Welcome to the Dharitri project (the "Project"). This Privacy Policy describes how Dugong Global Services Pvt Ltd, a company registered in India (hereinafter referred to as "Dugong," "the Company," "we," "us," or "our"), collects, uses, shares, and protects your personal information when you ("you," "your," or "User") visit our website located at [YourWebsiteAddress.com] (the "Website"), use our staking platform at stake.dharitri.org (the "Staking Platform"), interact with our content, or contact us. The Project is known by the name "Dharitri."
The data controller responsible for your personal information is Dugong Global Services Pvt Ltd, with a registered address at P&26/P, NAVYA THE GRAND, 1-179/27, Patancheru, Rameshwar Banda, Hyderabad, Telangana 502319, India.
Important Note on Project Structure: The Dharitri Foundation referenced in our project materials does not yet exist as a legal entity and holds no current legal responsibility. All current operations and data processing are conducted by Dugong Global Services Pvt Ltd.
We are committed to protecting your privacy and strive to comply with applicable Indian data protection laws, including the Digital Personal Data Protection Act 2023 (DPDPA), as well as international data protection standards where applicable. This Privacy Policy applies to the Website, our Staking Platform, and our current informational services. Please note that the future Dharitri platform and its associated applications, as outlined in our Project Roadmap, will involve the collection and processing of different types of data. Detailed privacy information specific to that platform will be provided at the time of its launch, potentially under updated or supplementary privacy notices. The Dharitri Project may in the future be operated or governed in part by the Dharitri Foundation, once legally established in Kenya, or another designated entity; any such change affecting data control will be communicated through updates to this policy or other official notices.
We collect information in the following ways:
Contact Forms: When you contact us through forms on our Website (e.g., for general inquiries or partnership information), we collect the information you choose to provide. This may include your name, email address, and optionally, your phone number, along with the content of your message. These forms are processed on our behalf by Tally.so, a third-party service provider. We encourage you to review Tally.so's privacy policy for information on their data handling practices, available on their website.
Staking Platform (stake.dharitri.org): When you access our Staking Platform to stake pREWA tokens, we collect your wallet address to facilitate staking operations. Staking parameters (APY, lockup periods, minimum amounts) are displayed on the platform and sourced from smart contract configurations. All staking transactions are recorded on the Binance Smart Chain and become part of the public blockchain record that cannot be modified or deleted.
Website Visitors:
Cookies and Similar Technologies: We use cookies and similar tracking technologies to track activity on our Website and hold certain information. For detailed information about the types of cookies we use (including strictly necessary, performance/analytics, and marketing/targeting cookies), the specific cookies deployed, their purposes, and how you can manage your cookie preferences, please refer to our separate Cookie Policy, which forms part of this Privacy Policy.
Log Data and Analytics: When you visit our Website, your browser automatically sends information that we, or our third-party analytics providers such as Google Analytics, collect. This information may include your computer's Internet Protocol (IP) address, browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers, and other diagnostic data. This data is generally aggregated and used for analytical purposes to improve our Website.
Staking Platform Users:
The acquisition of pREWA tokens takes place on third-party decentralized exchanges, such as PancakeSwap. Dugong does not directly process these financial transactions or collect personal financial information related to such purchases through this Website. Your interactions with these third-party platforms, including any wallet addresses used, are subject to their terms and the public nature of the Binance Smart Chain.
Dugong does not currently conduct Know Your Customer (KYC) or Anti-Money Laundering (AML) checks or collect such personal information directly through this Website or Staking Platform for individuals interested in the pREWA token.
Please be aware that the future Dharitri platform, as outlined in our Project Roadmap, is designed to empower smallholder farmers. This will involve the collection by Dugong (or a future designated project entity like the Dharitri Foundation) of specific information from participating farmers and agents, such as Farmer IDs (including optional photos), farm activity data, conservation records, and potentially geospatial data. Sensitive data collected in the future will be subject to enhanced consent and security protocols, detailed in platform-specific notices. The collection of such data will always be based on explicit user consent, for specific service delivery purposes, and will be governed by detailed privacy notices provided at the time of that platform's launch.
Dugong uses the information we collect for various purposes:
Marketing and Project Updates: Information you provide through our contact forms will be used solely to respond to your direct inquiry. We do not currently use this information for unsolicited marketing communications. We may offer you the option to subscribe to project updates or newsletters in the future, for which we will obtain your explicit consent if you choose to subscribe.
Dugong does not sell your personal information. We may share your personal information collected through this Website and Staking Platform in the following situations:
We may share your personal information with third-party service providers to monitor and analyze the use of our Website and Staking Platform, to provide website hosting, to process data submitted through forms, and to perform other services on our behalf. These include:
These service providers are authorized to use your personal information only as necessary to provide these services to us and are expected to comply with data protection obligations.
Staking activities involve smart contract interactions that are permanently recorded on public blockchains. While we don't share your personal information with third parties, your wallet addresses and transaction details become part of the public Binance Smart Chain record, which is accessible to anyone through blockchain explorers and cannot be modified or deleted.
Dugong may disclose your personal information if required to do so by law or in response to valid requests by public authorities (e.g., a court or a government agency). We may also disclose your information in the good faith belief that such action is necessary to:
For the future Dharitri platform, any sharing of farmer or agent data (e.g., with partner NGOs, Cooperatives for verification, or with Microfinance Institutions for loan applications based on farmer consent) will occur only with explicit user consent, for specific, disclosed purposes, and will be detailed in that platform's specific privacy notices at that time.
Dugong takes reasonable administrative, technical, and physical security measures to protect your personal information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
In the event of a data breach that poses risks to user rights and freedoms, we will notify affected users and relevant regulatory authorities within 72 hours of becoming aware of the breach (GDPR requirements) or 48 hours (Kenya DPA requirements), as applicable.
We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law.
Once the retention period expires, personal data shall be appropriately disposed of or anonymized. The rights to access, erasure, rectification, and data portability cannot be enforced after the expiration of the relevant retention period if the data has been deleted. Note that blockchain-recorded data cannot be deleted regardless of retention periods.
Depending on your location and applicable data protection laws, you may have certain rights regarding your personal information. These may include:
For EU Residents: GDPR rights apply to your personal data. You may contact us at privacy@dharitri.org for data protection inquiries.
Important Limitation: Please note that data recorded on blockchain networks (including staking transactions and wallet addresses) cannot be modified, deleted, or restricted by us or any other party due to the immutable nature of blockchain technology.
To exercise any of these rights, please contact us at privacy@dharitri.org. We may need to request specific information from you to help us confirm your identity before responding to such requests. We will respond to your request within a reasonable timeframe and in accordance with applicable law.
Your information, including personal data collected through this Website and Staking Platform, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.
Specifically, by using our Website and Staking Platform and submitting information through them, you acknowledge that your data may be processed in:
If you are located outside India and choose to provide information to us, please note that we transfer the data, including Personal Data, to India and process it there, as well as in other locations as described. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Dugong will take steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
Our Website and services are not directed to anyone under the age of 18. We do not knowingly collect personally identifiable information from children under 18. If you are a parent or guardian and you are aware that your child has provided us with personal data, please contact us. If we become aware that we have collected personal data from a child under the age of 18 without verification of parental consent, we will take steps to remove that information from our servers. Please note that any blockchain transactions cannot be removed once confirmed.
Our Website may contain links to other websites that are not operated by us (e.g., links to PancakeSwap for pREWA token acquisition, our social media channels, Tally.so, blockchain explorers, or other third-party resources). If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. Dugong has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date at the top of this Privacy Policy.
If we make material changes to this Privacy Policy, we will provide a more prominent notice (for example, by adding a statement to our homepage or by sending you a notification if we have your email address and are permitted to contact you for such purposes based on prior consent).
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy or our data protection practices, please contact us:
By email: privacy@dharitri.org
Grievance Officer: For complaints or concerns related to data processing that cannot be resolved through our general contact, you may escalate to our designated grievance officer at the same email address with "Grievance" in the subject line. We will address grievances within a reasonable timeframe as per applicable Indian data protection regulations.
By mail:
Dugong Global Services Pvt Ltd
P&26/P, NAVYA THE GRAND, 1-179/27,
Patancheru, Rameshwar Banda,
Hyderabad, Telangana 502319, India
Dharitri