Draft template. This page has not been reviewed by a lawyer and is not legal advice. It must be reviewed and completed by qualified counsel before anyone relies on it.
Privacy notice
Last updated: 2 October 2026.
This notice explains what personal data the Kasumi website and relay process, why, and what rights you have under the EU and UK General Data Protection Regulation (GDPR, in French RGPD).
Who is responsible
Data controller: [legal entity and contact to be completed]. Until that is completed there is no named controller, and this notice describes the processing only.
What is processed
| Data | Where it comes from | Why |
|---|---|---|
| IP address, user agent, request time and path | Every request, logged by the hosting provider. The relay also counts orders per IP address per epoch. | Serving the site, security, rate limiting. |
| Sealed orders: ciphertext, its hash, a salted commitment, the epoch number and arrival time | Sent by your browser when you submit an order. | Operating the batch auction. Before the epoch is decrypted this cannot be linked to a wallet or read by Kasumi. |
| Decrypted orders: wallet address, market, side, size, limit price, fills | Readable by anyone once the epoch's decryption round is published. | Matching and settlement. This data is public by design after the epoch closes. |
| Wallet address, balances and allowances | Read from the public blockchain when the terminal asks for your account. | Showing balances and checking that an order can settle. |
| Email address or wallet used to log in | Collected by Privy when you connect in the terminal. | Wallet login and embedded wallet creation. |
| Order history and your cookie choice | Stored in your own browser. Not sent to Kasumi. | Showing your orders and remembering your choice. |
Kasumi does not sell personal data and does not use it for advertising.
Legal bases
- Performance of a contract, or steps at your request: accepting, matching and settling the orders you submit.
- Legitimate interests: keeping the service secure and available, preventing abuse.
- Consent: any optional analytics, which are not in use today. You can withdraw consent at any time in Cookie settings.
- Legal obligation: where a law requires records to be kept or disclosed.
Processors and recipients
- Vercel: hosting and request logs.
- Neon: the database behind the relay.
- Privy: wallet login and embedded wallets.
- drand: a public randomness network. Kasumi reads its beacon; no personal data is sent to it.
- Public blockchains (Robinhood Chain): settlement transactions and anything they contain are public and visible to everyone.
Retention
- Relay epoch data (ciphertexts, commitments, decrypted results): about 36 hours in the relay store, then deleted.
- Rate-limit counters: about two epochs.
- Hosting logs: according to the hosting provider's retention.
- Blockchain data: permanent. It cannot be altered or erased by Kasumi or anyone else.
- Browser storage: until you clear it or use Clear history in the terminal.
International transfers
The processors above may store or access data outside the European Economic Area and the United Kingdom, including in the United States. Where they do, transfers should rely on an adequacy decision or standard contractual clauses. [Transfer mechanism to be confirmed with each processor.]
Your rights
You have the right to access your data, correct it, erase it, restrict or object to its processing, receive it in a portable form, and withdraw consent. You can also complain to your data protection authority, for example the CNIL in France or the ICO in the United Kingdom.
One limit applies: data written to a public blockchain cannot be erased or corrected. Think about that before you trade from an address that identifies you.
To exercise a right, contact: [contact to be completed].
Related
Cookies and local storage, what Kasumi hides and what it does not.