Privacy Policy

Last updated March 22, 2021

This privacy policy (the “Privacy Policy”) explains how dTrade Labs Inc. (“Firefly”, “we”, “us” and “our”) collects, uses, and discloses information about you or the person or entity you represent (“you” or “your”) through its websites, web applications, and other online products and services (collectively, the “Services”) or when you otherwise interact with us. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

1. Information We Collect

  • (a) Information You Provide to Us

    We collect information you provide directly to us. For example, we collect information when you access or use the Services, fill out a form, engage in a transaction, request customer support or otherwise communicate with us. The types of information we may collect include your email address and any other information you choose to provide.

  • (b) Automatically Collected Information

    When you access or use the Services, we automatically collect information about you, including the following:

    • (i) Log Information: We collect log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our Services.
    • (ii) Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
    • (iii) Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, please see Section 9 below.
  • (c) Information We Collect from Other Sources

    We may obtain information from other sources, including third parties, and combine that with information we collect through our Services.

  • 2. How We Use Information

    We use the information we collect to provide, maintain, and improve the Services. We may also use the information we collect to:

    • (a) send you technical notices, updates, security alerts and support and administrative messages, and to respond to your comments, questions and customer service requests;
    • (b) communicate with you about products, services, offers, and events offered by us and others, and provide news and information we think will be of interest to you;
    • (c) monitor and analyze trends, usage, and activities in connection with the Services; and
    • (d) detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Firefly and others.
  • 3. Sharing of Information

    We may share information about you as follows or as otherwise described in this Privacy Policy:

    • (a) with vendors, consultants and other service providers who need access to such information to carry out work on our behalf;
    • (b) in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, or legal process;
    • (c) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of Firefly or others;
    • (d) in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
    • (e) between and among Firefly and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and
    • (f) with your consent or at your direction.
  • 4. Advertising and Analytics Services Provided by Others

    We may allow others to provide analytics services and serve advertisements on our behalf across the Internet and in applications. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Firefly and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on the Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit (or if you are a resident of the European Economia Area).

  • 5. Retention of Data

    We store the information we collect about you for as long as is necessary for the purposes for which we originally collected it, or for other legitimate business purposes, including to meet our legal or other regulatory obligations, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service, and other actions permitted by law. There is no single retention period applicable to the various types of personal information collected. Please contact us if you would like to delete any personal information we hold about you. We also reserve the right to continue to hold personal information about you to the extent it is required to be held by us by law, rule, or regulation.

  • 6. Security Measures

    We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity of, and to help protect information about you from, loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.

  • 7. Transfer of Information to Other Countries

    We are based in the British Virgin Islands. However, we may transfer personal information to outside agents or service providers (including our affiliates acting in this capacity) that perform services on our behalf, such as customer service and support, marketing and analytics, data hosting or processing services, or similar services. Some of these service providers may be located outside of the British Virgin Islands, including the United States, and as a result your personal information may be processed in the United States or elsewhere outside of the British Virgin Islands, where local laws may permit foreign government and national security authorities to access personal information in certain circumstances.

  • 8. Residents of The European Economic Area

    If you are a resident of the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data. Any reference to “personal information” in this Privacy Policy should be understood as referring to “personal data”, defined under the General Data Protection Regulation (“GDPR”) as “any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.

  • (a) Legal Basis for Processing

    If you are a resident of the EEA, when we process your personal data we will only do so where we need to use your personal data to perform our responsibilities under our agreement with you (e.g., providing the Services you have requested). We have a legitimate interest in processing your personal data. For example, we may process your personal data to send you marketing communications, to communicate with you about changes to the Services, and to provide, secure, and improve the Services. You have consented to the processing of your personal data for one or more specific purposes. We consider that our legitimate interests are in compliance with the GDPR and your legal rights and freedoms. You have the right to object to any of this processing and, if you wish, please contact us at the contact details indicated below.

  • (b) Data Subject Requests

    If you are a resident of the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can contact us as indicated below. Please note that the limitation or deletion of your personal data may mean we will be unable to provide our Services to you. You also have the right to receive your personal data in a machine-readable format and have the data transferred to another party responsible for data processing.

  • (c) Questions or Complaints

    If you are a resident of the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:

  • 9. Your Choices

    (a) Account Information

    You may update, correct, or delete information about you at any time by emailing us at [email protected] Please note that we may retain cached or archived copies of information about you for a certain period of time.

  • (b) Cookies

    Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Services.

  • (c) Promotional Communications

    You may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at [email protected]. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

  • (d) Mobile Push Notifications/Alerts

    With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

  • 10. Contact

    If you have any questions about this Privacy Policy, please contact us at: [email protected].

Important Disclosures:

i) The platform is not available to United States residents
ii) Firefly is expected to go live within the first two Polkadot Parachain auctions. More information on this will be released soon.
iii) All assets on Firefly involve a degree of risk and may result in partial or total loss of your investment
iv) Micro gas fees will be paid out of the Firefly DAO
v) Sub-second settlement does not incorporate network latency or congestion
vi) While the Chainsafe bridge can be used to support USDC on the exchange, we may pivot to USDT since it is natively supported on Substrate

Firefly is a decentralized exchange powered by Substrate and Rollups, and designed to function as a fully decentralized public utility, owned and controlled by the community of token holders. Please view our terms of use and privacy policy before accessing the platform.