Privacy Policy
What doodle stores, why, for how long, and what stays on a public ledger. Summaries below; counsel supplies the binding text.
Version 0.1-draft. This document is a structured draft prepared for counsel review before the TikTok production review submission. It is not yet in force.
1. Who we areDraft
xlink Labs, Inc. is the controller for the personal data described here. Contact details for privacy requests will be listed in the final policy.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
2. Data we holdDraft
- Account: email address and passkey credential id
- TikTok-sourced, only if you connect TikTok: open_id, union_id, username, verified badge, numeric stats. Avatars and covers are never cached.
- Wallet addresses and their public on-chain activity
- IP-derived country and region, sanctions-screening results, and an identity-verification vendor reference where required
- Push subscriptions, billing customer id, and memos you write
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
3. Why we process itDraft
- Contract: your account, and the security and money notifications that make the 72-hour wallet-change protection work
- Legitimate interest: security, screening and ranking
- Legal obligation: sanctions compliance
- Consent: marketing email and push, which you can withdraw at any time. Transactional notices are not marketing.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
4. How long we keep itDraft
- Raw video statistics 30 days; daily roll-ups 13 months
- TikTok fields purged within 24 hours after you disconnect or revoke access
- Screening results 5 years; terms acceptances 7 years
- Memos until you delete them or moderation removes them
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
5. On-chain dataDraft
When a creator links, doodle publishes a pseudonymous identifier derived from their TikTok id and a hash of their handle to a public blockchain at their request. This record is permanent and cannot be erased; unlinking removes doodle's off-chain association, TikTok-sourced fields and marketing surfaces, and erasure requests are answered within 30 days with this explanation.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
6. Automated decisionsDraft
Sponsorship of transaction fees, trust scores, wash-trading flags and regional gating are automated. They gate a free convenience and interface features, never your funds. A human review path exists through support with a five-business-day response.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
9. Your rightsDraft
Access, correction, deletion, portability and objection, handled within 30 days. EU/UK representatives will be named in the final policy.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
10. MinorsDraft
doodle is for adults. We do not knowingly collect data from anyone under 18, and accounts found to belong to minors are closed.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).
11. TikTok dataDraft
Data from TikTok is used only for the purposes described in our developer-platform application: showing your public profile and videos on your own pages and dashboard. doodle is not affiliated with or endorsed by TikTok.
Placeholder: final wording to be supplied by counsel (docs/13 §10, W4/W6 memos).