01 Introduction
Accessa FZ LLE ("Accessa", "we", "us", "our"), a Free Zone Limited Liability Establishment incorporated in the Fujairah Creative City Free Zone (Fujairah Media Free Zone), United Arab Emirates, under the authority of the Fujairah Creative City Free Zone Authority, operates the Accessa platform, a listing intelligence and business development service for crypto projects (the "Platform").
This Privacy Policy explains what personal and business data we collect, why we collect it, how we use and protect it, and what rights you have in relation to it. "You" and "your" refer to any individual or entity that registers or uses the Platform, including authorized representatives of projects or firms.
By using the Platform, you confirm that you have read and understood this Privacy Policy. If you do not agree with how we handle data, please do not use the Platform.
For any privacy-related questions or requests, contact us at: info@accessa.network.
02 Data We Collect
We collect the following categories of data when you use the Platform:
Account data, including your name, email address, job title, company name, and any profile information you provide when registering.
Project and firm data, including token name and ticker, token contract address, chain, TGE date, token supply and tokenomics, current exchange listings, trading volume, market capitalization, treasury holdings, fundraising history, team information, and any other project-level data you submit through onboarding forms or profile updates.
Documents and materials, including pitch decks, tokenomics reports, audit reports, legal opinions, or any other files you upload to the Platform in connection with a potential deal or introduction.
Deal and contact preferences, including which Partners (exchanges, market makers, investors) you choose to contact or request introductions to, and the nature of your enquiry.
Usage data, including IP address, browser type, device type, pages visited, features used, and timestamps of activity on the Platform. This data is collected automatically when you access the Platform.
Communications data, including the content of any messages, emails, or support requests you send to Accessa.
On-chain payment data, including public blockchain transaction data (wallet addresses, transaction hashes, amounts) associated with success fees paid to Accessa. This data is publicly visible on-chain by its nature.
03 How We Collect Data
We collect data in the following ways:
- Directly from you, when you register, complete onboarding forms, update your profile, upload documents, request introductions, or contact our team.
- Automatically, through cookies, local storage, and similar technologies when you browse or use the Platform (see Section 12 on Cookies and Local Storage).
- From public sources, such as public blockchain data and publicly available project information, which we may use to supplement or verify the data you provide.
- From Partners, who may provide feedback or status updates related to an introduction we facilitated on your behalf.
04 How We Use Your Data
We use the data we collect for the following purposes:
- To register and manage your account and verify your eligibility.
- To facilitate introductions and deal-flow between your project and the specific Partners you select.
- To prepare and share your project profile and documents with Partners you have explicitly chosen to contact.
- To track and administer success-based fees, issue invoices, and process on-chain payments.
- To improve and maintain the Platform, fix bugs, and develop new features.
- To send you service-related communications, including confirmations, updates, and alerts about introductions or deal status.
- To comply with our legal obligations, including anti-money laundering (AML) and know-your-customer (KYC) checks where required.
- To generate aggregated, anonymized market intelligence about the crypto listing landscape. This intelligence never identifies individual projects or users.
- To respond to your queries and provide customer support.
We rely on the following legal bases for processing your data: performance of a contract with you; compliance with a legal obligation; our legitimate interests in operating and improving the Platform; and, where applicable, your consent.
05 We Never Sell Your Data
Your data is an asset that you entrust to us to facilitate your business development. It is not a product we monetize.
06 Data Sharing with Partners
We share your project profile, data, and documents with Partners only in the following strictly limited circumstance: you have explicitly selected that Partner and initiated a request for an introduction through the Platform.
We do not share your data with any Partner you have not chosen. We do not share your data speculatively or to "warm up" a Partner relationship without your knowledge and consent.
When we share data with a Partner, we do so subject to the Partner's own confidentiality obligations. However, you should be aware that once data is shared with a Partner, that Partner's own data practices apply and Accessa cannot control how the Partner stores or uses that data after receipt.
We may also share data in the following additional circumstances:
- With our service providers and technology vendors who help us operate the Platform (e.g., cloud hosting, email delivery), under contractual data processing obligations that restrict their use of your data.
- With legal or regulatory authorities, where required by applicable law, court order, or regulatory request.
- In connection with a merger, acquisition, or sale of all or substantially all of our assets, provided the acquiring entity agrees to be bound by this Privacy Policy.
07 On-Chain Payment Data
When you pay a success fee to Accessa, the transaction is recorded on a public blockchain. Blockchain transactions, including the sending wallet address, receiving wallet address, token amount, and timestamp, are publicly visible and permanently recorded. Accessa cannot delete or modify on-chain data.
Accessa links each invoice to the corresponding on-chain transaction hash for transparency and auditability. If you have concerns about the public nature of on-chain payments, please discuss alternative arrangements with our team before initiating a transaction.
08 Data Retention
We retain your data for as long as your account is active and for a reasonable period afterwards to fulfill our legal, accounting, and contractual obligations.
Specifically:
- Account and project data is retained for the duration of your account and for a minimum of five (5) years after account closure, to satisfy financial record-keeping and AML compliance obligations.
- Communications and support records are retained for up to three (3) years.
- Usage and analytics data is retained in aggregated or anonymized form indefinitely.
- On-chain payment data is publicly available on the blockchain and cannot be deleted.
We may retain data for longer periods where required by law or regulation, or where necessary to resolve disputes or enforce our agreements.
09 Security
Accessa implements commercially reasonable technical and organizational security measures to protect your data against unauthorized access, disclosure, alteration, or destruction. These measures include encryption of data in transit (TLS), access controls limiting data access to authorized personnel only, regular security reviews of our systems, and contractual security obligations imposed on our service providers.
No system is completely secure. While we take reasonable precautions, we cannot guarantee that unauthorized parties will never be able to circumvent our measures. In the event of a data breach that poses a significant risk to your rights, we will notify you and applicable regulators in accordance with our legal obligations.
You are responsible for maintaining the security of your own account credentials. Do not share your password with anyone, and contact us immediately at info@accessa.network if you suspect a security incident.
10 Your Rights
Subject to applicable law, you have the following rights regarding your personal data:
- Access: You may request a copy of the personal data we hold about you.
- Correction: You may request that we correct inaccurate or incomplete data.
- Deletion: You may request that we delete your personal data, subject to our legal retention obligations. Note that we cannot delete data that is required to be retained by law or that has been shared with a Partner who has independently received it.
- Restriction: You may request that we restrict the processing of your data in certain circumstances.
- Portability: You may request a copy of your data in a structured, machine-readable format where technically feasible.
- Objection: You may object to processing based on our legitimate interests, subject to overriding legal grounds.
- Withdrawal of consent: Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
To exercise any of these rights, contact us at info@accessa.network. We will respond within a reasonable timeframe and in any event within the period required by applicable law. We may ask you to verify your identity before processing a request.
11 International Data Transfers
Accessa is incorporated and operates in Fujairah, UAE. Your data may be stored on servers located in the UAE or in other jurisdictions where our cloud service providers operate (including the EU, UK, or US).
When we transfer data internationally, we take steps to ensure that appropriate safeguards are in place, such as standard contractual clauses, data processing agreements, or reliance on adequacy decisions, where applicable. By using the Platform, you acknowledge that your data may be transferred to and processed in countries that may have different data protection standards than your home jurisdiction.
12 Cookies and Local Storage
The Platform uses cookies and browser local storage to enhance your experience. Specifically, we use:
- Strictly necessary cookies and local storage, which are required for the Platform to function (e.g., keeping you logged in, storing session preferences). These cannot be disabled without breaking core functionality.
- Analytics cookies, which help us understand how users interact with the Platform so we can improve it. These may be provided by third-party analytics tools. Where such tools process personal data, they do so subject to their own privacy policies.
You can control cookies through your browser settings. Disabling certain cookies may affect Platform functionality. We do not use cookies for targeted advertising or to track you across third-party websites.
13 Age Restriction
The Platform is intended for adults aged 18 and over who are acting as authorized representatives of businesses or projects. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a person under 18 has provided personal data to us, we will delete that data promptly.
14 Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or for other operational reasons. When we make material changes, we will update the "Last updated" date at the top of this page and, where reasonably practicable, notify registered users via email or a prominent notice on the Platform.
Your continued use of the Platform after the revised Policy takes effect constitutes your acceptance of the changes. We encourage you to review this Policy periodically.
15 Contact and Complaints
For any questions, concerns, or requests relating to this Privacy Policy or our data practices, please contact us at:
Accessa FZ LLE
M1 Floor, Twin Towers, PO Box 4422
Fujairah Creative City Free Zone, Fujairah, UAE
Email: info@accessa.network
If you are not satisfied with our response, you may have the right to lodge a complaint with the relevant data protection authority in your jurisdiction.