General Data Protection Regulation

**Last Updated: January 10, 2026**

Mindsetx LLC ("we," "us," or "our") operates a health, wellness and personal development app, along with an associated website at https://mindsetx.health   (the "Website").

This GDPR Data Protection Notice applies to individuals in the European Union, European Economic Area, and United Kingdom ("you") whose personal data is processed under Regulation (EU) 2016/679 (General Data Protection Regulation - GDPR) and applicable national laws. It supplements our general Privacy Policy.

We act as the data controller for off-chain processing. For on-chain interactions, data is processed pseudonymously on public blockchains, where we do not control the data.

Contact: kevin.williams@mindsetx.health

Data Protection Officer: Not appointed (scale and nature of processing do not require one).

The Protocol is fully decentralized and non-custodial. Core trading occurs directly via self-custodied wallets on public blockchains without requiring personal data.

### 1. Personal Data We Process

We process minimal personal data:

**Categories**:

- **Identifiers**: Pseudonymous wallet addresses (on-chain), IP addresses (Website logs).

- **Internet/Network Activity**: Browser type, device info, timestamps, referral pages (via essential cookies and logs).

- **Geolocation Data**: Approximate location from IP (coarse only).

- **Correspondence Data**: Email address, name (if provided), and content when you contact us.

We do **not** process:

- Special categories of personal data (e.g., health, ethnicity, political opinions).

- Data from children under 16.

**Sources**: Directly from you (wallet connections, communications), automatically (Website interactions), or public blockchain queries.

**Legal Bases** (Art. 6 GDPR):

- Legitimate interests: Operating Services, security, fraud detection (e.g., Honest Volume moat), analytics (anonymized), support.

- Contract: Providing dashboard features or APIs.

- Consent: Non-essential cookies (revocable anytime).

- Legal obligations: Sanctions screening.

**Purposes**:

- Operate and improve Services (e.g., dashboards, risk alerts).

- Detect abuse/wash-trading.

- Anonymized analytics.

- Respond to inquiries.

- Compliance (e.g., sanctions via Chainalysis).

### 2. Sharing and International Transfers

We share data only where necessary:

- Service providers (e.g., hosting, analytics, Chainalysis) acting as processors under contracts (Art. 28 GDPR).

- Legal authorities if required.

- Business transfers (unlikely).

On-chain data is public and globally accessible.

**Transfers outside EEA/UK**: Blockchain is borderless; off-chain data may transfer to processors globally. We use safeguards like Standard Contractual Clauses (SCCs) and adequacy decisions where applicable.

### 3. Data Retention

- Off-chain logs/cookies: Up to 12 months.

- Correspondence: As needed for support/resolution.

- On-chain data: Permanent (immutable blockchain).

We retain only as long as necessary for purposes or legal requirements.

### 4. Your Rights Under GDPR

You have the following rights (subject to exceptions):

- **Access** (Art. 15): Confirm processing and obtain a copy.

- **Rectification** (Art. 16): Correct inaccurate data.

- **Erasure** ("right to be forgotten," Art. 17): Delete data where no overriding grounds.

- **Restriction** (Art. 18): Limit processing.

- **Portability** (Art. 20): Receive data in structured format.

- **Objection** (Art. 21): Object to legitimate interest processing.

- **Withdraw Consent** (Art. 7): Anytime for consent-based processing.

- **Lodge Complaint**: With supervisory authority (e.g., ICO in UK).

On-chain data cannot be erased due to immutability.

### 5. How to Exercise Rights

Submit requests to:  

kevin.williams@mindsetx.health  (subject: "GDPR Request")

Include details for verification (e.g., email or wallet reference). We respond within one month (extendable).

No fees normally; unreasonable requests may incur costs.

Authorized agents accepted with proof.

### 6. Automated Decision-Making

No automated decisions with legal/significant effects.

### 7. Changes to This Notice

Updates posted on Website with new date. Material changes notified via announcements.

### Contact

Questions or rights exercise: kevin.williams@mindsetx.health

We prioritize privacy in our decentralized, integrity-first design. Most interactions are pseudonymous and on-chain, placing control with you.