Privacy Notice

Last updated: January 21, 2025

Scope and our Role
Personal Data We Collect
How We Use Personal Data
How We Share Personal Data
Cookies and Similar Technologies
Storage Duration and Erasure
International Data Transfers
Your Privacy Rights
Security
Children’s Personal Data
Changes to our Privacy Notice
How to Contact Us
Regional and State Privacy Terms
Submit your Privacy Request

Scope and our Role

This Privacy Notice (“Notice”) explains how Chainalysis and its affiliates (collectively “Chainalysis,” “we,” “us,” or “our”) collect, use, and share your personal datain the operation of the chainalysis.com website and associated webpages (the “Chainalysis Website”), and our web-based services such as Chainalysis Academy, webinars and trainings by the company, and our online products, services, and applications (collectively with the Chainalysis Website, the “Service(s)”). Chainalysis determines the purpose and methods for processing your personal data as described in this Notice, acting as the controller of this data. This Notice does not apply to the company’s processing activities in its capacity as a processor or service provider.

Personal Data We Collect

We may collect personal data when you access the Chainalysis Website, register or subscribe for the Service, subscribe to a webinar or marketing communications, become a trainee at the Chainalysis Academy, become a user of our forum, contact us, send us feedback, otherwise interact with us, and when we perform our Services in general. This personal data is collected either directly from you, such as when you register with us, or automatically, such as when you browse or use the Chainalysis Website, or when we collect personal data from other sources for our Services, which may include receiving personal data from suppliers we have engaged or third-party data sources. The personal data we collect depends on the particular Services you have requested and/or activities being carried out and could include:

• • • Contact Details, such as your name, address, phone number, and email address;
    • Payment Data, such as credit card number, expiration date, and billing address;
    • Business Data, such as your role, company name, and website name;
    • Agent and End User Data, including any email addresses and names or aliases of any agents or end users you authorized to log into and utilize the Service in connection with your account as a Chainalysis customer (“Agent” or “End User”);
    • Log-In and Connection Data, such as the information you provide to set up your use the Service;
    • Log File Data, including IP addresses, operating system, browser type, browser id, date/time of visit, and pages visited;
    • Device Data, such as device type, operating system, and software version;
    • Forum Data, such as content of posts and interactions with such posts within the Chainalysis forum;
    • Transaction Data, including details of purchases or subscriptions with us or courses, followed;
    • Analytics or Clickstream Data, including the electronic path you take to our Services, through our Services and when exiting our Services, as well as your usage and activity on our Services, such as the links and objects you view, click or otherwise interact with.
    • Marketing Preferences, including the method of communication you prefer;
      Education Data, including university, instructor or education provider, and university single sign-on details (if you choose to give this to us);
    • Education Data, including university, instructor or education provider, and university single sign-on details (if you choose to give this to us);
    • Cookie Data, meaning data collected via cookies on the Chainalysis Website;
    • Personal Details, including other personal details about you that are related to the Service and use thereof or your relationship with Chainalysis; and
    • Inquiry and Feedback Data, such as the content of your email, chat, or call with us when you ask us a question or provide us with any feedback.

How We Use Personal Data

Chainalysis may use personal data to:

• • provide and administer the Service, including Chainalysis Academy, to customers, subscribers, trainees, and their Agents and End Users;
  • liaise with universities and education providers and instructors to provide and administer the Chainalysis Academy;
  • provide and run the Chainalysis forum for Agents and End Users;
  • contact and communicate with you and your Agents and End Users about the Service, including to help you manage your account(s);
  • tailor the Service to its customers’ needs;
  • carry out account administration and billing activities;
  • implement security controls such as identity verification and authentication;
  • analyze data to provide you with relevant information about our company, products or Service;
  • provide you with promotional and other marketing materials, including any training seminars and webinars;
  • carry out research (including for statistical purposes) to improve and develop our products and the content and functionality of the Service, and to understand more about how our Service is used;
  • otherwise operate, maintain, further develop, and provide the Service; and
  • exercise our rights or comply with legal obligations.

How We Share Personal Data

We may share your personal data in the circumstances outlined below. We may also share your personal data among other subsidiaries or affiliates that either are subject to this Notice or have practices at least as protective as those described in this Notice.

Third-Party Service Providers and Vendors
Third-party service providers or vendors that Chainalysis has engaged to perform business functions on our behalf might have access to your personal data. Such parties may include:

• Service and hosting partners to provide the necessary hardware, software, networking, storage, and other services we use to operate the Service and maintain a high-quality user experience;
• Bank(s); and,
• Professional advisors, such as accountants, lawyers, consultants, and tax specialists.

Third-Party Partners
We may make available to you services or products in collaboration with third parties, for example, those that are jointly offered by Chainalysis and its third-party partners or other businesses.

For example, if you register in order to participate in an event, webinar, or training organized by us, or download or access material on our website, we may share your Personal Data with partners that co-organize or sponsor these activities and projects. If required by applicable law, we will seek your consent to such sharing, via the registration form or another affirmative action by you. In these circumstances, your data will be subject to the relevant partner’s privacy statements. If you do not wish for your data to be shared in this manner, you may choose to not register for the event or otherwise participate, or not access the material.

Payment Processors
We may share personal data with, or direct customers to provide such data, to payment processors who process payment for services on our behalf.

Marketing Partners
In some instances, we may share personal data with our marketing partners, including ad networks, social networks, retargeting partners, and marketing communication providers, in order to communicate with you about our products and services.

Business Transactions
Chainalysis may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may assign or transfer this Notice and your personal data to a third party in connection with such a corporate business transaction, for example, during negotiations. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.

Legal Obligations and Rights
We share personal data with third parties, such as legal advisors and law enforcement, to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share personal data if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our agreement for services, or as otherwise required by law.

Transfers Directed or Permitted by You
We may share personal data about you to certain other third parties at your direction or with your consent or permission.

Third-Party Services
The Chainalysis Website and/or the Service may contain links to websites and applications other than the Service, including websites, services, and applications operated by affiliates and other third parties. The Chainalysis Website sometimes may also include third-party Social Media features, such as the Facebook Like or Share buttons and Widgets or interactive mini-programs, that run on our site. These third-party features may collect your IP address and which web page you are visiting on the Chainalysis Website, and may set a cookie to enable the feature to function properly. Social Media features and Widgets are either hosted by a third party or hosted directly on the Chainalysis Website.

If you choose to interact with any third parties or through third-party services or applications, whether through us or on your own, your data will be subject to their privacy practices and terms and conditions.

Public Blogs and Forums
We may also offer publicly-accessible blogs or community forums in our Service or the Chainalysis Website. You should be aware that any information provided in these areas may be read, collected, and used by others who access them. Please note that your use of any such blogs or forums is always subject to the terms and conditions applicable to such blogs or forums.

Cookies and Similar Technologies

To enable our systems to recognize your browser or device and to provide and improve our Services, we use cookies and similar technologies. For more information about how we use them, how you can control them, and your choices regarding interest-based advertising and targeted advertising please see our Cookies Policy.

Storage Duration and Erasure

Chainalysis will retain personal data we process on behalf of our customers or users in accordance with applicable privacy laws to the extent necessary to provide the Service to our customers, subject to our compliance with this Notice and any relevant customer agreements.

Subsequently, we will delete your personal data in accordance with our data retention and deletion policy or take steps to properly render the data anonymous, unless we are legally obliged or permitted to keep your personal data longer (e.g. for legal obligations, accounting, financial or other operational records, resolving disputes, enforcing our agreements, or to detect and prevent fraudulent or illegal activity).

International Data Transfers

Some of the third parties with whom we share personal data may be based outside your region or state. When we transfer, store or process personal data outside of your jurisdiction, we take appropriate safeguards to require that your personal data remain protected in accordance with this Notice and applicable law.

We will only transfer your personal data from the European Economic Area (EEA), United Kingdom or Switzerland to countries outside the EEA, to countries which have received an adequacy decision from European Commission, the UK Government, and the Swiss Government, which means that these countries are recognized as providing an adequate level of data protection under applicable UK, European, and Swiss data protection laws

Other recipients of your personal data may be located in countries outside the EEA and/or the UK that are not the subject of an adequacy decision. In these cases, we may rely on the standard contractual clauses published by the European Commission and similar measures under UK laws when we share your Personal Data within the Chainalysis corporate group.

Data Privacy Framework
Chainalysis complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Chainalysis is certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. Chainalysis has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

Your Privacy Rights

To the extent granted by applicable law, you may have certain state or country specific rights with respect to your personal information. Please see Additional Jurisdiction Specific Disclosures below.

Security

We use reasonable physical, technical and organizational safeguards to minimize risks associated with data loss, misuse, unauthorized access or alterations. Despite these controls, we cannot completely ensure the security of your personal data. Please contact us with security questions at [email protected]

Children’s Personal Data

Our Services are not intended for or directed to children under 13. We do not knowingly collect or solicit any personal data from children. If you have reason to believe that a child has provided personal data to Chainalysis or is otherwise included in our Services, please contact us.

Changes to our Privacy Notice

We may change this Notice from time to time. If we make any material changes in the way we process your personal data, we will notify you by email, through the Service, or by posting a prominent notice on the Chainalysis Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices. All changes shall be effective from the date of publication unless otherwise provided.

Regional and State Privacy Terms

Additional terms to this Notice may apply to you based upon the country you are located in or the Service you use. Please see below for details:

• European Economic Area and United Kingdom
• California

How to Contact Us

If you have any questions, you can reach out to our Data Protection Officer (DPO) at [email protected]. If you have a privacy request, please fill out the form below or mail your request to the following address:

Chainalysis Inc.

ATTN: Privacy Department

114 5th Avenue, 19th Floor

New York, NY 10011

Submit your Privacy Request

Please complete the form below with the relevant email address. On completion of this form, you will receive an email confirming your request. Please note, Chainalysis may ask for more information to verify your identity before releasing any personal data. The information you provide will be used solely for the purpose of identity verification related to your privacy request, and will be processed and stored in accordance with our Privacy Policy.