DGN Privacy Policy

• Name: Data Guardian Tech Ltd.
• Registration: Business Company No. 2173379
• Address: Rough Point, P.O. Box 4203, Mount Healthy, Road Town, Tortola, VG1110, British Virgin Islands
• Data Protection Officer: privacy@d-gn.io

• All users of the D-GN Speak2Earn platform
• Data collected through our website, mobile applications, and related services
• Personal data of EU residents (enhanced protections under GDPR)
• Cross-border data transfers and international processing activities

Data Types:

• Voice recordings and audio clips
• Facial expression captures and photographs
• Lip-sync videos and facial movement data
• Biometric identifiers derived from submitted content
• Purpose: AI model training for speech recognition, facial expression analysis, and lip-sync technology development.
• Legal Basis (GDPR): Explicit consent (Article 6(1)(a)) and legitimate interests for AI research (Article 6(1)(f)).

Data Types:

• Username and display name
• Email address and contact information
• Date of birth and age verification
• Country/region of residence
• IP address and device identifiers
• Purpose: Account management, age verification, geographic compliance, and platform security.
• Legal Basis: Contractual necessity (Article 6(1)(b)) and legal compliance (Article 6(1)(c)).

Data Types (for users exceeding $500 rewards):

• Government-issued identification documents
• Proof of address documentation
• Financial transaction records
• Beneficial ownership information (where applicable)
• Purpose: Anti-money laundering (AML) compliance and regulatory reporting.
• Legal Basis: Legal compliance (Article 6(1)(c)) and legitimate interests for fraud prevention (Article 6(1)(f)).

Data Types:

• Submission timestamps and frequency
• Platform interaction logs
• Performance analytics and error reports
• Communication records with support teams
• Purpose: Platform improvement, security monitoring, and user experience optimization.
• Legal Basis: Legitimate interests for platform security and improvement (Article 6(1)(f)).

• Voice Data: Training speech recognition models, accent analysis, and pronunciation improvement
• Facial Data: Developing expression recognition systems and emotional AI capabilities
• Lip-Sync Data: Creating accurate lip-movement prediction models for avatar and dubbing technologies

• Point Calculation: Tracking submissions and calculating earned points
• Prize Distribution: Managing USDT giveaways and $DGN token airdrops
• Anti-Fraud: Detecting gaming attempts and ensuring fair distribution

• Identity Verification: Confirming user authenticity and preventing multiple accounts
• AML Monitoring: Detecting suspicious patterns and ensuring regulatory compliance
• Data Integrity: Maintaining quality standards and preventing fraudulent submissions

• Technical Support: Providing assistance with platform issues
• Community Management: Facilitating Discord and Telegram interactions
• Updates and Notifications: Informing users of platform changes and opportunities

Your submitted data may be used to:

• Train neural networks for speech recognition and synthesis
• Develop facial expression recognition algorithms
• Create lip-sync prediction models
• Improve bias detection and mitigation systems

• Synthetic Data Generation: Creating training variations from your submissions
• Anonymization Techniques: Removing identifying characteristics while preserving useful patterns
• Cross-Language Processing: Developing multilingual AI capabilities
• Quality Enhancement: Improving audio and video resolution for better training outcomes

We may use trusted AI service providers for:

• Initial data processing and validation
• Advanced machine learning model training
• Research collaboration with academic institutions
• Commercial partnerships for AI development

We share personal data with trusted service providers for:

• Cloud Storage: Secure data hosting and backup services
• Payment Processing: USDT distribution and financial transactions
• Identity Verification: KYC and AML compliance services
• Analytics: Platform performance monitoring and improvement

Anonymized and aggregated data may be shared with:

• Universities and research institutions for AI ethics research
• Industry partners for bias reduction initiatives
• Standards organizations for AI safety development
• Open-source projects for community benefit

We may disclose personal data when required by:

• Court orders and legal process
• Regulatory investigations and compliance requests
• Law enforcement agencies for criminal investigations
• Emergency situations involving safety or security threats

• In the event of merger, acquisition, or asset sale, personal data may be transferred as part of business assets, subject to equivalent privacy protections.

Your personal data may be processed in countries outside your residence, including:

• United States: Cloud infrastructure and AI processing services
• European Union: GDPR-compliant data centers and research partnerships
• Asia-Pacific: Regional user support and data processing facilities

For EU residents, we implement appropriate safeguards:

• Standard Contractual Clauses (SCCs): EU-approved contractual protections
• Adequacy Decisions: Transfers to countries with adequate protection levels
• Binding Corporate Rules: Internal privacy standards for global operations
• Certification Schemes: Third-party verified privacy frameworks

• We comply with local data residency requirements where applicable and maintain regional data processing capabilities to minimize cross-border transfers when required by law.

To balance blockchain immutability with GDPR requirements:

• Personal Data Storage: Stored off-chain in mutable databases
• Blockchain Records: Only cryptographic hashes and references stored on-chain
• Transaction History: Immutable records of rewards and point distributions
• Smart Contracts: Automated processing without embedded personal data

When you request data deletion:

• Off-Chain Deletion: Personal data removed from our databases
• Encryption Key Destruction: Keys deleted, rendering on-chain references unreadable
• Verification Records: Compliance documentation maintained as required by law
• Functional Erasure: Data becomes inaccessible and meaningless

• Zero-Knowledge Proofs: Processing data without exposing personal information
• Homomorphic Encryption: Computations on encrypted data
• Privacy-Preserving Analytics: Aggregate insights without individual identification
• Secure Multi-Party Computation: Collaborative processing with privacy protection

• Right to Information: Clear explanation of data processing
• Right of Access: Copies of your personal data and processing details
• Right to Rectification: Correction of inaccurate or incomplete data
• Right to Erasure: Deletion of personal data (subject to blockchain limitations)
• Right to Restrict Processing: Limitation of specific processing activities
• Right to Data Portability: Transfer of data in machine-readable format
• Right to Object: Opposition to processing based on legitimate interests
• Rights Related to Automated Decision-Making: Information about algorithmic processing

Contact Methods:

• Email: privacy@d-gn.io
• Online Form: Available in your account dashboard
• Postal Mail: Data Guardian Tech Ltd., Attention: Privacy Officer, Rough Point, P.O. Box 4203, Mount Healthy, Road Town, Tortola, VG1110, British Virgin Islands
• Response Timeline:
• Standard requests: 30 days
• Complex requests: Up to 60 days (with notification)
• Identity verification may be required for security

• EU residents may lodge complaints with their local data protection authority if unsatisfied with our response to privacy concerns.

• Encryption: AES-256 encryption for data at rest and TLS 1.3 for data in transit
• Access Controls: Role-based permissions and multi-factor authentication
• Network Security: Firewalls, intrusion detection, and DDoS protection
• Regular Audits: Penetration testing and security assessments

• Staff Training: Regular privacy and security awareness programs
• Data Minimization: Collection and retention limited to necessary purposes
• Incident Response: Documented procedures for data breach management
• Vendor Management: Security requirements for all service providers

In the event of a personal data breach:

• Supervisory Authority: Notification within 72 hours (where required)
• Affected Individuals: Direct notification when high risk of harm
• Documentation: Detailed records of breach circumstances and response
• Remediation: Immediate steps to contain and mitigate impact

• Voice/Facial Data: Retained for AI training purposes unless deletion requested
• Account Information: Maintained while account is active plus 2 years
• KYC Documents: 7 years from last transaction (regulatory requirement)
• Platform Logs: 12 months for security and troubleshooting
• Communication Records: 3 years for support and legal purposes

Upon retention period expiration or valid deletion request:

• Physical Destruction: Secure overwriting of storage media
• Cryptographic Deletion: Encryption key destruction for blockchain-referenced data
• Third-Party Notification: Instructions for service providers to delete data
• Verification: Documentation of successful deletion procedures

• Minimum Age: 18 years for independent participation
• 13-17 Years: Permitted with verifiable parental consent
• Under 13: Prohibited from platform use

For users aged 13-17:

• Consent Verification: Documented parental permission required
• Limited Data Collection: Reduced data processing for minors
• Enhanced Protections: Additional security measures for minor accounts
• Parental Access: Parents may request information about child's account

• Strictly Necessary: Essential for platform functionality (no consent required)
• Performance: Analytics and platform improvement (consent required)
• Functional: Enhanced user experience features (consent required)
• Targeting: Personalized content and marketing (consent required)

• Consent Banner: Clear options to accept or reject non-essential cookies
• Preference Center: Granular control over cookie categories
• Browser Controls: Instructions for browser-level cookie management
• Regular Updates: Periodic consent renewal and preference confirmation
• For detailed cookie information, see our separate Cookie Policy.

We may update this Privacy Policy to reflect:

• Changes in data processing practices
• New legal requirements or regulatory guidance
• Platform features and service improvements
• Feedback from users and privacy authorities

Updates will be communicated through:

• Email notification to registered users
• Platform notifications during login
• Website posting with effective date
• Version history maintained for transparency

• Continued use of the platform after policy updates constitutes acceptance of changes. For material changes affecting your rights, we may require explicit consent.

• Email: privacy@d-gn.io
• Response Time: 5 business days for initial acknowledgment

• Email: support@d-gn.io
• Community: Discord and Telegram channels available

• Data Guardian Tech Ltd.
• Attention: Privacy Officer
• Rough Point, P.O. Box 4203
• Mount Healthy, Road Town
• Tortola, VG1110, British Virgin Islands

For EU-related privacy matters, our European representative can be contacted at: eu-privacy@d-gn.io This Privacy Policy demonstrates our commitment to protecting your personal data and ensuring transparent, lawful processing in compliance with applicable privacy laws. Your participation in D-GN Speak2Earn is voluntary, and you maintain control over your personal data throughout your journey with us.