Privacy Policy

ENS VISION PTE. LTD., (/”We”/”Us”/”Our”/”ENS Vision”/"Vision.io"/"Vision") is the owner of www.vision.io (the “Website”) and is committed to respecting and protecting the privacy of the Website’s Users’ (“You”/”Your”) privacy. We are considered to be the Data Controller of any Personal Data which You provide to Us in terms of this privacy policy (the “Policy”/”Privacy Policy”). This policy governs the way in which we process Personal Data. As a company based in Singapore, we are subject to the Personal Data Protection Act 2012 (PDPA). However, because we serve users around the world, we also aim to comply with other relevant data protection regulations, including the General Data Protection Regulation (GDPR) for users in the European Economic Area (EEA), the UK GDPR, and the California Privacy Rights Act (CPRA). This Privacy Policy explains how we collect, use, disclose, and protect personal data in the course of providing our services. It also outlines the choices and rights you have regarding your personal information.

We encourage you to read this Privacy Policy and our Privacy Notice in full to understand how your personal data is handled. If you have any questions or concerns, please contact us at [e-mail].

1. Data Collection and Usage

We will retain and use your information to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our policies.

At Vision.io, we prioritize transparency regarding the data we collect and how it's utilized. As a non-custodial user interface (UI) platform facilitating interactions with the Ethereum Name Service (ENS), we collect specific data to ensure the functionality and security of our services.

We process information about and/or related to you to run our business, provide the Service, personalize your experience on the Service, and improve the Service. Specifically, we use your information to:

• provide, operate and maintain the Service;

• improve and analyze the Service;

• investigate, address, and prevent conduct that may violate our Terms of Service and/or that is otherwise harmful or unlawful;

• comply with applicable laws, cooperate with investigations by law enforcement or other authorities of suspected violations of law, and/or to protect our and our Affiliates’ legal rights; and

• act in any other way which we have communicated to you and to which you have consented or we may describe when you provide your information.

We generally do not collect your personal data unless:

(a) it is provided to us voluntarily by you or via a third party duly authorised by you to disclose your personal data, after you have been notified of the purposes for which the data is collected and you have provided your written or deemed consent to such collection and use; or

(b) such collection and use without consent is permitted or required under applicable law.

2. Types of Information We Collect

a. Information You Provide Us:

• Wallet Signature for Terms of Service Agreement: When you connect your Ethereum wallet to our platform, you are prompted to sign our Terms of Service. This cryptographic signature serves as your explicit agreement to our terms and is securely stored in our database. This process ensures Verification of your consent to our Terms of Service. Your provision of such information constitutes consent to our collection and use of it for the relevant purposes as described herein.

• Account Information: We do not collect or store public Ethereum Name Service information (such as Public ENS Records) which may include social media links, Twitter Handles, Contact Information or any other information you publicly set on the blockchain on our servers. Any data you associate with your ENS (Ethereum Name Service) domain, such as linked accounts or preferences, is stored directly on the Ethereum blockchain as part of the public ENS records. This information is not controlled or retained by Vision. Please note that because this data is stored on a decentralized public ledger, it may remain publicly accessible even if you remove or update it through your ENS account!

• Feedback. If you provide us with feedback or contact us directly (e.g., by email), we may receive your name, email address, and any other information you voluntarily include in your message. We use ProtonMail, a secure, end-to-end encrypted email service, to handle feedback communications. This ensures that your correspondence with us is protected through strong encryption protocols while in transit and at rest.

• Support Requests: If you provide us with feedback or contact us for support through our support portal, we may receive your name, email address, and any other information you voluntarily include in your message. We use Jira Service Desk (by Atlassian) to manage tickets and communications. Information submitted through Jira may include your email address and, optionally, your name if provided. This data is not stored on our servers but is securely processed and retained within Jira’s cloud infrastructure, in accordance with Atlassian’s privacy and security standards.

• Notification Preferences (Opt-In): We offer optional, opt-in notification features to help you stay informed about domain sales, domain expiry reminders, bids and related updates. These services are provided only with your explicit consent and can be unsubscribed from at any time.

  • Telegram Chat IDs: When you connect with our Telegram bot to receive updates, sales notifications, or domain expiry reminders, your Telegram Chat ID is collected and stored securely for the duration of your active connection to the bot. This identifier is used solely to deliver relevant notifications while you remain subscribed. You may unsubscribe at any time via the bot interface, which will delete your Telegram Chat ID from our system.

  • E-Mail Notifications: If you choose to receive notifications via email, we will collect and store your email address securely and in encrypted form within our database. Your email address is used exclusively for the purpose of sending opt-in communications, such as:

    • Domain sales/bids notifications

    • Expiry or renewal reminders

    You may withdraw your consent and unsubscribe from these emails at any time using the unsubscribe link provided in the message or by contacting us at [e-mail]. We do not use your email or Telegram information for any unrelated marketing or third-party sharing.

• Watchlist & Favorite Items: As part of your user experience on Vision.io, you can add domains to your watchlist or mark items and collections as favorites. This feature allows you to easily track domains and collections you're interested in. The information you select is tied to your account and is securely stored in our database. It is not publicly visible and is used solely to personalize and enhance your experience on the platform.

• Wallet Address: Additionally, like much of Web3, your blockchain wallet address functions as your identity on Vision.io. Accordingly, you will need a blockchain wallet address and a third-party wallet to access certain aspects of the Service. We do not consider a blockchain wallet address, standing alone, to be information that identifies you. However, a blockchain wallet address may become associated with you or information you provide when you use our Service.

b. Information Collected Automatically

As you navigate through and interact with our Service, we may use automatic data collection technologies to collect certain information, including:

• Interactions with our Service: To deliver and improve our Service, analyze usage trends, enforce our Terms of Service, and enhance user experience, we collect certain information when you interact with our platform. This typically includes anonymized data such as your browser type or fingerprint, operating system, IP address and approximate geolocation, device ID, blockchain wallet address and type, user actions and clickstream data, referring and exit pages, and timestamps. This data may also be stored in log files for analytical and operational purposes.

• Cookies and Other Tracking Technologies: We use essential cookies only. This includes both session cookies, which expire when you close your browser and automatically expiring cookies, read more here.

c. Information Collected from Third-Party Companies

We may receive or reference publicly available information related to your wallet address from third-party services or blockchain networks. This information may include, for example:

• Third-party wallet providers that provide us with your blockchain wallet address and certain other information you choose to share with those wallet providers

We do not control or access the data collected directly by these third-party services, but we only use providers that align with high data protection and security standards.

d. Public Information

We collect data from activity and information that is publicly visible and/or accessible on blockchains or other public sources. This may include, for example, blockchain wallet addresses, public records and information regarding purchases, sales, or transfers of NFT domains, which may then be associated with other data you have provided to us.

This includes data stored on-chain, such as activity linked to the Ethereum Name Service (ENS). For example, we reference the following ENS-related on-chain activity to support functionality and enhance the user experience on our platform:

• Domain Transfers: Monitoring the transfer of ENS domains between wallet addresses.

• Domain Registrations: Detecting the registration of ENS domains on the Ethereum blockchain.

• Record Settings: Displaying updates made to domain records (e.g., wallet addresses, avatars, or other public metadata) stored on ENS.

This information is gathered from the public Ethereum blockchain.

Information Related to Your Public Activity: We may display or share information relating to your public activity on blockchains and Vision. For example, we use technology like APIs to make certain information like your blockchain activity available to websites, apps, and others for their use.

This data collection enables us to:

• Ensure compliance with applicable laws and regulations.

3. Data Storage and Security

We are committed to protecting the security of your personal data and implement reasonable physical, administrative, and technical safeguards to maintain the integrity and confidentiality of any information collected through our Service. These measures are designed in accordance with the requirements of the Personal Data Protection Act 2012 (PDPA) of Singapore. While we take reasonable steps to protect your data, no security system is entirely immune to risk. Therefore, we cannot guarantee absolute security of our systems or those of our service providers. In the event of a data breach involving personal data under our custody or control, we will assess the situation promptly and, where required under applicable laws, notify the affected individuals and the Personal Data Protection Commission (PDPC) in a timely manner.

Please note that you are responsible for the security of your digital wallet, and we strongly encourage you to take necessary precautions to protect your private keys and credentials. If you become aware of any issue affecting your wallet, please contact your wallet provider directly.

All personal data collected by us is stored securely using appropriate technical and organizational measures to prevent unauthorized access, alteration, disclosure, or destruction. We retain such data only for as long as necessary to fulfill the purposes stated in this policy, or as required by applicable law.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

4. Data Access and Control & User Rights

We are a Data Controller of your information.

Vision.io legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Information we collect and the specific context in which we collect the information:

• Legitimate interests: Processing is necessary for our legitimate business interests, such as improving our services, detecting fraud, or securing our platform, and is not overridden by your data protection rights.

• Legal obligations: The processing is necessary to comply with a legal obligation applicable to us (e.g., anti-money laundering regulations, consumer protection laws).

In cases where we rely on the legitimate interests exception under the PDPA to collect, use, or disclose your personal data, we will conduct a careful evaluation of the potential adverse effects on you and determine that our legitimate business interests outweigh those effects. Specifically:

• the personal data involved (e.g. wallet addresses and usage behaviour) is non-sensitive in nature and is not used to make decisions that will have legal or significant effects on individuals;

• data collected through tools such as Google Analytics is anonymised or pseudonymised where possible, and is used solely for improving platform performance, diagnosing issues, and enhancing user experience;

• individuals are not subject to profiling, tracking for advertising purposes, or decision-making based solely on automated processing; and

• Reasonable safeguards, including data minimisation, encryption, access control, and purpose limitation, are in place to mitigate any risks of unauthorised access or harm.

You may submit a request to access or correct your personal data in our possession or under our control by writing to our Data Protection Officer at the contact details below. We will respond to your request as soon as reasonably possible, generally within 30 days. If we are unable to do so within that period, we will inform you in writing of the time by which we will respond. A reasonable administrative fee may apply for access requests.

If you wish to withdraw your consent to our continued use or disclosure of your personal data, you may do so by contacting our Data Protection Officer. Upon receiving your request, we will inform you of the likely consequences and aim to process your request within 7 business days. Withdrawal of consent will not affect our right to continue to collect, use and disclose personal data where permitted or required under applicable laws.

We generally rely on personal data provided by you. To ensure your data is current and accurate, please update us if there are any changes to your personal data.

a. Personal Data Protection Act (PDPA) Compliance

Under the Personal Data Protection Act of Singapore, we endeavor to protect your personal information. Our collection, use, and disclosure of personal data are conducted with due regard to consent provided by you and in line with legal allowances. You may request access to and rectification of your personal data; however, such requests will be subject to verification and compliance processes.

b. General Data Protection Regulation (GDPR)

We acknowledge the GDPR standards for users from the EEA, UK, and Switzerland and aim to align our practices accordingly. Subject to our assessment of the legal basis and necessity for processing as permitted within the scope of GDPR provisions. If you are a user in the European Economic Area (“EEA”), United Kingdom (“UK”) or Switzerland, you have certain rights under applicable law.

(i) Rights of EEA Residents Under GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

• The right to access, update or to delete the information we have on you.

• The right of rectification.

• The right to object.

• The right of restriction.

• The right to data portability

• The right to withdraw consent

Additionally, if we have collected and processed your personal information with your consent, you have the right to withdraw your consent at any time.

(ii) Privacy Rights Under the California Privacy Rights Act (CPRA)

If you are a California resident, you have certain rights under the California Privacy Rights Act ("CPRA"). These include the right to (i) request access to, details regarding, and a copy of the personal information we have collected about you and/or shared with third parties; (ii) request deletion of the personal information that we have collected about you; and (iii) the right to opt-out of sale of your personal information. As the terms are defined under the CPRA, we do not "sell" your "personal information." California Privacy Rights Disclosure: - The categories of personal information we collect about users, as described above , include: (1) identifiers, (2) internet or online identifiers, (3) geolocation data, and (4) information derived from other personal information about you. - The categories of sources from which the personal information is collected are described above in Section 2. - The business purpose for collecting personal information is described above in Section 2b. - The categories of personal information we share with third parties, as described above in Section 2c, include: (1) identifiers,(2) internet or online identifiers, (3) geolocation data, and (4) information derived from other personal information about you.

(iii) Other Regional Privacy Rights

We aim to comply with applicable data protection laws in all jurisdictions in which we operate. If you reside in a country with specific data protection rights not explicitly covered in this notice (such as Brazil’s LGPD, Canada’s PIPEDA, or the United Kingdom’s UK GDPR), you may still contact us to inquire about or exercise your privacy rights.

c. International Data Transfer

We may conduct international data transfers in a manner that is compliant with prevailing data protection laws. Data transfers from the EEA, UK, or Switzerland to other regions are executed under protections like Standard Contractual Clauses. Nonetheless, such transfers will be optimized for operational efficiency and may be subject to exemptions under applicable legal frameworks. “Standard Contractual Clauses” are a set of legal tools approved by the European Commission, as specified under Article 46(2) of the General Data Protection Regulation (GDPR), to ensure the protection of personal data transferred from within the European Economic Area (EEA) to countries that have not been deemed to provide an adequate level of data protection. These contractual clauses bind the data importer to comply with EU data protection standards, thereby safeguarding transferred data. Our company commits to the application of SCCs for any personal data transfer to third countries, in compliance with the GDPR, ensuring enforceable rights and legal remedies for data subjects.

5. Disclosure of Your Information

We may disclose your information as outlined below:

a. Legal Compliance and Protection

We may disclose your information if we believe in good faith that it is necessary to:

• Comply with laws, legal processes, or governmental requests (e.g., subpoenas or warrants)

• In connection with any legal investigation

• Investigate or address illegal activity or violations of our Terms of Service

• To investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service

• Protect the rights, safety, or property of ENS Vision, our users, or others

b. Other Disclosures

We may also disclose your information:

• To fulfill the purpose for which you provided it

• As otherwise disclosed at the time of collection

• for any other purpose disclosed by us when you provide it

• with your consent

6. Log Files

Vision.io follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services & analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users & movement on the website, and gathering demographic information.

7. Third-Party Websites

Our Service may contain links to third-party websites (f.E. Afternic.com). When you click on a link to any other website or location, you will leave our Service and go to another site, and another entity may collect information from you.

We have no control over and cannot be responsible for these third-party websites or their content. Please be aware that this Privacy Policy does not apply to these third-party websites or their content, or to any collection of your information or information about you after you click on links to such third-party websites.

We encourage you to read the privacy policies of every website you visit. Any links to third-party websites or locations are for your convenience and do not signify our endorsement of such third parties or their products, content, or websites.

Afternic Affiliate Link-Outs: Please note that any transactions conducted on Afternic are subject to Afternic's own terms of service and privacy policies. We encourage users to review Afternic's policies to understand how their data is handled during such transactions. Vision.io does not collect or store any personal information related to transactions completed on Afternic. Our involvement is limited to providing the affiliate link-outs for user convenience.

Note that Vision.io has no access to or control over these cookies that are used by third-party advertisers.

8. Third Party Wallets

To access certain features of our Service, you will need to use a third-party wallet that enables transactions on public blockchains. Please note that your use of any third-party wallet is subject to that provider’s own terms of service and privacy policy. We do not control and are not responsible for the practices of these third-party services.

9. Cookies

Our website uses only essential cookies that are strictly necessary for core functionality, such as secure login and session management. These cookies cannot be disabled via our site, as they are required for the Service to operate properly. Find our Cookie Policy here.

However, you can manage cookies generally by adjusting your browser settings. This may allow you to disable all cookies or receive a prompt before a cookie is stored. Please note that disabling cookies through your browser may impact the availability or functionality of some features.

10. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required for legal or business purposes, in accordance with the Personal Data Protection Act 2012 of Singapore. In some cases, we may continue to retain your information even after a deletion request, if such retention is reasonably necessary to:

• Comply with our legal obligations,

• Resolve disputes,

• Prevent fraud or abuse,

• Enforce our Terms or other agreements, or

• Protect our legal rights and interests.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.

We may continue to retain your information or information about you even after you request deletion of your data if such retention is reasonably necessary to comply with our legal obligations, to resolve disputes, prevent fraud and abuse, enforce our Terms or other agreements, and/or protect our legal rights and other interests.

11. Children’s Privacy and Age Restrictions

Vision.io is committed to protecting the privacy of children and complying with applicable laws and regulations.

• Age Restriction: Our services are intended for individuals who are at least 18 years old. By accessing or using Vision.io, you affirm that you are at least 18 years of age.

• Prohibition for Minors: We do not knowingly collect or solicit personal information from individuals under the age of 18. If we become aware that we have collected personal data from a person under 18 without verification of parental consent, we will take steps to delete that information promptly.

• Parental Guidance: We encourage parents and legal guardians to monitor their children's internet usage and to help enforce our Privacy Policy by instructing their children never to provide personal information through our services without permission.

• Contacting Us: If you believe that we might have any information from or about a child under 18, please contact us at [e-mail], and we will promptly take appropriate actions.

12. Users

a. Users Outside of Singapore

If you are a non-Singaporean user of the Service, by visiting the Service and providing us with information directly or indirectly, you understand and acknowledge that your information and information about you may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of your information or information about you may be less stringent than the laws in your own country.

b. Users in EEA, UK and Switzerland

Legal Bases for Processing Personal Data. When you access or use the Service, we collect, use, share, and otherwise process your personal data for the purposes described in this Privacy Policy. We rely on a number of legal bases to use your information in these ways.

• We process your personal data with your consent, for example, to: communicate with you; send you email notifications; and for any other purpose that we communicate to you and to which you have consented.

• We process your personal data in order to fulfill our contract with you and to provide you with our Service, for example, to: provide, operate and maintain the Service; and investigate, address, and prevent conduct that may violate our Terms of Service.

• We process your personal data pursuant to legitimate interests, for example, to: improve and analyze the Service; and personalize your experience on the Service.

• We process your personal data in order to comply with legal obligations, in the public interest, or in your vital interests, for example, to: detect, prevent, and address activities that we consider could be fraudulent, violations of our Terms of Service or policies, and/or otherwise harmful or unlawful.

We will use appropriate safeguards for transferring your personal data out of the EEA, UK and Switzerland where required and only transfer such personal data under a legally valid transfer mechanism.

13. Transfer of Personal Data outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

14. Online Privacy Policy Only

Our Privacy Policy applies only to our online activities and is valid for visitors to our website with regards to the information that they shared and/or collect in Vision.io. This policy is not applicable to any information collected offline or via channels other than this website.

15. Changes to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy at https://docs.vision.io/privacy-and-terms/privacy-policy The date the Privacy Policy was last revised is identified at the end of this Privacy Policy. You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.

16. Data Protection Officer

ENS Vision maintains internal policies and procedures to ensure ongoing compliance with the PDPA. This includes regular staff training on data protection, audits of data handling practices, documentation of data processing activities, and periodic policy reviews. Our Data Protection Officer oversees compliance and serves as the point of contact for any privacy-related issues. If you have any questions or concerns about our data protection practices, please contact our DPO Mr. Austin at [e-mail] or [e-mail].

17. Data Breach Notification

Should a data breach occur, our policy is to inform affected parties and the relevant authorities in line with statutory obligations. The notification will outline the breach’s scope and the remedial actions undertaken. However, such notification is contingent upon a thorough verification of the breach and its impacts, in accordance with the legal definitions and thresholds of data breaches. Where required, we will notify the affected individuals and the relevant authorities as soon as practicable and no later than 3 calendar days upon determining that the breach is notifiable.

18. Contact, Questions, Reporting Violations

If you wish to exercise your rights under an applicable data protection or privacy law, please contact us via [e-mail], specify your request, and reference the applicable law. We may ask you to verify your identity, or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.

• If you believe that we have infringed your rights, we encourage you to first contact us via [e-mail] so that we can try to resolve the issue or dispute informally.

Read further details in our Privacy Notice.

19. Governing Law

This Privacy Policy is governed and construed in accordance with the laws of Singapore. We may choose either:

1. The courts of Singapore. Any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity or termination shall be resolved by the courts of Singapore; or

2. Binding Arbitration. Any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of arbitration shall be Singapore. The Tribunal shall consist of one (1) arbitrator. The language of the arbitration shall be English.

20. User Consent

By using our website, you hereby consent to our Privacy Policy and our Privacy Notice and agree to its terms and our T&S. Where additional consent is required for specific data processing activities, we will seek such consent in accordance with regulatory requirements. Your continued use of the Service constitutes ongoing consent. If you have any questions or concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us via [e-mail].

___ Updated 06/2025