Privacy Policy

Effective Date: 2026-05-20

Havenlon Labs (“Havenlon”, “we”, “us”, or “our”) provides the Havenlon mobile application, web console, hardware-enabled execution control devices, backend services, and related support services, including but not limited to Havenlon Bletchley and Havenlon Enigma products and services.

This Privacy Policy explains how we collect, use, store, disclose, and protect information when you use our applications, websites, hardware devices, backend services, and related services collectively referred to as the “Services”.

By using the Services, you acknowledge that you have read and understood this Privacy Policy.

1. Scope of This Policy

This Privacy Policy applies to information processed in connection with the Services, including:

Havenlon mobile applications
Havenlon web console and online services
Havenlon hardware devices and device-management workflows
Account, team, approval, policy, audit, and execution-control services
Customer support and operational communications

This Privacy Policy does not apply to third-party websites, blockchain networks, wallets, applications, infrastructure providers, or services that are not controlled by Havenlon.

2. Information We Collect

We may collect or process the following categories of information depending on how you use the Services.

2.1 Account Information

When you create or use an account, we may collect information such as:

Name
Email address
Phone number
Organization or team information
Account role and permission information
Authentication and login-related information
Support and communication records

2.2 Device and App Information

We may collect technical information related to the device, browser, operating system, application, and service environment, including:

Device model
Operating system version
App version
Browser type and version
Language and region settings
Device identifiers
Push notification tokens
IP address
Crash logs
Diagnostic data
Performance and reliability data
Basic usage events related to service operation and security

2.3 Havenlon Hardware Device Information

When you connect, register, manage, or use supported Havenlon hardware devices, we may process information such as:

Device serial number
Device identity information
Device model and hardware version
Firmware version
Device status
Connection status
Activation and binding status
Authorization status
Policy status
Security state
Diagnostic and operational logs
Device health, heartbeat, and availability information

This information is used to support device onboarding, device management, security verification, policy enforcement, execution-control workflows, diagnostics, and customer support.

2.4 Wallet, Address, and Transaction Metadata

Depending on your use of the Services, we may process wallet-related and transaction-related metadata, including:

Wallet addresses
Blockchain network or chain identifiers
Transaction requests
Signing requests
Approval requests
Authorization records
Execution-control records
Policy decision records
Audit logs
Transaction hashes
Transaction status
Related operational logs

We process this information to provide approval workflows, policy checks, device-based authorization, auditability, execution-control, and security-related functionality.

2.5 Policy, Approval, and Audit Information

The Services may process information related to execution-control policies, team approvals, authorization workflows, and audit trails, including:

Policy configuration
Approval rules
Team member roles
Request initiator information
Approval status
Rejection or failure status
Time stamps
Device participation records
Execution result records
Security and compliance logs

These records help provide security, accountability, dispute resolution, system integrity, and operational transparency.

2.6 Bluetooth, Camera, Photo, and Location Permissions

The mobile application may request access to Bluetooth to connect to supported hardware devices.

On Android, location permission may be required by the operating system for Bluetooth scanning. Havenlon does not use Bluetooth or location permission to track your physical location.

The mobile application may request camera access for scanning QR codes.

The mobile application may request photo library or media access to save, select, or upload images when necessary for specific features.

You may disable permissions through your device settings. Some features may not work properly if required permissions are disabled.

2.7 Push Notifications

We may collect and process push notification tokens to send account, security, transaction, approval, device, and service-related notifications.

You can disable push notifications through your device settings, although doing so may affect your ability to receive time-sensitive security or approval notifications.

2.8 Analytics and Crash Reports

We may use analytics, diagnostic, and crash reporting tools to understand service performance, detect issues, improve reliability, and enhance the Services.

These tools may process information such as:

Crash logs
Diagnostic information
Device and app information
Performance events
Basic usage events
Error reports

We do not use advertising identifiers for analytics.

3. Information We Do Not Collect

Havenlon is designed as a non-custodial execution-control system.

We do not collect, store, or have access to:

Your private keys
Your seed phrases
Your recovery phrases
Your hardware device PIN codes
Your full wallet recovery credentials
Information that would allow us to independently sign transactions on your behalf

Havenlon does not have the ability to move your digital assets, reverse blockchain transactions, recover your private keys, or sign transactions without the required authorization and execution path.

You are responsible for securely storing your private keys, recovery phrases, PIN codes, hardware devices, and other credentials.

4. Blockchain and Public Network Data

Blockchain networks are operated by third parties and may be public, decentralized, irreversible, and outside Havenlon’s control.

When you use the Services in connection with blockchain networks, certain information may become publicly visible, including wallet addresses, transaction hashes, transaction amounts, token information, timestamps, smart contract interactions, and other on-chain data.

Havenlon cannot delete, modify, hide, or reverse information that has already been recorded on a public blockchain or other third-party network.

Deleting your Havenlon account or requesting deletion of personal information from Havenlon systems does not delete information from public blockchains, third-party wallets, block explorers, indexers, validators, nodes, or other external systems.

5. How We Use Information

We may use the information we collect or process to:

Provide, operate, maintain, and improve the Services
Create and manage user accounts
Authenticate users
Protect account and service security
Register, connect, and manage supported hardware devices
Verify device identity and device status
Process signing requests, approval requests, and execution-control workflows
Apply policy, approval, and authorization rules
Provide audit logs and operational records
Send account, security, transaction, approval, device, and service notifications
Detect, investigate, and prevent fraud, abuse, unauthorized access, and security incidents
Diagnose crashes, bugs, performance issues, and service failures
Provide customer support
Maintain service integrity and availability
Comply with legal, regulatory, tax, accounting, security, and compliance obligations
Enforce our agreements, policies, and terms

6. How We Share Information

We do not sell your personal information.

We may share information with the following categories of recipients when necessary to provide, secure, operate, or improve the Services:

Cloud infrastructure providers
Hosting and storage providers
Push notification providers
Analytics and crash reporting providers
Customer support and communication providers
Security, monitoring, and fraud-prevention providers
Payment, billing, or order-processing providers where applicable
Professional advisors, such as legal, accounting, compliance, or audit advisors
Legal, regulatory, law enforcement, or government authorities where required by applicable law
Successors or assignees in connection with a merger, acquisition, financing, restructuring, or sale of assets

These third parties are only permitted to process information as necessary to provide services to us or as otherwise permitted by applicable law.

We may also share information when we believe it is necessary to protect the rights, property, safety, security, or integrity of Havenlon, our users, our Services, or others.

7. Third-Party Services

The Services may use third-party services, including but not limited to:

Firebase Cloud Messaging
Firebase Analytics
Firebase Crashlytics
Apple Push Notification service
Google Play services
Cloud hosting and infrastructure providers
Error monitoring and diagnostic services
Email and customer communication services

The specific third-party services used may vary depending on your platform, region, product version, and service configuration.

Third-party services may process information according to their own privacy policies and terms. Havenlon is not responsible for the privacy practices of third-party services that are not controlled by Havenlon.

8. Data Storage and Security

We use reasonable technical and organizational measures designed to protect information against unauthorized access, loss, misuse, alteration, or disclosure.

These measures may include encryption, access controls, authentication controls, logging, monitoring, network security measures, and operational security procedures.

However, no method of transmission, processing, or storage is completely secure. We cannot guarantee absolute security.

You are responsible for keeping your account credentials, hardware devices, private keys, recovery phrases, PIN codes, and other security credentials secure.

If you believe your account, device, private key, recovery phrase, or credentials have been compromised, you should take immediate protective action and contact us where appropriate.

9. Data Retention

We retain information for as long as reasonably necessary to provide the Services, maintain security, comply with legal obligations, resolve disputes, enforce agreements, and maintain operational integrity.

Account information is generally retained while your account remains active.

Device, approval, policy, security, and audit logs may be retained for a longer period where necessary for security, compliance, dispute resolution, fraud prevention, abuse prevention, system integrity, or legal reasons.

We may retain certain information in backup systems, archives, logs, or records for a limited period before deletion is fully completed.

We may also retain information where required or permitted by law.

10. Your Rights and Choices

Depending on your location and applicable law, you may have rights to:

Access the personal information we hold about you
Correct inaccurate or incomplete information
Delete certain personal information
Object to certain processing
Restrict certain processing
Withdraw consent where processing is based on consent
Request portability of certain information
Lodge a complaint with a relevant data protection authority

To exercise these rights, please contact us using the contact information listed at the end of this Privacy Policy.

We may need to verify your identity before processing your request.

Some information may be retained where necessary for security, legal compliance, dispute resolution, fraud prevention, abuse prevention, auditability, or legitimate business purposes.

Your rights may be limited where the request conflicts with legal obligations, security requirements, blockchain immutability, third-party network records, or the rights and freedoms of others.

11. Permissions and User Controls

You may control certain permissions through your device, browser, or account settings.

These may include:

Bluetooth permissions
Camera permissions
Photo or media permissions
Location permissions
Notification permissions
Account settings
Team and workspace settings
Device binding and management settings where available

Disabling certain permissions may limit or prevent some Services from working properly.

12. International Data Transfers

Your information may be processed, stored, or transferred in countries or regions other than where you live.

These countries or regions may have data protection laws that differ from those in your jurisdiction.

Where required by applicable law, we use appropriate safeguards designed to protect information transferred internationally, such as contractual, technical, and organizational measures.

13. Children’s Privacy

The Services are intended for business, technical, and professional users.

The Services are not directed to children under 13 years old, or the equivalent minimum age required by applicable law in the relevant jurisdiction.

We do not knowingly collect personal information from children. If we become aware that we have collected personal information from a child in violation of applicable law, we will take reasonable steps to delete such information.

14. Business Transfers

If Havenlon is involved in a merger, acquisition, financing, restructuring, bankruptcy, sale of assets, or similar transaction, information may be transferred as part of that transaction.

If required by applicable law, we will provide notice or obtain consent before your information becomes subject to a materially different privacy policy.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

If we make material changes, we will notify you through the Services, by email, or by other appropriate means.

The updated Privacy Policy will be effective when posted unless otherwise stated.

Your continued use of the Services after the effective date of an updated Privacy Policy means you acknowledge the updated Privacy Policy.

16. Contact Us

If you have any questions, requests, or concerns regarding this Privacy Policy, please contact us at:

Havenlon Labs
Email: [email protected]
Website: https://havenlon.com