaining the security of your own Credentials.

5. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

Access and Portability

Request access to your personal information and receive a copy in a structured, commonly used, and machine-readable format.

Correction

Request correction of inaccurate or incomplete personal information we hold about you.

Deletion

Request deletion of your personal information (“Right to be Forgotten”), subject to certain legal obligations (e.g., tax or accounting requirements).

Restriction

Request restriction of processing of your personal information under certain circumstances.

Objection

Object to processing of your information for direct marketing purposes or where processing is based on legitimate interests.

Withdraw Consent

Withdraw consent at any time where processing is based on your consent, without affecting the lawfulness of processing based on consent before its withdrawal.

To exercise these rights, please contact us at privacy@chunkworks.net. We will respond to your request within the timeframes required by applicable law.

6. Data Retention

We retain your information only for as long as necessary to:

• Provide the Services you have requested.
• Comply with our legal obligations (e.g., tax, accounting, audit).
• Resolve disputes and enforce our agreements.

When we no longer need your information, we will securely delete or anonymize it in accordance with our data retention policies.

7. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, where data protection laws may differ. We ensure appropriate safeguards are in place for such transfers, including:

• Transferring data to countries recognized by the European Commission as providing adequate data protection.
• Using Standard Contractual Clauses (SCCs) approved by the European Commission for transfers to other jurisdictions.

8. Children’s Privacy

Our services are not directed to children under the age of 16. We do not knowingly collect personal information from children. If you are a parent or guardian and believe we have collected information from a child, please contact us immediately, and we will take steps to remove such information.

9. Cookies and Tracking

We use cookies and similar tracking technologies to track activity on our Services and hold certain information. For more detailed information, please see our Cookie Policy. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

10. Third-Party Links

Our website may contain links to third-party websites or services that are not owned or controlled by Chunk Works. We are not responsible for the privacy practices or content of these third-party sites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Updates to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of material changes by:

• Posting the new Privacy Policy on this page with a new “Last Updated” date.
• Sending an email notification to registered users (where appropriate).
• Placing a prominent notice on our website.

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

12. GDPR Compliance

For residents of the European Economic Area (EEA), we process personal data in compliance with the General Data Protection Regulation (GDPR). Our legal bases for processing personal data include:

• Contractual Necessity: To fulfill our contract with you (e.g., processing payments, delivering services).
• Legitimate Interests: For our legitimate business interests (e.g., improving services, fraud prevention), provided these are not overridden by your rights.
• Legal Obligation: To comply with applicable laws.
• Consent: Where you have given specific consent (e.g., for marketing communications).

13. Contact Us

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

• Data Protection Officer: legal@chunkworks.net
• General Inquiries: Info@ChunkWorks.Net
• Mailing Address:
  Skaly B.V. (trading as Chunk Works)
  Wilhelminaplein 1-40
  3072 DE Rotterdam
  The Netherlands

Supervisory Authority

You have the right to lodge a complaint with your local data protection authority if you believe your rights have been violated. In the Netherlands, the supervisory authority is the Autoriteit Persoonsgegevens (AP).