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LEGAL / 01 PRIVACY

HOW HETIM HANDLES PERSONAL DATA

Privacy
policy.

Information about how Hetim handles personal data across its website, products, Intelligence service, support, licensing, and payment services.

Effective date01.09.2026
Last updated01.09.2026
CONTENTS / 16
01Data controller 02Local-first model 03Data collected 04Processing purposes 05Not collected 06Data sharing 07Retention 08Security 09Your rights 10Attribution requests 11Organizations 12Children 13Automated decisions 14Changes 15Contact

This Privacy Policy explains how Davide Marzano, operating under the name Hetim (“Hetim”), processes personal data when you:

  • visit hetim.app or another Hetim website
  • purchase, download, activate, or use Hetim Viewer or Hetim Investigator
  • use Hetim Intelligence
  • contact us for support or other enquiries or
  • interact with our account, licensing, update, or payment services.
01

Who is responsible for your data?

The data controller is:

Davide Marzano Trading as: Hetim Email: privacy@hetim.app
02

Hetim’s local-first model

Hetim is designed as a local-first cryptocurrency investigation application.

Investigation files, Workspaces, graphs, notes, imported transaction data, investigator labels, approved attribution evidence, and locally generated reports are normally stored on your device or in storage locations you choose.

Local by default

Hetim does not automatically upload complete Investigation files to us.

We do not normally receive or have access to your local case contents unless:

  • you intentionally submit files or information to us for support
  • you use a feature that sends a specific query to Hetim Intelligence
  • you configure a third-party data provider
  • you export or share information through a service outside Hetim

Organizations using Hetim are responsible for determining whether they are permitted to collect and process the personal data contained in their Investigations.

03

Personal data we may collect

3.1 Account, purchase, and licensing data

When you purchase Investigator or subscribe to Hetim Intelligence, we may process:

  • your name
  • email address
  • organization
  • billing country
  • order and subscription information
  • product edition
  • license or entitlement identifier
  • activation status
  • subscription dates
  • payment status.

For Investigator activation and update checks, the app sends your purchase license key to Hetim’s licensing service, which verifies the key with Payhip. The app stores the signed offline license on your device and uses the operating system’s credential store for the purchase key used for updates.

Payment card information is normally processed directly by Payhip. We should not receive your complete payment-card number.

3.2 Hetim Intelligence queries

When Hetim sends a query to Hetim Intelligence, we may process:

  • blockchain network
  • wallet address, transaction hash, or other query identifier
  • query time
  • application and API version
  • entitlement or account identifier
  • response status
  • rate-limit and usage information
  • security and abuse-prevention signals and
  • limited technical logs necessary to provide and protect the service.

Blockchain addresses and transaction information may relate to identifiable individuals when combined with other information.

We do not use Investigation contents for unrelated advertising.

Our infrastructure and security providers may temporarily process limited request metadata and technical logs on our behalf where necessary to deliver, secure, maintain, and diagnose the service.

Hetim does not intentionally store raw wallet addresses, transaction hashes, or other query identifiers as a history of your searches after returning the requested response.

3.3 Intelligence review submissions

Users may submit proposed blockchain attributions, labels, corrections, sources, comments, or supporting evidence for review.

When you make an intelligence review submission, we may process:

  • the relevant blockchain network
  • wallet addresses, transaction identifiers, entities, or services
  • the proposed attribution, label, category, or correction
  • supporting links, documents, screenshots, comments, or reasoning
  • source and provenance information
  • your account or contact information, where provided
  • submission and review timestamps
  • the review decision and related reviewer notes and
  • limited technical, security, and abuse-prevention information.

We use this information to assess the accuracy, reliability, provenance, relevance, and suitability of proposed intelligence records.

Pending submissions are retained until reviewed and ordinarily for no longer than 180 days.

Rejected, discarded, or withdrawn submissions are normally deleted within 30 days after the review decision.

We may retain a limited audit record, such as the submission identifier, decision, date, and relevant security or abuse-prevention information, for up to 12 months where necessary to maintain review integrity, prevent repeated abuse, resolve disputes, or comply with legal obligations.

Approved submissions may be incorporated into Hetim Intelligence as curated intelligence records. Approved records and their supporting provenance may be retained while they remain necessary, relevant, sufficiently supported, accurate, and lawful for providing Hetim Intelligence.

Approved records may later be corrected, qualified, superseded, restricted, or removed following further review or a substantiated correction request.

We do not use intelligence review submissions for advertising or unrelated profiling.

3.4 Third-party provider queries

Hetim Investigator may allow you to connect your own accounts or API keys for supported blockchain and intelligence providers.

When you use such a provider:

  • Hetim may send addresses, transaction identifiers, network details, and request parameters directly to that provider
  • the provider processes the request under its own terms and privacy policy
  • the provider may record your IP address, API key, query, and usage details and
  • Hetim is not responsible for the provider’s independent processing.

Provider credentials are intended to be stored separately from Investigation files, using the operating system’s secure credential storage where supported.

3.5 Support and communications

When you contact us, we may process:

  • name and contact information
  • organization
  • correspondence
  • diagnostic information
  • application version and operating system
  • purchase or license information and
  • files or case information you voluntarily provide.

Do not send Investigation files, wallet addresses, personal data, credentials, or confidential evidence unless necessary and expressly requested.

3.6 Website and security data

When you visit our websites or use online services, we may process:

  • IP address
  • browser and device type
  • requested pages
  • timestamps
  • referring page
  • security events
  • server errors and
  • consent preferences.

We use this information to operate the website, prevent abuse, diagnose problems, and protect our systems.

3.7 Cookies and similar technologies

We may use strictly necessary cookies or local storage to provide essential functions, such as session security, authentication, checkout, language, or consent preferences.

A separate cookie notice will identify any cookies actually used, their purposes, providers, and retention periods.

04

Why we process personal data

We may process personal data for the following purposes:

Purpose Typical legal basis
Providing downloads, accounts, licenses, activation, and paid services Performance of a contract
Processing purchases and subscriptions Performance of a contract and legal obligations
Responding to support requests Performance of a contract or legitimate interests
Delivering Hetim Intelligence responses Performance of a contract
Preventing fraud, abuse, attacks, or license misuse Legitimate interests
Maintaining security logs and investigating incidents Legitimate interests and legal obligations
Sending service, security, and account communications Performance of a contract or legitimate interests
Sending optional marketing communications Consent, where required
Maintaining accounting and transaction records Legal obligations
Establishing, exercising, or defending legal claims Legitimate interests or applicable law

Where we rely on legitimate interests, we balance our interests against your rights and reasonable expectations.

Where processing is based on consent, you may withdraw that consent at any time without affecting earlier lawful processing.

05

Information we do not intentionally collect

We do not intentionally require or collect:

  • private cryptocurrency keys
  • wallet recovery phrases
  • exchange passwords
  • complete payment-card details
  • passwords for third-party providers or
  • credentials inside Investigation files.
Never enter wallet seed phrases or private keys into Hetim.

We do not sell personal data.

06

How we share personal data

We may share limited personal data with service providers that help us operate Hetim, including:

  • payment and merchant-of-record providers
  • account and licensing providers
  • website and infrastructure hosts
  • transactional email providers
  • error-monitoring or security providers
  • customer-support tools
  • professional advisers and
  • public authorities where legally required.

Current providers should be listed here or in a separate subprocessor list:

Payments
Payhip, Stripe, PayPal
Website hosting
Cloudflare
Hetim infrastructure
Cloudflare

Service providers may process data only for the agreed purpose and under appropriate contractual protections.

We may also disclose information:

  • to comply with binding legal obligations
  • to protect users, Hetim, or others from fraud or security threats
  • in connection with a merger, acquisition, restructuring, or asset sale or
  • with your instructions or consent.
07

Retention

We retain personal data only for as long as necessary for the stated purpose, including:

Account information
while the account remains active and for 12 months afterward
Purchase and accounting records
for the period required by applicable accounting and tax law
Investigator’s signed offline license
Stored on your device.
Intelligence query logs
No retention.
Intelligence review submissions
Retention might vary.
Support correspondence
12 months after the request is closed
Marketing consent records
until withdrawal and for the period needed to demonstrate compliance

Local Investigation files remain under the user’s control and are not deleted by closing a Hetim account unless the files were separately uploaded to a Hetim-operated service.

We may retain information longer where required by law, a dispute, fraud prevention, or security investigation.

08

Security

We use technical and organizational measures intended to protect personal data, including, where appropriate:

  • encryption in transit
  • access controls
  • secure credential storage
  • cryptographic verification of desktop updates
  • restricted administrative access
  • logging and abuse detection
  • vulnerability management
  • backups and
  • data minimization.

No system can guarantee absolute security. Users remain responsible for protecting their devices, operating-system accounts, Investigation files, backups, provider credentials, and exported reports.

09

Your rights

Depending on applicable law, you may have the right to:

  • receive information about our processing
  • access your personal data
  • correct inaccurate data
  • request deletion
  • restrict processing
  • object to processing based on legitimate interests
  • receive certain information in a portable format
  • withdraw consent
  • object to direct marketing and
  • complain to a supervisory authority.

Privacy information must be clear, accessible, and sufficient for individuals to exercise these rights.

To exercise a right, contact privacy@hetim.app. We may need to verify your identity before acting on the request.

10

Blockchain attribution and correction requests

Public blockchain information is generally permanent, but Hetim-controlled attribution records may be corrected, qualified, or updated.

If you believe that Hetim Intelligence incorrectly associates a blockchain address with you or another identifiable person, contact:

privacy@hetim.app

Include:

  • the relevant network and address
  • the disputed attribution
  • the reason you believe it is inaccurate
  • supporting information and
  • a safe method for us to respond.

We may preserve historical evidence, source information, or dispute records where necessary for accuracy, security, legal claims, and auditability. Correcting a Hetim attribution does not modify the underlying public blockchain.

11

Organizational customers

Where an organization uses Hetim to investigate blockchain activity, that organization normally determines:

  • what information is entered into an Investigation
  • why it is processed
  • how long it is retained
  • who may access it and
  • whether it is shared or included in a report.

In those circumstances, the organization is generally responsible for responding to privacy requests concerning the content of its local Investigations.

Where Hetim processes personal data solely on an organization’s documented instructions, the parties may enter into a data-processing agreement.

12

Children

Hetim is intended for professional and educational use and is not directed to children under 16.

We do not knowingly collect children’s personal data through accounts or marketing services. Contact us if you believe a child has provided personal data to us.

13

Automated decision-making

Hetim provides investigation, visualization, attribution, and reporting tools.

Hetim Intelligence results should be treated as investigative context rather than automatic proof of ownership, wrongdoing, legal status, or identity.

We do not use account or website personal data to make decisions producing legal or similarly significant effects solely through automated processing.

14

Changes to this policy

We may update this Privacy Policy when our products, providers, legal obligations, or processing practices change.

We will publish the updated version with a revised effective date. Where a change materially affects your rights or how we use personal data, we will provide additional notice where appropriate.

15

Contact

Questions, complaints, correction requests, or privacy-rights requests may be sent to:

Davide Marzano Email: privacy@hetim.app Support: support@hetim.app
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