Privacy Policy

1. Introduction

Extol, Inc. ("Extol," "we," "us") operates the Extol platform, including the Extol community event tool and associated services (collectively, the "Services"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information.

We are committed to transparency. We do not sell your personal information. We collect only what we need to provide the Services. You can delete your account and data at any time.

2. Information We Collect

2.1 Information You Provide

Data Type	When Collected	Purpose
Account information	Registration	Name, email address, password hash — to create and secure your account
Profile information	Optional	Display name, bio, community affiliations — to identify you within communities
Event data	Event creation (coordinators)	Event name, description, date, location — to organize community activities
Contribution records	Activity tracking	Description of contributions, timestamps — to record your community participation
Payment information	Paid subscriptions	Processed by our payment processor; Extol does not store credit card numbers

2.2 Information Created Through Use

Data Type	When Created	Purpose
Attendance records	Check-in at events	Records that you attended a community event — created by you or by a coordinator on your behalf
Peer attestations	Community interaction	Records where community members attest to your participation or contributions
Governance activity	Governance participation	Votes, proposals, staking actions — to operate community governance
Wallet address	Extol governance activation	A blockchain wallet address generated for on-chain attestations

2.3 Information Collected Automatically

Data Type	Purpose
Device and browser information	User-Agent, IP address, device type — for security, fraud prevention, and service optimization
Usage data	Pages viewed, features used, session duration — to improve the Services
Log data	Server logs for debugging and security monitoring — retained for 90 days

2.4 Information Created by Coordinators

Community coordinators may record attendance or activities on your behalf. When this happens:

You are notified the first time a coordinator creates a record for you
You can review all records created on your behalf
You can delete any or all of these records at any time

3. How We Use Your Information

We use your information to:

Provide the Services — account management, event coordination, attendance tracking, governance tools
Process on-chain attestations — translate your activity into pseudonymous blockchain records (only if your community uses Extol governance features)
Communicate with you — service announcements, notifications about records created on your behalf, responses to your inquiries
Improve the Services — usage analytics, bug fixes, feature development
Ensure security — fraud detection, abuse prevention, account protection
Comply with legal obligations — tax reporting, law enforcement requests, regulatory requirements

We do not use your information to:

Sell to third parties
Target advertising
Build profiles for sale to data brokers
Train AI models on your personal data without your explicit consent. If your Collective votes to participate in community-initiated research, you retain an individual right to opt out regardless of the Collective's vote. Consent for AI training use is always individual and opt-in — a Collective vote authorizes the Collective's participation, not yours personally

4. The Identity-to-Wallet Link

This section describes the most sensitive data we hold.

4.1 What It Is

If your community uses Extol governance features, we create and maintain a link between your account identity (name, email) and your blockchain wallet address. This link exists in Extol's secure infrastructure between Extol and the public blockchain.

4.2 Why It Exists

The link is necessary to:

Connect your community activity (recorded in Extol) to your on-chain attestations
Display your governance token balance and voting weight in the app
Enable you to participate in governance through a familiar interface rather than directly interacting with blockchain tools

4.3 Who Can Access It

You — you can see your own wallet address and linked records
Extol operations staff — limited access for support and debugging, subject to internal access controls and audit logging
No one else — we do not share the link with communities, coordinators, other users, or third parties except as required by law (see Section 6)

4.4 How We Protect It

The link is stored in encrypted form in our database
Access is restricted to authorized personnel with logged access
The link is the first data deleted when you delete your account

4.5 What Happens When You Delete

When you delete your account, the identity-to-wallet link is permanently destroyed. Your wallet address becomes an anonymous orphan on the blockchain — the on-chain records persist but are no longer linked to any identity in our systems. There is no backup copy and no way to re-link. See Section 8 for full deletion details.

5. On-Chain Data

5.1 What Goes On-Chain

If your community uses Extol governance features, the following data may be recorded on a public blockchain:

Hashed attestation records (a one-way cryptographic hash of your activity data — not the raw data itself; see Section 5.4 for details on irreversibility)
Community governance token positions (your participation commitment and portable balances, recorded as token data — not as dollar amounts)
Governance votes and proposals

Community tokens are recorded as on-chain positions. Some positions are permanent commitments that cannot be reversed. Portable balances may change over time due to earning, spending, or depreciation. Community tokens have no public market price or exchange rate to any currency.

5.2 What Does NOT Go On-Chain

The following data is never written to the blockchain:

Your name, email, or other personally identifying information
Raw event data, attendance records, or contribution details
The identity-to-wallet link

5.3 Permanence

On-chain data is public and permanent. It cannot be modified, deleted, or made private after recording. However, on-chain records use pseudonymous wallet addresses — without the identity-to-wallet link (which you can delete), they are not linked to a person.

5.4 Hashing

Attestation data recorded on-chain is a one-way cryptographic hash. The hash cannot be reversed to reveal the underlying data. Once the off-chain source record is deleted, the hash is a meaningless string with no reversibility path.

We share personal information only in these circumstances:

6.1 With Your Community

Your community coordinators and members can see information you make available through your community participation — your display name, contributions, attendance, and governance activity. This is the purpose of the Services.

6.2 Service Providers

We use third-party service providers for:

Cloud hosting and infrastructure
Payment processing
Email delivery
Analytics (aggregated, not individual)

Service providers are contractually bound to use your information only to provide services to Extol and are prohibited from using it for their own purposes.

6.3 Legal Requirements

We may disclose personal information if required by law, subpoena, court order, or government request. When legally permitted, we will notify you before disclosure.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction. We will notify you before your information becomes subject to a different privacy policy.

6.5 Attestation API — Third-Party Verification

The Extol platform provides an Attestation API that allows authorized third parties to verify your community participation credentials.

How it works:

A third party (e.g., a potential employer, platform, or licensing partner) requests verification of your community participation credentials
You receive a consent request specifying: who is asking, what data they want to verify, and why
You explicitly approve or deny each verification request
If approved, the third party receives only the specific credential data you authorized — not your full profile, activity history, or wallet address

What is shared:

Community membership status (active/inactive)
Participation credentials (e.g., "verified contributor in [Collective] for [duration]")
Governance participation level (if you consent)
Attestation scores or tiers (if you consent)

What is never shared through the API:

Your identity-to-wallet link
Raw activity records or attendance history
Other community memberships you have not authorized for disclosure
Governance vote content (how you voted — only that you participated)

Consent model:

Verification requires your explicit, per-request consent
You can revoke access to previously shared credentials at any time
A Collective's governance vote does not authorize sharing your individual credentials — individual consent is always required
You can disable API access entirely in Settings

6.6 With Your Consent

We may share information for purposes not listed here with your explicit, informed consent.

7. Your Rights

7.1 Access

You can access all personal information we hold about you through your account settings. This includes attendance records, contribution records, peer attestations, and (if applicable) your wallet address.

7.2 Correction

You can correct your account information at any time through Settings.

7.3 Deletion

You can delete your account and all associated data at any time. See Section 8.

7.4 Data Portability

You can export your data in a standard, machine-readable format (JSON) through Settings. This includes your activity history, contributions, and attestation records.

7.5 Opt-Out of On-Chain Features

If your community activates Extol governance features, you can opt out of on-chain attestations while remaining a community member using Extol features.

7.6 California Residents (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:

Right to know what personal information we collect, use, and share
Right to delete your personal information
Right to opt out of the sale of personal information (we do not sell personal information)
Right to non-discrimination for exercising your privacy rights

To exercise these rights, contact privacy@extol.work or use the self-service options in Settings.

7.7 EU/EEA Residents (GDPR)

If you are located in the European Union or European Economic Area, you have additional rights under the General Data Protection Regulation:

Legal basis: We process your data based on (a) your consent, (b) performance of our contract with you (these Terms), (c) our legitimate interests in operating the Services, or (d) compliance with legal obligations
Right to restrict processing — you can ask us to limit how we use your data
Right to object — you can object to processing based on legitimate interests
Right to lodge a complaint with your local data protection authority
Data transfers — we transfer data from the EU/EEA to the United States. We use Standard Contractual Clauses to protect your data during transfer.

8. Data Deletion

8.1 How Deletion Works

When you delete your account, a single action triggers deletion across all layers:

Your activity data: Complete deletion of your user record, all attendance records, all contribution records, and all peer attestations. This is a clean, irreversible wipe.

Your identity link: Permanent deletion of the connection between your identity and your blockchain wallet address. Your wallet address becomes anonymous — it exists on the blockchain but is connected to no one in our systems.

On-chain records: Attestations, token balances, and staking positions on the public blockchain cannot be deleted. However, without the identity link, these records are pseudonymous data that cannot be linked back to you.

8.2 What We Cannot Delete

We cannot delete data recorded on a public blockchain. We can — and do — delete the only link between that data and your identity.

8.3 Backup and Log Purge

When you delete your account, we also:

Remove your data from backups within 30 days
Purge any log entries containing your identity link within 30 days
Retain only anonymized, aggregated data that cannot identify you

8.4 Coordinator-Created Records

Records that a coordinator created on your behalf are deleted when you delete your account. The coordinator is not notified of individual record deletions.

9. Data Security

9.1 Measures

We implement industry-standard security measures including:

Encryption in transit (TLS) and at rest (AES-256)
Access controls and authentication for all internal systems
Regular security assessments
Audit logging for access to sensitive data (especially the identity-to-wallet link)

9.2 Breach Notification

In the event of a data breach affecting your personal information, we will notify you within 72 hours of becoming aware of the breach, as required by applicable law. Notification will include the nature of the breach, the data affected, and steps we are taking in response.

10. Data Retention

Data Type	Retention Period
Account information	Until you delete your account
Activity records (Extol)	Until you delete your account
Identity-to-wallet link	Until you delete your account
On-chain data	Permanent (blockchain)
Server logs	90 days
Backup copies	Purged within 30 days of account deletion
Payment records	As required by tax law (typically 7 years)
Aggregated analytics	Indefinite (anonymized, non-personal)
Pre-community activity data	See Section 10.1 below

10.1 Pre-Community Activity Data

Extol allows coordinators to create events and track participation before a formal community or Collective is formed. This early-stage data — attendance records, contributions, and peer attestations collected through Extol before any community governance structure exists — is subject to the following rules:

If a community forms: Pre-community data becomes part of the community's activity history, subject to all standard retention and deletion policies.

If a community never forms: Pre-community activity data is retained for 12 months from the last recorded activity. After 12 months of inactivity with no community formation, we will:

Notify the coordinator and all participants with recorded activity
Provide a 30-day window to export data
Delete all pre-community activity data, including attendance records and contribution records

Your rights during this period: Even before a community forms, you retain full rights to:

View all records associated with your account
Delete your own records at any time
Export your data
Delete your account entirely

11. Children's Privacy (COPPA)

11.1 General Policy

The Services are not directed to children under 13. We do not knowingly collect personal information from children under 13 without verifiable parental consent.

11.2 Youth-Serving Communities

Communities that serve participants under 13 must comply with COPPA by:

Obtaining verifiable parental consent before any data collection
Providing parents with notice of what data is collected and how it is used
Allowing parents to review, delete, or refuse further collection of their child's data
Not conditioning participation on the child providing more data than necessary

11.3 Parental Rights

Parents of children under 13 can:

Review all data collected about their child
Request deletion of their child's data
Refuse further data collection
Contact us at privacy@extol.work

12. Cookies and Tracking

12.1 Essential Cookies

We use essential cookies for:

Session management (keeping you logged in)
Security (CSRF protection)
Preferences (language, display settings)

These cookies are necessary for the Services to function and cannot be disabled.

12.2 Analytics

We use privacy-respecting analytics to understand how the Services are used. We do not use third-party advertising trackers. Analytics data is aggregated and cannot identify individual users.

12.3 No Third-Party Advertising

We do not serve third-party advertisements. We do not share data with advertising networks. We do not track users across other websites.

13. International Data Transfers

Extol is based in the United States. If you access the Services from outside the US, your data is transferred to and processed in the US.

For EU/EEA users, we use Standard Contractual Clauses approved by the European Commission to ensure adequate protection of your data during transfer.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated with at least 30 days' advance notice through the platform or by email. The "Last Updated" date at the top reflects the most recent revision.

15. Contact Us

For privacy questions, data requests, or concerns:

Email: privacy@extol.work

For GDPR-related inquiries, you may also contact your local data protection authority.