Privacy Policy
Last modified: October 22, 2025
This Privacy Policy (the "Policy") explains how Risk Labs ("Across," "we," "us," or "our") collects, uses, and shares data in connection with the Across web app (app.across.to), www.across.to website, our APIs, and all of our other properties, products, and services (the "Services"). Your use of the Services is subject to this Policy as well as our Terms of Service.
High Level Summary
  • Across is operated by Risk Labs, a Cayman Islands Foundation.
  • The Across Protocol is not centrally controlled by Risk Labs. It is a decentralized protocol with smart contracts deployed across various blockchains.
  • Across does not collect or store certain personal data such as first name, last name, street address, date of birth, or government ID in connection with your use of the Services.
  • Across may collect limited data, such as public on-chain data and off-chain data like internet protocol ("IP") address, device type, and browser type. This is done to improve user experience and maintain security, not to track or profile individual users.
  • If you sign up to receive emails from us, we will store your email address solely for communication purposes. You can unsubscribe from our emails at any time. We will not link your email address to your wallet address or other personal data.
  • Users are encouraged to explore client-side privacy techniques and tools.
  • Any material changes to this Policy will be reflected in an updated version of this document.
  • We work with third parties, who may have their own privacy policies; users are encouraged to review the respective privacy policies of these third parties.
Data We Collect
We take privacy seriously and are transparent about what limited data we collect. We do not maintain user accounts and do not collect and store personal data, other than your email address, IP address, and device type. When you interact with the Services, we may collect:
  1. Publicly-available blockchain data. When you connect your blockchain wallet to the Services, we may collect and log your publicly-available blockchain address and screen it for any prior illicit activity. Blockchain addresses are public data not created or assigned by us.
  2. Information from other sources. We may receive information about your wallet address or transactions from third-party providers to comply with legal obligations and prevent fraudulent or other illicit activity.
  3. Information collected automatically via cookies and tracking technologies. When you visit our websites, we may collect certain information by automated means, such as through the use of cookies, web beacons and tracking technologies. We use this information we collect by automated means to provide and personalize the Services and features of the Services for you, learn about your preferences, your use of the Services, and our interactions with you. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.
  4. Survey or usability information. If you participate in surveys or usability studies, we collect the responses and any information you voluntarily provide (such as wallet address, email address, and social handles including discord, twitter, and telegram).
  5. Correspondence. We receive any information you provide when contacting us by email, customer support, or social media. This includes opting into our newsletter and receiving emails from us.
  6. Biographical information. If you apply for a job with us, we collect information such as your name, email, phone, work and immigration status, and any other information you provide in application materials.
  7. Information you choose to provide. If you provide us with data (e.g., your email), we use it for the purposes described at the time. We do not attempt to link this to your wallet or other identifiers.
How We Use Data
We use the data we collect in accordance with your instructions, our Terms of Service, and as required by law. Our other uses of data include:
  • Providing the Services. To operate, maintain, and improve our Services.
  • Customer support. To respond to inquiries and provide assistance to users.
  • Safety and security. To detect, investigate, and prevent fraud, unauthorized use, or illegal activity; to enforce our rights, agreements, and policies; and to address potential security risks, and to protect users, the protocol, and the broader ecosystem.
  • Legal compliance. To comply with applicable laws and regulations, and to respond to lawful requests from regulators, law enforcement, or court orders.
  • Aggregated data. To analyze aggregated usage trends so as to improve the user experience.
  • Hiring. To recruit and hire talent.
We retain each category of personal information that we collect for as long as necessary to fulfill the purposes described herein.
How We Share Data
We may share data as follows:
  • With service providers. For infrastructure, analytics, compliance, and support (e.g., Infura, Cloudflare, blockchain analytics providers) to provide, deliver, and improve the Services.
  • For legal reasons. To comply with laws, regulations, legal processes, or enforce our rights, agreements, and policies.
  • For safety and security. To detect, investigate, and prevent fraud, unauthorized use, or illegal activity; to address potential security risks; to protect users, the protocol, and the broader ecosystem; including as necessary or appropriate to prevent physical harm.
  • Business transfers. In the event of a merger, acquisition, joint venture, reorganization, divestiture, dissolution, liquidation or other similar business transaction, with the successor of such business or assets.
  • With your consent. At any other time when you specifically direct us to share information.
We do not share your information with third parties for those third parties' marketing purposes.
We may also aggregate or anonymize personal information in accordance with applicable law and disclose such aggregated or anonymized information to third parties.
Third-Party Links and Sites
Our Services may use third parties. Please refer to our Terms of Service to see the list of providers and review their terms and privacy policies. When using the services of any third party, their terms and privacy policies apply. We are not responsible for their terms, policies, or practices. You can learn more about how these third parties collect and use your data by consulting their privacy policies and other terms.
Security
We implement reasonable administrative, physical, and technical safeguards to protect data from unauthorized access, disclosure, loss, or misuse. You are responsible for all activity engaged in with our Services, including the security of your wallets, private keys, and blockchain network addresses.
Age Requirements
The Services are geared toward a general audience, not intended for or directed at children under 13 years of age, and we do not knowingly collect personal information from individuals under 18. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information, unless we are legally obligated to retain such information. If you believe a child under the age of 13 has provided, or we have otherwise received, personal information as defined by the U.S. Children's Online Privacy Protection Act, please contact us at [email protected].
U.S. State Privacy Rights
Certain U.S. states have enacted privacy laws and regulations that provide the residents of such states with certain rights and require certain disclosures in respect of their personal information.
  • For a description of the categories of personal information that we collect, including in the past 12 months, and the sources therefor, please review the "Data We Collect" section above.
  • For a description of the business or commercial purposes for which we collect data, please review the "How We Use Data" section above.
  • For a description of any third parties to whom we disclose personal information, including in the past 12 months, and the purposes therefor, please review the "How We Share Data" section above. We do not "sell" or "share" (as such terms are defined under the California Consumer Privacy Act of 2018) personal information and we do not process personal information for purposes of "targeted advertising."
  • We do not collect any sensitive personal information other than immigration status from potential employees for purposes of complying with applicable legal requirements.
  • Residents of U.S. states that have enacted privacy laws and regulations provide the residents of such states with certain rights in respect of their personal information. The exact scope of such rights may vary by state:
    • Right to Data Portability: The right to access personal information collected about you in a portable format.
    • Right to Delete: The right to request that we delete personal information that we have collected about you, subject to the fact that we cannot alter or delete data recorded on blockchains.
    • Right to Correct: The right to request that we correct inaccurate personal information that we maintain about you, subject to the fact that we cannot alter or delete data recorded on blockchains.
    • Right to Opt Out of the Sale or Sharing of Personal Information: The right to opt out of the "sale," "sharing," "targeted advertising" or certain other processing of personal information that produces legal or similarly significant effects.
    • Right to Request Information Regarding Disclosure to Third Parties: The right to request a list of the categories of third parties to which we have disclosed your personal information, and, in certain cases, the specific third parties to which we have disclosed personal information or a list of categories of personal information disclosed to third parties for direct marketing purposes.
    • Right to Appeal: In certain cases, the right to appeal a decision we have made in connection with a privacy rights request.
    • Right to Non-Discrimination: The right to not receive retaliatory or discriminatory treatment in connection with a request to exercise your privacy rights.
    • Right to Request Removal of Content: In certain cases, individuals under the age of 18 may make requests to remove content.
You can submit in writing any requests or questions in respect of any rights you may have under applicable U.S. state privacy laws to [email protected]. We will respond to requests for information access, correction or deletion only to the extent we are able to associate, with a reasonable effort, the information we may maintain with the identifying details you provide in your request. We may be required to collect and verify the identity of an individual submitting any such request before providing a substantive response. Certain states provide that you may designate an authorized agent to submit such requests on your behalf. We will require any such agent to have written authorization confirming their authority.
Rights for Cayman Islands, European Union and United Kingdom Residents (EU and UK General Data Protection Regulation "GDPR" Notice)
  • We process personal data for the limited purposes described in the "How We Use Data" section above.
  • Generally the legal basis upon which we process personal data is our legitimate interest in, for example, providing and improving our services, ensuring users' security, and responding to your communications, inquiries and requests through our customer service functions. In addition, we process personal data for substantial public interest reasons (such as the prevention of fraud) and to comply with our various legal and regulatory obligations. In some circumstances, we may also process personal data with your consent or for the purposes of performing a contract with you.
  • Under the GDPR and certain other applicable privacy laws, you have the following rights with respect to personal data that we have collected from you, subject to the fact that we cannot alter or delete data recorded on blockchains, such as transaction data or wallet addresses:
  • To request access to personal data, and be provided with it in permanent form;
  • To request correction of personal data that is inaccurate or incomplete;
  • To request deletion of personal data to the extent permitted by law;
  • To request the restriction of the processing of personal data;
  • To object to the processing of personal data based on legitimate interests or for direct marketing purposes;
  • To request that we return the personal data or, where technically feasible, have it transferred to a third party;
  • To request that we disclose to you:
    • the categories of personal data we have collected about you,
    • the categories of sources from which the personal data is collected,
    • the business or commercial purpose for collecting the personal data,
    • the categories of third parties with whom we have shared the personal data, and
    • the specific pieces of personal data we have collected about you;
  • To not be subject to a decision based solely on automated processing based on profiling or otherwise that has a legal or significant effect.
  • To not receive discriminatory treatment for the exercise of any of the foregoing rights.
  • Requests may be made to [email protected]. We may request additional information from you in order to process such requests. We may retain information as necessary to fulfill the purpose for which it was collected and may continue to do so even after such a request in accordance with our legitimate interests, including to comply with our legal obligations, resolves disputes, prevent fraud, and enforce our agreements.
Changes to this Policy
We may update this Policy from time to time. Updates will be posted here, and continued use of the Services constitutes acceptance of the revised Policy.
Contact Us
If you have questions or concerns about this Policy or our data practices, please contact us at:
Email: [email protected]
Mailing Address: Governor's Square, 23 Lime Tree Bay Avenue, PO Box 10176, Grand Caymans KY1-1002, Cayman Islands
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