Privacy Policy

Who we are

havl operates a human verification network for artificial intelligence, autonomous agents and autonomous machines.

The data controller responsible for the processing described in this Privacy Policy is:

havl AB

Stockholm, Sweden

Email: hello@havl.io

Information we collect

The personal data we collect depends on how you interact with havl.

Account information

When you create or use a havl account, we may collect information such as:

• name, alias or username;
• email address;
• connected social account information;
• profile information;
• account identifiers; and
• authentication and security information.

Wallet and blockchain information

If you connect a blockchain wallet or interact with blockchain-based features, we may process:

• public wallet addresses;
• blockchain transaction information;
• token balances relevant to the Services;
• staking activity;
• reward transactions; and
• other publicly available on-chain information.

Public blockchain transactions are inherently public and may remain permanently available on the relevant blockchain. havl cannot modify or delete information recorded directly on a public blockchain.

Verification activity

When participating as a verifier, we may process information relating to your activity within the network, including:

• verification tasks completed;
• submitted assessments;
• accuracy and quality metrics;
• XP and verifier level;
• qualifications and credentials;
• Certified Expert status where applicable;
• task history;
• rewards earned; and
• network-integrity and fraud-prevention signals.

This information may be used to operate the verifier level, reputation and quality-control systems.

Client information

If you use havl as a client or integrate our Services, we may process:

• business contact information;
• account and organisation information;
• API usage;
• verification requests;
• billing and transaction information; and
• communications with havl.

Technical information

When you access the Services, certain technical information may be collected automatically, such as:

• IP address;
• browser and device information;
• operating system;
• timestamps;
• pages or features accessed;
• log information; and
• security and diagnostic data.

Where required, cookies or similar technologies are used only in accordance with applicable consent requirements.

How we use personal data

We may use personal data to:

• provide and operate the havl Services;
• create and maintain user accounts;
• authenticate users;
• connect blockchain wallets;
• assign and process verification tasks;
• calculate XP, levels, reputation and rewards;
• process or facilitate network rewards;
• maintain verification quality;
• detect fraud, manipulation and abuse;
• secure the network and user accounts;
• provide customer support;
• communicate important service information;
• improve the performance and functionality of havl;
• comply with legal and regulatory obligations; and
• establish, exercise or defend legal claims.

We do not sell personal data.

Legal bases for processing

Under the GDPR, we process personal data only where we have a valid legal basis.

Depending on the circumstances, this may include:

Performance of a contract — where processing is necessary to provide the Services you request.

Legitimate interests — where processing is necessary to operate, secure and improve havl, prevent fraud, protect the integrity of the verification network or manage our business, provided those interests are not overridden by your rights.

Legal obligations — where processing is required to comply with applicable law.

Consent — where we specifically ask for your consent, for example for certain cookies or marketing communications. Where processing is based on consent, you may withdraw that consent at any time.

Verification tasks and client data

Verification tasks may contain information submitted by havl clients.

Clients are responsible for ensuring that they have an appropriate legal basis and the necessary rights to submit personal data to havl for processing.

Where havl processes personal data solely on behalf of a client, havl may act as a data processor and the client as the data controller. Such processing may be governed by a separate Data Processing Agreement.

Verifiers may only access task information for the purpose of completing the relevant verification task. They must not retain, disclose, reproduce or use task information for unrelated purposes.

Where appropriate, havl may use technical and organisational measures to minimise or pseudonymise information presented to verifiers.

Blockchain data

Public blockchain networks operate differently from conventional databases.

Information recorded on a public blockchain may be visible to anyone and may be practically impossible to alter or erase. This can include wallet addresses and transaction information.

Where possible, havl avoids recording unnecessary personal information directly on-chain.

Users should understand that a public wallet address may become associated with an individual through their own activity or information available from third parties.

Sharing personal data

We may share personal data with trusted service providers where necessary to operate havl.

These may include providers of:

• cloud infrastructure and hosting;
• databases;
• authentication;
• analytics;
• security and fraud prevention;
• blockchain infrastructure;
• wallet connectivity;
• communications;
• payment or reward infrastructure; and
• professional legal, accounting or compliance services.

Service providers may process personal data only for authorised purposes and subject to appropriate contractual and security requirements.

We may also disclose information where required by law, court order or competent public authorities.

International data transfers

Some service providers may process information outside Sweden or the European Economic Area (“EEA”).

Where personal data is transferred outside the EEA, we use appropriate safeguards as required by the GDPR, such as an adequacy decision by the European Commission or approved Standard Contractual Clauses.

Data retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy or as required by law.

Retention periods may vary depending on the type of information, legal requirements, security needs and whether an account remains active.

Verification records may be retained where reasonably necessary to maintain network integrity, calculate reputation, investigate abuse or demonstrate the reliability of verification results.

Information recorded independently on public blockchains is not controlled by havl and may remain permanently available.

Security

We use appropriate technical and organisational measures designed to protect personal data against unauthorised access, loss, alteration, disclosure or destruction.

However, no online system, blockchain network or data transmission method can be guaranteed to be completely secure.

Users are responsible for protecting their account credentials, connected wallets and private keys.

Your rights

If the GDPR applies to you, you may have the right to:

• access personal data we hold about you;
• correct inaccurate personal data;
• request deletion of your personal data;
• restrict certain processing;
• object to processing based on legitimate interests;
• receive certain personal data in a portable format;
• withdraw consent where processing is based on consent; and
• lodge a complaint with a competent data-protection authority.

These rights may be subject to limitations under applicable law.

Requests can be submitted using the contact information provided below.

Automated systems and profiling

havl may use automated systems to calculate or support calculations relating to XP, verifier levels, reputation, task eligibility, fraud detection and network quality.

Where automated processing produces legal or similarly significant effects, havl will provide the protections required under applicable data-protection law, including human review where required.

Cookies and analytics

havl may use cookies and similar technologies necessary for security, authentication, functionality and performance.

Non-essential cookies, including certain analytics technologies, will only be used with consent where required by applicable law.

Users can manage applicable preferences through the cookie settings provided on the website.

Children's privacy

The havl Services are not intended for children.

Users must meet the minimum age requirements applicable to the relevant Service and their jurisdiction. We do not knowingly collect personal data from children in circumstances where doing so would violate applicable law.

Third-party services

The Services may connect to third-party platforms, wallets, blockchain networks or other external services.

Those third parties may process personal data independently under their own privacy policies. havl is not responsible for the privacy practices of independent third parties.

Changes to this Privacy Policy

We may update this Privacy Policy as havl develops, our processing activities change or legal requirements evolve.

The current version will be published on the havl website with the date of the latest update. Where required by law, we will provide additional notice of material changes.

Contact

For questions about this Privacy Policy or requests relating to your personal data, contact:

havl AB

Stockholm, Sweden

Email: [privacy contact email]

Registration number: [Swedish organisation number]

You also have the right to lodge a complaint with the competent supervisory authority. In Sweden, the supervisory authority is the Swedish Authority for Privacy Protection (Integritetsskyddsmyndigheten, IMY).