Privacy Policy

Last Revised: 19.12.2025

This Privacy Policy (“Policy”) describes how Loculus (“Loculus”, “we”, “our”, or “us”) collects, uses, stores, and shares personal data when you access or use our website, applications, and related tools, services, features, and functionalities (collectively, the “Services”).

For the purposes of applicable data protection laws, Loculus acts as the data controller. References to “you” or “your” mean you as a user of the Services.

Please read this Policy carefully to understand how we process your personal data and what rights you have. If you do not agree with this Policy, you should not access or use the Services.

1. Personal Data We Collect, Why We Collect It, and Legal Basis

When you access, use, or interact with the Services, we may collect certain categories of personal data from you or about you.

A. Information You Provide to Us

This may include:

  • Basic account information (such as name, email address, profile image) when you sign up or log in using third-party authentication providers (e.g. Google);
  • Wallet addresses and related public blockchain identifiers you choose to connect;
  • Portfolio preferences, trade parameters, and feature selections;
  • Communications you send to us (e.g. support requests or feedback);
  • Preferences related to testnets, airdrops, or experimental features.

We process this information to:

  • Create and manage your account;
  • Provide and operate the Services;
  • Perform our contract with you;
  • Respond to inquiries and support requests.

Legal basis: performance of a contract; legitimate interests.

B. Information We Collect Automatically

When you access or use the Services, we may automatically collect:

  • IP address;
  • Date and time of access;
  • Device, browser, operating system, and user-agent information;
  • Language and general location (country-level);
  • Usage and interaction data (pages visited, features used, session duration);
  • API requests and technical logs.

This data is processed to:

  • Enable access to and operation of the Services;
  • Maintain security, stability, and fraud prevention;
  • Monitor performance, debug issues, and optimize functionality;
  • Conduct analytics and internal statistical analysis.

Legal basis: legitimate interests; in some cases, legal obligations.

C. AI and Behavioral Data

When you interact with Loculus’ AI-powered features, we may process:

  • AI interaction data (such as prompts, preferences, and feature usage);
  • Behavioral signals related to platform usage.

This data is used to:

  • Provide personalized AI-driven analysis and insights;
  • Improve model performance and user experience;
  • Generate aggregated, anonymized, or de-identified analytics.

AI learning processes are conducted on anonymous or aggregated data and are not used to make fully automated decisions with legal or similarly significant effects on you.

Legal basis: legitimate interests and, where required, your consent.

D. Blockchain and Wallet Data

Certain Services may require you to connect a third-party wallet. When you do so, we may process:

  • Public wallet addresses;
  • Public transaction metadata relevant to the Services.

We do not control or store private keys and do not access wallet credentials.

Use of third-party wallets is governed by the privacy policies and terms of those wallet providers. Loculus is not responsible for their practices.

Legal basis: performance of a contract; legitimate interests.

How We Use Your Data

We use personal data to:

  • Provide, operate, and maintain the Services;
  • Personalize AI features, content, and user experience;
  • Enable trading-related workflows, portfolios, testnets, and airdrop features;
  • Improve platform security and reliability;
  • Comply with legal obligations;
  • Enforce our Terms of Service and protect our rights.

We may also create aggregated or anonymized datasets that no longer identify you.

Cookies and Tracking Technologies

We may use cookies and similar technologies to:

  • Enable core functionality;
  • Analyze usage and performance;
  • Improve user experience.

Where required by law, cookies will be subject to your consent.

Sharing of Personal Data

We may share your personal data in limited circumstances, including:

  • Service providers and vendors (e.g. hosting, analytics, cloud infrastructure);
  • Professional advisors (legal, accounting, security);
  • Regulators or authorities, where required by law;
  • Affiliates, where applicable and in our legitimate interests;
  • Business transactions, such as mergers or restructurings.

We do not sell your personal data.

International Data Transfers

Your data may be processed in countries outside your country of residence, including outside the EEA or UK.

Where required, we implement appropriate safeguards, such as:

  • Standard Contractual Clauses (SCCs);
  • Other legally recognized transfer mechanisms.

Data Retention

We retain personal data only for as long as necessary to:

  • Provide the Services;
  • Fulfill legal or regulatory obligations;
  • Resolve disputes or enforce agreements.

Retention periods depend on data type and purpose.

Your Rights

Depending on your location, you may have rights to:

  1. Access your personal data;
  2. Correct inaccurate data;
  3. Request deletion;
  4. Object to processing;
  5. Restrict processing;
  6. Data portability;
  7. Withdraw consent;
  8. Lodge a complaint with a supervisory authority.

Requests can be made using the contact details below. We may need to verify your identity.

Children’s Privacy

The Services are not intended for individuals under the age of 18.

We do not knowingly collect personal data from children.

Security

We implement reasonable technical and organizational measures to protect personal data.

However, no system can guarantee absolute security, and use of the Services is at your own risk.

Third-Party Links and Services

The Services may contain links to third-party websites or tools.

We are not responsible for their privacy practices or content.

Updates to This Policy

We may update this Policy from time to time.

Material changes will be reflected by updating the “Last Revised” date.

Contact

For questions or requests regarding this Policy or your personal data, contact us at:

support@loculus.xyz
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