CLC App Privacy Notice
Draft version: 1.0 Draft date: 24 October 2026Review draft — not yet effective. This English text is available for public review before legal approval and translation. Until an approved version takes effect, it must not be treated as the App's operative Privacy Notice.
This Privacy Notice explains how Grassroots Economics Foundation (GEF, we, us, or our) handles personal data when you visit or use the Cosmo-Local Credit App at cosmolocal.credit and the related services that GEF operates (together, the App).
Read before publishing. Your profile contact details and saved location are not automatically shown on public resources. Information you enter or copy into a Voucher, Pool, Offering, Want, Catalog, or Post can become public when you publish it. A public location can include the exact map coordinates you selected.
This Notice supplements the Terms of Service and the Data Protection Policy.
1. Who is responsible for your data?
Grassroots Economics Foundation is the operator of the App and the data controller for the App data described in this Notice, except where another party independently determines how it uses data.
Contact GEF at:
- Email: [email protected]
- Postal address: P.O. Box 1659-80108, Kilifi, Kenya
Issuers, Pool Stewards, payment providers, Wallet providers, blockchain participants, and operators of external services may be independent controllers for information they receive or publish. Their own notices and terms may also apply.
2. Who and what does this Notice cover?
This Notice covers visitors, account holders, people using App features, and people whose information an authorized user submits through the App. It covers GEF-operated App interfaces, APIs, catalogs, storage, relaying, notifications, moderation, support, and related operational services.
It does not control how an independent Issuer, Pool Steward, third-party provider, public blockchain, external website, or another user processes information outside GEF's role. The App is for adults who meet the eligibility requirements in the Terms.
3. Data we collect
Account and profile data
Depending on the features you use, we may collect:
- your public username and public blockchain Wallet address;
- your name, email address, phone number, country, and preferred currency;
- your biography, website, avatar, and saved location name and coordinates;
- account role, status, resource limits, and account creation or update times; and
- settings, language, notification preferences, and other choices you make.
Your public username is different from your private profile name. Your profile can be used to prefill forms, but prefilling a form does not publish the field until you choose to publish the resource.
Authentication, Wallet, and transaction data
We may process Wallet addresses, signed messages, transaction authorizations, signatures, passkey credential identifiers and public-key coordinates, session identifiers, transaction requests, relayer records, and transaction status. We do not need your passkey's private key in order to verify a passkey assertion.
If you use a paper Wallet or another credential that you control, you are responsible for protecting its private material. A public Wallet address and public blockchain transactions are not private.
Device, security, and usage data
We may collect technical and operational information such as IP address, browser and device information, timestamps, requested pages or endpoints, session and security events, validation errors, rate-limit information, notification subscriptions, service activity, and diagnostic records.
Content and support data
We process information you submit in Vouchers, Pools, Offerings, Wants, Catalogs, Posts, Reviews, images, attachments, terms, descriptions, tags, locations, contact fields, complaints, support messages, and other communications.
Do not publish another person's personal data, image, contact information, or precise location unless you have a lawful reason and any permission that is required.
4. What becomes public?
The App has four important visibility levels.
| Visibility | What it means |
|---|---|
| Private profile and account data | Profile name, email, phone number, saved location, preferences, authentication records, and similar account information are used to operate the App and are not automatically placed in public resource responses. Authorized GEF personnel and service providers may access them when necessary for their work. |
| Exact recipient lookup | A signed-in user who enters your exact username or full phone number may receive your public username and Wallet address. Partial usernames do not return a user. The phone number used for the query, your private profile name, email, phone number, and saved location are not returned in the recipient result. |
| Published App resources | Fields deliberately entered or copied into a published resource can be visible to anyone who can access the public catalog or resource. Public fields may be indexed, copied, shared, or associated with a Wallet or another resource. |
| Public blockchain records | Wallet addresses, contracts, balances, holdings, transfers, amounts, counterparties, timestamps, signatures, and contract actions can be visible permanently through public networks and independent block explorers. GEF cannot erase or rewrite a public blockchain. |
Removing a resource from the App's catalog does not remove copies already made by other people, search services, archives, independent indexers, or public blockchains.
5. Public resource fields
The fields available to a resource can change as the App develops. The form shown before publication is the most direct notice of what you are choosing to publish.
| Resource | Information that can become public |
|---|---|
| Voucher | Contract and chain identifiers; Voucher name, symbol, description, stated unit and value; Issuer or owner Wallet address; terms; contact details; location name and exact coordinates; images; tags; visual markers; and active or retired catalog status. |
| Pool | Contract and chain identifiers; Pool name and description; owner, fee-recipient, dependency, or other technical-controller Wallet addresses; supported Vouchers; inventory or availability information; valuation method; fees, limits, rules, and other configuration; contact details; location name and exact coordinates; images; tags; and timestamps. |
| Offering | Linked Voucher details; seller or provenance Wallet address; goods or services offered; description, quantity, unit, frequency, price, and availability; location name and exact or inherited coordinates; image; tags; and timestamps. |
| Want | Requested goods or services; description; tags; image; status and dates; location name and exact coordinates; and only the contact method deliberately selected for that Want. Public Want responses do not need to identify the creator's private profile. |
| Catalog | Catalog name, description, image, tags, owner Wallet address, listed members or resources, counts, location name and exact coordinates, and timestamps. |
| Approved Post | Title, summary, body, host name, participant information, dates, images, captions, attachments, embedded links, tags, linked Vouchers or Pools, and exact coordinates. Draft, submitted, or rejected Posts are not public. The author's Wallet address is retained for management and accountability but is omitted from public Post responses. Linked resources or the content itself may still reveal an association. |
| Review | Rating, comment, and any public reply by the Voucher owner. The public Review response omits the reviewer's Wallet address and redemption metadata, although the service retains information needed to verify eligibility, prevent duplicate reviews, moderate content, and enforce the review period. |
Contact details and exact coordinates can create personal safety risks. Use a suitable public contact method and a safe public meeting place rather than a private home whenever possible.
6. Public blockchain information
The App interacts with public blockchain networks. A transaction may disclose the Wallets involved, Token or Voucher contract, amount, time, status, and related contract events. Pool contracts can also disclose supported assets, balances, fees, limits, valuations, owners, administrators, dependencies, and other configuration.
Blockchain information may be processed by network validators, node operators, indexers, Wallet software, analytics services, and anyone who reads the network. Transactions can be irreversible. Closing an App account, changing a profile, or asking GEF to delete off-chain data does not delete blockchain records.
7. Why we use data and our legal grounds
We use personal data only where we have an applicable legal ground. The ground can depend on the person, feature, and jurisdiction.
| Purpose | Typical legal ground |
|---|---|
| Create and operate accounts, authenticate users, provide requested features, submit authorized transactions, and provide support | Performance of our agreement with you and steps taken at your request |
| Publish a resource or contact method you deliberately submit for public display | Performance of our agreement, your deliberate public action, and consent where consent is required |
| Protect accounts and services, prevent fraud or misuse, enforce limits, investigate incidents, and maintain reliable records | Legitimate interests in operating a safe and accountable service, performance of our agreement, and legal obligations |
| Moderate Content, review complaints, enforce the Terms, and protect users or the public | Legitimate interests, performance of our agreement, and legal obligations |
| Keep financial, transaction, governance, compliance, tax, and dispute records | Legal obligations and legitimate interests in accountability and legal claims |
| Send optional communications or notifications | Consent where required, or our agreement and legitimate interests for service messages |
| Improve services and produce research or aggregate statistics | Legitimate interests, consent where required, and other lawful research grounds with appropriate safeguards |
We do not treat your decision to publish one field as consent to publish unrelated private profile fields.
8. Required and optional data
The App identifies required fields in the relevant form. A Wallet address, authentication proof, name, and email are required for current account registration. Particular features can require additional transaction, contact, location, eligibility, or resource information.
Other profile and resource fields are optional unless the form says otherwise. If you do not provide required information, we may be unable to create an account, authenticate you, submit a transaction, publish a resource, provide support, meet a legal requirement, or make the requested feature available.
Optional does not mean private after publication. An optional contact detail, image, description, or map pin becomes public if you add it to a resource and publish that resource.
9. How we receive data
We receive data:
- directly from you or a person authorized to act for you;
- from your browser, device, Wallet, passkey, or notification service;
- from public blockchain networks, contracts, nodes, and indexers;
- from Issuers, Pool Stewards, counterparties, payment or service providers, and other users involved in a feature or transaction;
- from public sources where collection is lawful; and
- from security, moderation, support, and compliance processes.
10. Who receives data?
We disclose only the information reasonably needed for the stated purpose, applicable law, or your requested public action. Recipients can include:
- App visitors and users when you publish a resource or use a public blockchain;
- Issuers, Pool Stewards, counterparties, and other participants needed for a transaction, redemption, complaint, or requested service;
- infrastructure providers for hosting, databases, storage, content delivery, security, authentication, support, email, notifications, mapping, geocoding, blockchain access, indexing, transaction relaying, and monitoring;
- independent Wallet, blockchain, payment, stablecoin, cash-ramp, or other third-party service providers you choose to use;
- professional advisers, auditors, insurers, researchers, funders, and partners under appropriate duties and safeguards; and
- regulators, courts, law-enforcement bodies, or other persons where disclosure is required by law or reasonably necessary to protect rights, safety, and the integrity of the service.
Third-party services can collect data directly under their own privacy notices. Before publication of this Notice, GEF reviews the current provider and transfer inventory so the disclosures remain accurate.
11. International processing
The App, public blockchain networks, service providers, partners, and users can operate in more than one country. Personal data may therefore be accessed or processed outside Kenya or the country where it was collected.
Where a transfer requires safeguards, GEF uses measures appropriate to the transfer and applicable law, which can include contracts, access restrictions, encryption in transit, assessments of the recipient and destination, consent where appropriate, or another legally recognized transfer basis. Public information and blockchain transactions can be accessed globally and cannot be confined to one country.
12. How long we keep data
GEF keeps personal data only for as long as reasonably necessary for the purpose for which it was collected, including:
- while an account, resource, transaction, complaint, or support matter remains active;
- for security, fraud prevention, reconciliation, audit, governance, research-integrity, and service-continuity needs;
- for tax, accounting, regulatory, contractual, dispute, limitation-period, or other legal requirements; and
- for a limited period in protected backups and logs before scheduled deletion or replacement.
Different records therefore have different retention periods. We delete, aggregate, de-identify, or restrict data when it is no longer needed, unless preservation is required or permitted by law. Public blockchain records and copies controlled by other people are outside GEF's deletion control.
13. Security
GEF uses proportionate technical and organizational measures designed to protect personal data. These can include access controls, authentication, role separation, secure transport, system updates, monitoring, backups, incident procedures, staff duties, and provider safeguards.
No online system, public blockchain, credential, or transmission is completely secure. You must protect your devices, sessions, passkeys, private keys, paper Wallets, and recovery information and review information before making it public.
14. Your rights and choices
Subject to applicable law, you may have the right to:
- be informed about how your personal data is used;
- request access to personal data GEF holds about you;
- request correction of inaccurate or misleading data;
- object to or request restriction of particular processing;
- withdraw consent where processing depends on consent;
- request deletion of data that GEF is not required or entitled to retain;
- receive portable data where the right applies; and
- complain to the Office of the Data Protection Commissioner (ODPC) or another competent authority.
Send a request to [email protected]. We may need to verify your identity and authority before acting. Rights can be limited by other people's rights, public records, legal duties, technical necessity, or the permanent nature of a public blockchain.
You can also choose not to enter optional profile fields, remove optional information before publication, use a suitable public contact method, select a safe public map point, manage notification permission, and avoid a feature that requires data you do not wish to provide.
Information about Kenyan data-subject rights is available from the ODPC.
15. Children
The CLC App is restricted to people who are at least 18 years old and have reached the age of legal majority that applies to them. Do not create an App account for a child or submit a child's personal data through the App unless GEF has expressly provided a separate lawful process with the required safeguards and authorization.
GEF activities outside the App that involve children are governed by the Child Safeguarding Policy and applicable data-protection requirements.
16. Complaints and incidents
Contact [email protected] if you have a privacy complaint, believe personal data has been published without authority, or suspect a data-security incident. Include enough information for us to locate and assess the issue, but do not send private keys, passwords, or unnecessary sensitive data.
You may also complain to the Office of the Data Protection Commissioner or another authority with jurisdiction over the processing.
17. Changes to this Notice
GEF reviews this Notice when App behavior, providers, legal requirements, or data practices materially change. We will publish the current version and effective date on this page and provide any additional notice or consent required by applicable law.
A later Notice does not make previously private data public. The visibility of a resource is determined by the fields, controls, and notices that apply when it is published or later edited.
18. Contact
For privacy questions or requests:
Grassroots Economics Foundation
P.O. Box 1659-80108
Kilifi, Kenya
[email protected]