Effective: March 8, 2026
We at ELOOP Foundation, c/o MULLER PAPARIS AG, Bundesstrasse 5, 6300 Zug, a Swiss foundation ("us," "we," "our," or the "Company") recognize the importance of protecting privacy rights, and information relating to an identified or identifiable natural person ("Personal Information" or "PII" or "Personal Data") collected about you and other users (collectively, "Users") through the Teneo Node desktop application (the "Application") and our website (the "Site"). We are committed to ensuring that your privacy is protected. To that end, this Privacy Policy ("Policy") discloses our practices regarding the collection, use, and disclosure of the PII we receive through your use of the Application and the Site. Unless otherwise expressly agreed to in writing, your Personal Information will be processed according to the terms of this Policy. Defined terms used but not defined herein have the meaning set forth in the Terms of Service.
This Policy is drafted to comply with the California Consumer Privacy Act ("CCPA") (as amended by the California Privacy Rights Act), with the E.U. General Data Protection Regulation (EU) 2016/679, the U.K. GDPR (collectively, the "GDPR") and the Swiss Federal Act on Data Protection ("FADP"). However, the application of these laws depends on each individual case. Users of the Application are under no statutory or contractual obligation, or other obligation to provide PII to us. For the purposes of compliance with the GDPR and the FADP, we are the data controller of information we collect from data subjects through the Application. For the purposes of this Policy, "data subject" means an identified or identifiable natural person.
This Policy applies to the Application, the Site (https://teneo.pro/), its subdomains, and all the websites and applications owned or operated by us. This version of the Policy replaces and supersedes any prior privacy policies applicable to the Application.
By installing and running the Application, you hereby consent to this Privacy Policy and agree to its terms.
The information that we collect depends on your interactions with us, the choices that you make, the products and features you use, your location, and applicable laws. We collect only essential data required to operate the Application, support the Teneo Network, and ensure its functionality.
We are the sole owner of information collected through the Application. We collect several types of information from and about Users, including:
(A) Personal Information. We may collect PII when you create an account, log in to the Application, or interact with our Services. We do not collect Sensitive PII about you.
The types of PII we have collected, used, stored, and disclosed in the last twelve (12) months include the following categories of information:
| Category | Type(s) of Information | |----------|----------------------| | Identifiers | Email Address, IP Address, and other identifiers | | Internet or Other Similar Network Activities | Node online status, connection uptime, bandwidth contribution metrics, and interactions with the Application |
(B) Device and Network Information. To ensure the security, integrity, and proper functioning of the Network, the Application may collect the following technical information about your device and network:
- Node Online Status: We monitor whether your node is active, which helps in assessing network performance and connectivity. - Bandwidth Metrics: We collect data regarding the volume of network traffic routed through your device in connection with the Teneo ecosystem, including traffic from authorized enterprise participants. This data is used to calculate Teneo Points, enforce fair-use policies, and to optimize Network operations. We do not inspect or store the content of traffic routed through your device. - Device Fingerprint: We may collect technical identifiers related to your device (such as operating system, hardware characteristics, and application version) for the purpose of preventing abuse, detecting fraud, and ensuring the security of the Network. Device fingerprints are used for identification and verification purposes only. - IP Address and Geolocation: Your IP address is collected to facilitate network connectivity, enforce geographic restrictions, and ensure compliance with applicable laws and sanctions requirements. We may derive approximate geolocation information from your IP address. - Connection Metadata: We collect metadata about your connection to the Network, including connection timestamps, session duration, and protocol-level data necessary for network operations.
(C) Deidentified Information. We may collect deidentified information and aggregate information that may not by itself reasonably identify you as the source ("Deidentified Information"). Deidentified Information may include: (i) device type; (ii) device operating system; (iii) application version; (iv) connection quality metrics; and (v) aggregate network performance data. We will take reasonable measures to ensure that Deidentified Information we collect is not personally identifiable as required by applicable law.
(D) Children's Information. We do not offer our Services to, nor do we intentionally collect or retain PII from, children who are younger than 18 years of age. If we discover that we have inadvertently collected information from a child under 18 years of age, we will promptly take all reasonable measures to delete such information from our systems.
(E) Credential Storage. The Application stores your authentication credentials (such as access tokens) locally on your device using your operating system's secure credential storage (e.g., keychain, credential manager). These credentials are not transmitted to us and remain under your control.
(F) Other Information. We may collect technical data such as blockchain wallet addresses and network transactions in connection with Teneo Points and Network participation.
We collect PII and Deidentified Information in various ways, including:
(A) Directly from You. We collect PII when you create an account, log in through the Application, or contact us.
(B) Through Your Use of the Application. We collect PII and Deidentified Information automatically when you run the Application, including node status, bandwidth metrics, connection data, and device information as described above.
(C) From Third-Party Services. We may collect PII about you from third parties whose privacy practices may differ from the practices described in this Policy, including authentication providers. We encourage you to carefully review the privacy policies of such third parties.
We may use Users' PII for lawful business purposes: (i) as necessary for the performance of our contract with Users, (ii) for our legitimate interests, so long as they are not overridden by Users' own rights and interests, or (iii) as required by law. These purposes include:
(A) Service Operation. We may use your PII and/or Deidentified Information to operate, administer, provide, maintain, and deliver the Application and our Services, including network connectivity, Teneo Points calculation, and resource allocation within the Network.
(B) Network Optimization. We may use your connection data, bandwidth metrics, and device information to optimize the performance, reliability, and security of the Teneo Network.
(C) Security and Fraud Prevention. We may use your PII, device fingerprint, and IP address to detect and prevent abuse, fraud, unauthorized access, and violations of our Terms of Service. This includes enforcing geographic restrictions, verifying node authenticity, and preventing manipulation of the Network.
(D) Customer Service and Communications. We may use your PII to respond to your inquiries, provide support, and communicate important updates about the Application or the Network.
(E) Business Optimization. We may use Deidentified Information to improve the Application, analyze usage patterns, and enhance the overall functionality of the Network.
(F) Legal Compliance. We may use your PII to comply with applicable laws, regulations, and legal processes, including sanctions compliance.
(G) For Any Other Purposes with Your Consent.
We will not collect additional categories of PII or use PII we collected for materially different, unrelated, or incompatible purposes without providing you notice.
We do not sell, rent, lease, or share PII, and will not disclose Users' PII to third parties without your permission. We may disclose Users' PII to third parties for a business purpose as described below:
(A) To Affiliates. We may disclose your PII to affiliates, including entities within the Company. Any PII that we provide to our affiliates will be treated by those affiliates in accordance with the terms of this Policy.
(B) To Service Providers. We may disclose your PII to third-party service providers that require access to information to support our operations and delivery of the Application and our Services.
(C) Law Enforcement, Safety, and Legal Processes. We may disclose your PII to law enforcement or other government officials if it relates to a criminal investigation or alleged criminal activity. We may also disclose your PII: (i) if required or permitted to do so by law; (ii) for fraud protection and risk reduction purposes; (iii) in the good-faith belief that such action is necessary to protect our rights, interests, or property; (iv) in the good-faith belief that such action is necessary to protect your safety or the safety of others or the public; or (v) to comply with a judicial proceeding, court order, subpoena, or other similar legal, arbitration, or administrative process.
(D) Sale or Acquisition of Assets. If we become involved in a transaction involving the sale of our assets, such as a merger or acquisition, or if we are transferred to another company, we may disclose and/or transfer your PII as part of the transaction.
(E) Any Other Party with Your Consent.
The Application does not use cookies. However, any associated websites or services (such as the Site) may utilize cookies, which will be covered in their respective privacy policies.
The security and confidentiality of your PII is important to us. We use commercially reasonable administrative, technical, and physical security measures to protect your PII from unauthorized or unlawful access, use, modification, destruction, loss, alteration, and/or disclosure. However, no data transmitted over or accessible through the internet can be guaranteed to be 100% secure. As a result, while we attempt to protect your PII, we cannot guarantee or warrant that your PII will be completely secure from misappropriation by hackers or from other nefarious or criminal activities, or in the event of a failure of computer hardware, software, or telecommunications networks.
We will retain Users' PII while they maintain an account or as long as the Application remains installed and active, and to the extent necessary to provide the Services. Thereafter, we will keep PII for as long as reasonably necessary: (i) to respond to any queries from Users; (ii) to demonstrate we treated Users fairly; (iii) for ordinary business continuity procedures; or (iv) to comply with any applicable laws.
When we no longer have an ongoing legitimate business need to process your PII, we will either delete or anonymize it.
(A) GDPR and FADP Data Subject Rights
You have various rights in relation to our processing of your PII, depending on the applicable data protection law:
- Right to Access: You have the right to request a copy of your PII. - Right to Rectification: You have the right to request that we correct any mistakes in your PII. - Right to Erasure: You have the right to request that we delete your PII. - Right to Restrict Processing: You have the right to restrict processing of your PII. - Right to Object to Processing: You have the right to object to our processing of your PII. - Right to Data Portability: You have the right to receive your PII in a structured, commonly used and machine-readable format. - Right Not to be Subject to Automated Individual Decision Making: You have the right not to be subject to a decision based solely on automated processing.
To exercise your rights, please use the Verifiable Consumer Request method described below.
(B) US State Law Privacy Rights
In some states, you are granted additional protection under your state privacy laws. Your rights may include the:
- Right to Access: You have the right to request a copy of the specific pieces of PII that we have collected about you in the previous twelve (12) months. - Right to Data Portability: You have the right to receive your PII in a portable, readily usable format. - Right to Correct Inaccurate Information: You have the right to request that we correct inaccurate information about you. - Right to Deletion: You have the right to request that we delete your PII. - Right to Be Free from Discrimination: You have the right not to be discriminated against by us for exercising any of your rights under state privacy laws.
To exercise your rights, please use the Verifiable Consumer Request method described below.
(C) Additional Privacy Rights
California's "Shine the Light" law permits Users that are California residents to request certain information regarding our disclosure of PII to third parties for their direct marketing purposes. To make such a request, please contact us with the contact information provided below.
If you are a California resident or a data subject located in the EEA or Switzerland, you can exercise your legal rights by submitting a Verifiable Consumer Request to us by emailing us at support@teneo.pro.
Only you, or someone legally authorized to act on your behalf, may make a Verifiable Consumer Request related to your PII. The Verifiable Consumer Request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with PII if we cannot verify your identity or authority to make the request and confirm the PII relates to you.
Generally, we do not process PII based on consent. However, in the event we do, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on said consent before its withdrawal. If you would like to withdraw your consent, please use the Verifiable Consumer Request method described above.
To deliver our Services through the Application, it may be necessary for us to share data subjects' PII outside the EEA or Switzerland. We may share PII with Company affiliates and service providers located in the United States and around the world. In the event we transfer PII outside the EEA or Switzerland, we will do so in accordance with the terms of this Policy and applicable data protection law. Our standard practice is to use standard contractual clauses approved by the European Commission and the UK Information Commissioner's Office, if applicable and required, to facilitate such data transfers.
The Application may contain links to other websites or services ("Linked Sites") that are not owned by the Company. We do not control the collection or use of any information, including PII, which occurs while you visit Linked Sites. We encourage you to be aware of when you leave the Application and read the privacy policies of Linked Sites.
We reserve the right to update this Policy from time to time in our sole discretion. If our privacy practices change materially, we will post an updated version of the Policy. It is your responsibility to review this Policy for any changes. Any modifications to this Policy will be effective upon our posting of the updated terms.
If you would like to file a complaint with us about our privacy practices, please contact us at the Contact Information provided below. If you are a data subject located in the EEA or Switzerland, the GDPR, respectively the FADP grants you the right to lodge a complaint with a competent supervisory authority. To find a competent supervisory authority, please use the following resources:
- EU: https://edpb.europa.eu/about-edpb/board/members_en - UK: https://ico.org.uk/global/contact-us/ - Switzerland (FDPIC): https://www.edoeb.admin.ch/en/contact-2
If you have questions about this Policy or wish to contact us, please contact us at:
ELOOP FOUNDATION support@teneo.pro