Symfalogic Corporation LLC & Symfalogic Ecosystem Ltd
Effective Date: April 1, 2026
1. Introduction — Who We Are
This Privacy Policy explains how Symfalogic Corporation LLC, a limited liability company registered in the United States of America (8 The Green, Suite A, Dover, DE 19901, USA), and its subsidiary Symfalogic Ecosystem Ltd, a company registered in England and Wales ( 293 Sugar Mill Business Park, Oakhurst Avenue, Leeds, LS11 7HL, United Kingdom), (collectively referred to as "Symfalogic," "we," "us," or "our") collect, use, store, share, and protect personal data in connection with the SYMGATE token and our wider service ecosystem.
Symfalogic Corporation LLC and Symfalogic Ecosystem Ltd act as joint data controllers for the
processing activities described in this Policy. Both entities share responsibility for ensuring compliance with applicable data protection legislation, including the UK General Data Protection Regulation (UK GDPR), the EU General Data Protection Regulation (EU GDPR), and relevant United States federal and state privacy laws.
SYMGATE is an ERC-20 utility token deployed on the Arbitrum network. It functions exclusively as a digital access key and VIP membership pass within the Symfalogic service ecosystem. SYMGATE is not an investment product, security, share, or any form of ownership interest in Symfalogic or any affiliated entity. By interacting with our website, purchasing or holding SYMGATE tokens, or using any Symfalogic services, you acknowledge that you have read and understood this Privacy Policy.
2. What Data We Collect
We may collect and process the following categories of personal data:
2.1 Identity and Contact Data
• Full name, email address, business name, and other contact details you provide during
registration or service onboarding.
2.2 Wallet and Blockchain Data
• Public blockchain wallet addresses that you connect to our platform or use to interact with
SYMGATE tokens.
• On-chain transaction data, including token transfers, balances, and smart contract interactions
publicly recorded on the Arbitrum blockchain.
2.3 KYC/AML Data
• Where applicable, government-issued identification documents, proof of address, and other
information required to comply with Know Your Customer (KYC) and Anti-Money Laundering
(AML) regulations.
2.4 Usage Data
• Information about how you access and use our website and services, including IP address,
browser type, operating system, referral URLs, pages visited, time spent on pages, and click
patterns.
2.5 Transaction and Service Data
• Records of token purchases, service orders, VIP status determinations, invoices, payment
details, and customer support interactions.
2.6 Communication Records
• Content and metadata of emails, messages, and other communications between you and
Symfalogic.
3. How We Collect Data
We collect personal data through the following means:
• Website interaction: When you visit [www.symgate.io or www.symfalogic.com], complete forms, create an account, or submit inquiries.
• Token purchase and wallet connection: When you acquire SYMGATE tokens or connect your
cryptocurrency wallet to our platform.
• Service onboarding: When you register for Symfalogic consulting services or other products.
• Blockchain monitoring: By reading publicly available on-chain data from the Arbitrum network to verify token holdings, process VIP status, and ensure service eligibility.
• Email and messaging: When you communicate with us via [info@symgate.io] or other channels.
• Cookies and analytics: Through cookies and similar technologies deployed on our website
• Third parties: We may receive data from KYC/AML service providers, blockchain analytics
providers, or public registers where permitted by law.
4. Legal Basis and Purposes of Processing
We process personal data only where we have a valid legal basis under applicable data protection law. The table below sets out our purposes and corresponding legal bases.
4.1 Performance of a Contract
• To facilitate SYMGATE token transactions and manage your account.
• To provide and deliver Symfalogic consulting and related services.
• To determine and administer VIP status based on token holdings.
4.2 Legal Obligation
• To comply with KYC/AML requirements and other applicable regulations.
• To respond to lawful requests from regulatory or law enforcement authorities.
• To maintain legally required financial and tax records.
4.3 Legitimate Interest
• To maintain the security and integrity of our platform and services.
• To analyze usage patterns for service improvement and fraud prevention.
• To communicate updates about SYMGATE and Symfalogic services.
4.4 Consent
• To send marketing communications (where not covered by legitimate interest).
• To deploy non-essential cookies for analytics purposes.
Where processing is based on consent, you may withdraw your consent at any time by contacting us at [info@symgate.io]. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
5. Blockchain Data Disclaimer
SYMGATE is an ERC-20 token on the Arbitrum blockchain, a public, decentralized, and distributed ledger. You should be aware of the following:
• Public visibility: All transactions on the Arbitrum network — including wallet addresses, token
transfers, and balances — are permanently and publicly recorded on the blockchain. Anyone with access to a blockchain explorer can view this data.
• Immutability: Blockchain transactions cannot be altered, reversed, or deleted once confirmed. This is an inherent characteristic of blockchain technology and is outside Symfalogic's control.
• No erasure of on-chain data: While Symfalogic will honour your data protection rights with
respect to data held in our off-chain systems, we cannot modify or erase data recorded on the
Arbitrum blockchain. This limitation applies to any request for erasure or rectification of on-chain data under Article 17 or Article 16 of the GDPR.
• Pseudonymity, not anonymity: Wallet addresses are pseudonymous. While they do not
inherently reveal personal identity, they may be linked to an individual if associated with other
identifying information. By acquiring or transacting in SYMGATE tokens, you acknowledge and accept the public, permanent, and immutable nature of blockchain data.
6. VIP Status System — Token Holding Data
Symfalogic operates a VIP membership system whereby clients who hold the required amount of SYMGATE tokens in a connected wallet are granted VIP status and associated priority access to Symfalogic services.
6.1 How It Works
• When you connect your wallet to our platform, we periodically query the Arbitrum blockchain to verify your SYMGATE token balance.
• If your balance meets or exceeds the published threshold, your account is automatically flagged for VIP status.
• VIP status is reassessed at regular intervals. If your token balance falls below the required
threshold, VIP privileges may be suspended or revoked.
6.2 Data Processed
• Your connected wallet address(es).
• Current SYMGATE token balance (read from the public blockchain). SYMGATE Privacy Policy
• VIP status determination outcome and timestamps.
6.3 Legal Basis
This processing is necessary for the performance of the contract between you and Symfalogic - specifically, to administer and deliver the VIP membership benefits to which you have subscribed.
7. Data Sharing and Third Parties
We may share personal data with the following categories of recipients:
• Between Symfalogic entities: Data may be shared between Symfalogic Corporation LLC and
Symfalogic Ecosystem Ltd for the purposes described in this Policy.
• Blockchain infrastructure providers: Including node operators, RPC providers, and blockchain
analytics services that facilitate interaction with the Arbitrum network.
• KYC/AML service providers: Where identity verification is required, we may share relevant data
with third-party KYC/AML processors acting on our behalf.
• Professional advisers: Including lawyers, auditors, accountants, and insurers who provide
consultancy, banking, legal, insurance, and accounting services.
• Regulatory and law enforcement authorities: Where required by applicable law, court order, or regulatory directive.
• Technology service providers: Including hosting, cloud storage, email delivery, and analytics
providers who process data on our behalf under appropriate data processing agreements.
We do not sell, rent, or trade your personal data to third parties for marketing purposes.
8. International Data Transfers
Given that Symfalogic operates through entities in both the United States and the United Kingdom, personal data may be processed and stored in either jurisdiction.
Where personal data is transferred from the UK or the European Economic Area to the United States or any other country that has not been deemed to provide an adequate level of data protection, we implement appropriate safeguards, which may include:
• Standard Contractual Clauses (SCCs) approved by the European Commission or the UK
Information Commissioner's Office (ICO).
• The UK International Data Transfer Agreement (IDTA) or UK Addendum to the EU SCCs.
• Binding corporate rules or other legally recognized transfer mechanisms.
You may request a copy of the applicable safeguards by contacting us at [info@symgate.io].
9. Data Retention
We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. The following retention periods apply:
• Account and identity data: Retained for the duration of your relationship with Symfalogic and for six (6) years thereafter, in accordance with applicable limitation periods and financial
record-keeping obligations.
• KYC/AML data: Retained for a minimum of five (5) years following termination of the business
relationship, or longer if required by applicable law.