Smurnix Privacy Policy

I. Scope of Application

This Policy applies to information processing activities generated when users access the official Smurnix website, create or use an account, connect a digital wallet, participate in the node network, use communication and verification services, submit cooperation applications, subscribe to project updates, or contact the customer service team.

Third-party wallets, trading platforms, blockchain explorers, partner institutions, and external websites have independent privacy rules, and their information processing activities are not governed by this Policy.

II. Information We May Collect

1. Information Voluntarily Provided by Users

When users register an account, apply for node access, submit enterprise cooperation requests, subscribe to updates, or contact customer service, we may collect names, email addresses, phone numbers, countries or regions, organization names, positions, and other content submitted by users.

Where required by laws, regulations, or specific business requirements, we may also collect information necessary for identity authentication, enterprise qualification verification, and compliance review. Such information will be collected only when there is a clear basis and actual need.

2. Device and Network Information

When users access the website or use the services, we may automatically collect IP addresses, device types, operating systems, browser types, access times, page records, language settings, error logs, node status, network latency, and security incident records. Such information is used to maintain service operation, identify abnormal activities, optimize network performance, and improve system stability.

3. Wallet and On-Chain Information

When users connect digital wallets, participate in node staking, governance voting, resource settlement, or other on-chain activities, we may process wallet addresses, transaction hashes, block times, smart contract interaction records, node contributions, and publicly visible on-chain data.

Please do not submit identity documents, contact information, communication content, private keys, mnemonic phrases, or other sensitive information in public on-chain remarks, transaction memos, or governance proposals.

4. Communication and Verification Information

To enable path scheduling, identity consistency verification, node collaboration, resource metering, and security auditing, we may process communication request times, node identifiers, path status, security levels, encryption protocol status, key exchange status, and verification results.

Unless necessary to implement specific functions and clearly explained to users, Smurnix will not collect or store users’ private keys, mnemonic phrases, complete session keys, or private communication content in plaintext.

5. Cookies and Similar Technologies

We may use necessary cookies to maintain website functionality, security status, and language settings. After obtaining authorization as required by applicable law, we may also use analytics cookies to understand website access and improve user experience.

Users may manage non-essential cookies through their browser or the cookie settings center. Disabling certain cookies may affect the normal use of specific functions.

III. Purposes of Information Use

Based on applicable grounds such as user consent, performance of agreements, fulfillment of legal obligations, and protection of legitimate interests, we may use information for the following purposes:

To provide, maintain, and improve the Smurnix website, protocols, and related services;
To complete account management, node access, identity verification, and customer support;
To execute communication path scheduling, on-chain verification, resource metering, and network settlement;
To identify attacks, scams, abnormal nodes, and unauthorized access;
To analyze service performance, repair faults, and improve system operating efficiency;
To send service notices, protocol updates, security alerts, and updates subscribed to by users;
To fulfill compliance review, regulatory reporting, dispute resolution, and other legal obligations;
To advance research, testing, ecosystem cooperation, and product optimization authorized by users.

We will not use information for activities clearly unrelated to the purposes for which it was collected. If information needs to be used for new purposes, we will update the explanation in accordance with applicable requirements and, where necessary, obtain consent again.

IV. On-Chain Data

Smurnix’s on-chain verification layer may record communication behavior status, key exchange status, node participation, and resource settlement results to form a traceable audit structure.

Considering that blockchain records may be public, distributed, and difficult to modify directly, Smurnix will follow the principle of data minimization and avoid writing information that can directly identify individuals into public ledgers wherever possible. Where on-chain verification is required, hash digests, status proofs, anonymized identifiers, or other necessary technical data will generally be recorded first, while identifiable information will be stored in appropriate off-chain systems. This design principle is consistent with the latest guidance direction proposed by European data protection authorities regarding the processing of personal data on blockchains.

Information independently initiated by users and written to public blockchains may not be capable of being modified or deleted unilaterally by Smurnix. For off-chain data controlled by Smurnix, we will process access, correction, or deletion requests in accordance with applicable law.

V. Information Sharing and Disclosure

Smurnix does not make the sale of personal information its primary business model. We may share necessary information only in the following circumstances:

With cloud services, security auditing, website analytics, email delivery, and customer support providers;
With necessary technical participants involved in communication routing, node verification, or network operation;
With wallets, applications, or partner institutions selected by users, in accordance with user instructions;
To disclose information in compliance with laws and regulations, court orders, or regulatory requirements;
To disclose information for the investigation of scams, security attacks, rights infringement, or other unlawful conduct;

We will require entrusted service providers to process information only for the agreed purposes and to adopt reasonable confidentiality and security measures.

VI. Cross-Border Data Transfers

Smurnix is designed for global networks and cross-regional communication scenarios, and some information may be transferred to servers, service providers, or node locations outside the country or region where users are located.

When cross-border processing occurs, we will adopt contractual clauses, access controls, encrypted transmission, data minimization, or other appropriate mechanisms in accordance with applicable law to reduce privacy risks arising from cross-border processing.

VII. Information Retention Period

We retain personal information only for the period necessary to achieve the purposes described in this Policy, perform contracts, handle disputes, and satisfy legal obligations.

Account information is generally retained until account cancellation and for a reasonable subsequent processing period. Security logs are retained according to risk management needs. Customer service and cooperation records are retained according to business and dispute-handling needs. Information required by law to be retained will be stored for the statutory period.

After the necessary period expires, we will delete, anonymize, or otherwise appropriately process the relevant information. Public blockchain records are not fully controlled by Smurnix and may continue to exist according to the rules of their underlying networks.

VIII. Information Security

Smurnix will adopt measures such as access permission management, encrypted transmission, identity authentication, log monitoring, node verification, risk isolation, and emergency response according to the nature of the data and the degree of risk.

Quantum key distribution, post-quantum cryptography, and on-chain verification can provide technical support for specific communication and verification scenarios, but no network, software, or storage system can guarantee absolute security. Users should properly safeguard account credentials, wallet private keys, mnemonic phrases, and device access permissions, and should not disclose them to any third party.

In the event of an information security incident that may affect users’ rights and interests, we will take remedial measures in accordance with applicable law and notify users and relevant authorities where necessary.

IX. Users’ Privacy Rights

Depending on the user’s location and applicable law, users may enjoy some or all of the following rights:

To inquire whether we process users’ information;
To obtain a copy of personal information;
To correct inaccurate or incomplete information;
To request deletion of eligible personal information;
To restrict or object to specific information processing activities;
To withdraw previously granted authorization or consent;
To obtain data in a structured and commonly used format and request portability;
To opt out of the sale or sharing of personal information or targeted advertising activities;
To request restrictions on specific uses of sensitive personal information;
To lodge complaints with local regulatory authorities regarding information processing issues.

Some rights may be subject to restrictions due to identity verification, legal retention obligations, the technical characteristics of public blockchains, and other statutory exceptions. Privacy regimes such as those in the European Union and California require enterprises to provide eligible users with corresponding information control rights.

X. Information of Minors

Smurnix’s services are not intended for minors who do not have independent legal capacity. We do not knowingly collect personal information from users below the statutory age applicable in their region. If a guardian discovers that a minor has submitted personal information to us without authorization, the guardian may contact us to request processing.

XI. Third-Party Services

The Smurnix website may contain links to third-party websites, wallets, community platforms, blockchain explorers, or partner services. After users access such services, relevant information will be processed in accordance with the third party’s privacy policy. Users are advised to carefully read third-party terms and permission explanations before connecting wallets, authorizing smart contracts, or submitting information.

XII. Policy Updates

We may update this Policy in accordance with changes in product functions, protocol architecture, legal requirements, and operating methods. In the event of material adjustments, we will notify users through official website announcements, product notices, emails, or other appropriate means.