urble Privacy Policy
Privacy Policy
Last updated July 31, 2025
1. General & Scope
This Privacy Policy describes how personal data of Users and/or visitors (individually and collectively, the "User(s)") who access, visit, or register on the urble platform via the website urble.io (the “Website”) or the mobile application (the “Mobile App”) is processed. The Website and Mobile App are collectively referred to as the "Apps".
The Apps are operated by Brick Towers AG, a company incorporated under the laws of Switzerland, with company registration number CHE-378.414.731, and registered office at Baarerstrasse 12, 6300 Zug, Switzerland ("urble", "we", "us", or "our").
We process your personal data in accordance with applicable data protection laws, including the Swiss Federal Act on Data Protection (FADP) and, where applicable, the General Data Protection Regulation (EU) 2016/679 (GDPR).
This Privacy Policy outlines the purposes and methods of data processing, the types of personal data collected, and your rights as a data subject.
What is Personal Data? Personal data refers to any information that identifies you directly (e.g., name, email address, residential address) or indirectly (e.g., unique ID numbers, IP addresses, or pseudonymized data).
We are committed to collecting and processing only the minimum amount of personal data necessary for operating our services.
This Privacy Policy is originally drafted in English and may be translated into other languages. In the event of any discrepancies, the English version shall prevail.
2. Who are the Data Controller and the Data Protection Officer?
The data controller for personal data processed via the urble Apps is:
Brick Towers AG
Baarerstrasse 12, 6300 Zug, Switzerland
Email: privacy@bricktowers.io
In accordance with the Swiss Federal Act on Data Protection of 25 September 2020 (“FADP”) and the General Data Protection Regulation (EU) 2016/679 (“GDPR”), urble has appointed a Data Protection Officer (DPO). The DPO may be contacted at the same email address: privacy@bricktowers.io.
At this time, urble is not required to appoint a representative within the European Economic Area (EEA) under Article 27 GDPR, as our processing of personal data is occasional, does not include large-scale processing of special categories of data under Article 9(1) or data relating to criminal convictions under Article 10, and is unlikely to result in a risk to the rights and freedoms of natural persons.
urble engages selected third-party data processors for the provision of services related to the operation of the Apps.
3. What categories of personal data does urble process?
We may collect the following personal information when you use the Services:
Data you provide us
| Information Category | Description |
|---|---|
| Basic Personal Information | Name, email address, phone number if you choose to provide them. |
| urble User Profile Information | urble User profile information, including Username, display name. |
| Financial Information | We may collect certain financial information, including your account balance and payment methods to facilitate transactions you may make through our Services. |
| Transaction Information | Information about the transactions made on our Services, such as the name of the sender, the name of the recipient, the amount, currency preferences, payment method, date, and/or timestamp. |
| Wallet Information | When you sign up for a urble Account or our Services, we may collect your wallet addresses. We do not store private keys – users bear sole responsibility for their security, but we provide educational resources on best practices. Please note that this information is stored on-chain and is therefore publicly accessible. |
| Content You Share | Content you share on the Services, including your avatar, your posts and your likes and replies. |
| Referral Information | Referrer wallet address, referees wallet address, referral payout data. |
| Settings | Your selected settings and preferences within the App. |
| Address Book Data | Address book, which may include your contacts' information, including name, phone numbers if you choose to sync your contacts. |
| Customer Support Information | We may collect information you disclose when you interact with our customer support team, including call recordings or messages exchanged through interfaces such as chatbots. If you report content or behavior within the app, we may collect details about you and your report. |
Information collected automatically
| Information Category | Description |
|---|---|
| Product Usage Information |
Activity Information: Information about what you view or click on and how you use our
Services. Diagnostic and Troubleshooting Information: Information about how our Services are performing when you use them, i.e. service-related diagnostic and performance information, including timestamps, crash data, website performance logs, and error messages or reports. |
| App, Browser, and Device Information | We may collect device-specific information when you install, access, or use our Services. This may include other device characteristics or identifiers, your IP address and, if you choose to allow push notifications through the urble App, your device's unique push token as well as any authentication, access, or refresh tokens generated during your interaction with the Services. |
| Rewards | To issue rewards we will collect your wallet address, recipients wallet address, and earnings. |
| Information from cookies and similar technologies | We use only essential, functional, and performance cookies that are necessary for the proper operation of our website and Services. These cookies enable core features such as security, network management, and accessibility. |
Information we collect from third parties
| Information Category | Description |
|---|---|
| On-ramp Services Provider ("Affiliates") | If you choose to use our integrated On-ramp services, we may collect certain information including: Basic Personal Information, Financial Information, Transaction Information and Product Usage Information, from our Affiliates as a normal part of conducting business. |
| Virtual Account Number (VAN) | We collect your KYC status (approved, rejected). |
| Blockchain Data | We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, gas information, NFT data, and wallet addresses. |
| Information from Analytics Providers | We receive information about your usage on our Services, interactions, age group, and survey responses (including prior to account creation, in some cases). |
4. What Are the Purposes of the Processing and the Legal Basis?
4.1 Registration on the Mobile App and Creation of a Personal Account
Legal Basis: Article 6(1)(b) GDPR and/or Article 31(2)(a) FADP.
- Register on the urble Mobile App and create/manage their personal account;
- Access and use urble’s core functionalities, such as buying and selling digital assets (e.g., Cardano, Bitcoin, Ethereum);
- View transaction history, account movements, and communications from urble;
- Receive technical and customer support related to the use of the App;
- Verify their identity and account to comply with legal requirements (e.g., submission of identity documents, proof of address, KYC checks).
4.2 Fulfillment of legal obligations
Legal Basis: Article 6(1)(c) GDPR.
- The data processing legal basis is the need to comply with a legal obligation to which the Data Controller is subject.
- The personal data will be processed by urble for the fulfillment of the legal obligations imposed on urble by virtue of civil, fiscal and accounting regulations, as well as in the field of anti-money laundering, prevention of terrorist financing, and to respond to any requests for information from national and supranational authorities.
4.3 Marketing and Promotional Activities
Legal Basis: Article 6(1)(a) GDPR and/or Article 31(1) FADP.
With the User’s explicit consent, we may process their personal data for the following promotional purposes:
- Sending newsletters, product updates, or offers via email, SMS, or push notifications;
- Invitations to urble-hosted events or community programs;
- Market research and satisfaction surveys related to urble’s services.
In pursuit of its legitimate interests and provided these do not override the fundamental rights and freedoms of the User, urble may process the User’s email address to send limited promotional communications regarding similar services or products, as permitted under Article 6(1)(f) GDPR and Article 3(1)(o) of the Swiss Unfair Competition Act (UWG).
4.4 Profiling
Legal Basis: Article 6(1)(a) GDPR and Article 31(1) FADP.
The personal data of the User may be processed for profiling activities, which may include partly automated processing, for the following purposes:
- To develop or analyze profiles based on the User’s preferences;
- To personalize the User’s experience with the services provided by urble.
Such profiling activities do not result in decisions producing legal effects or similarly significant impacts on the User, as defined in Article 22(1) GDPR.
The User has the right, at any time, to withdraw consent to profiling, object to profiling, request human intervention in automated decisions, and access, correct, or delete data used for profiling.
4.5 Contact Requests and Appointment Scheduling
Legal Basis: Article 6(1)(b) GDPR and/or Article 31(2)(a) FADP.
- If the User submits a request for further information or schedules an appointment, we process their contact and contextual data to fulfill the request;
- Any follow-up processing will only occur with appropriate notice and, where required, consent.
5. Am I obliged to provide my personal data? What happens if I refuse to do so?
The disclosure of the User’s personal data for the purposes in Section 3 is optional but necessary to register on the urble App and create your account. Failure to provide it will make it impossible to establish or continue a contractual relationship.
The provision of data for purposes in Sections 4.3, 4.4, and 4.5 is optional and refusal will have no consequence on registration or contractual relationships but will prevent promotional communications, profiling, and appointment scheduling.
Users may revoke consent or object to processing at any time by sending a written request to the contact details in Section 10.
6. What are the ways in which my personal data are processed?
Personal data are processed lawfully, correctly, and transparently, for specific, explicit, and legitimate purposes, in compliance with applicable laws.
Data are mainly processed electronically and, in some cases, in paper format.
7. Who are the recipients of my personal data?
Recipients include:
- urble personnel, collaborators, and consultants appointed as processors with written instructions;
- Third-party service providers (e.g., CRM, hosting, instant messaging);
- Independent entities such as banking institutions, tax consultants, regulatory and judicial authorities.
For a complete and updated list, contact us at the details in Section 1.
8. How long do you keep my personal data?
- Data from Section 3: for the duration of the contractual relationship and 5 years thereafter (AML requirements under Swiss law);
- Marketing data (Section 4.3): 1 year from consent or until withdrawal;
- Profiling data (Section 4.4): 6 months from consent, unless cancelled earlier.
9. How do you handle the transfer of personal data to third parties?
Data will not be transferred outside the EU or other adequate jurisdictions, except under Standard Contractual Clauses, adequate guarantees under Art. 46 GDPR, or exceptions under Art. 49 GDPR. Transfers to the US under the EU-US Data Privacy Framework are considered adequate.
10. How can I exercise my rights?
Under Articles 15–22 GDPR and Articles 25–29 FADP, Users may:
- Request access, rectification, or erasure of personal data;
- Obtain restriction or portability of processing;
- Object to processing based on legitimate interests;
- Withdraw consent at any time;
- Not be subject to solely automated decisions with legal effects;
- Lodge complaints with supervisory authorities (EU or Swiss FDPIC).
Requests are free of charge; urble may ask to verify identity before acting.
11. Who can I contact to exercise my rights and for more information?
To exercise your rights or for more information, contact: privacy@bricktowers.io
12. What about …..?
12.1 Cookies
We use cookies to enable security, network management, and accessibility. For details, read our Cookie Policy.
12.2 Social Media
The Apps can be reached via urble’s social media pages. This Privacy Policy does not cover the social platforms’ own processing; refer to their policies.
Who is responsible in such cases?
urble is responsible for data you share directly on social media. Other platforms process data under their own terms, for which urble is not liable. For opt-out and more information, see the platforms’ policies below:
12.3 Security measures
urble takes appropriate physical, electronic, and managerial measures (secure servers, encryption in transit and at rest, access controls) to protect your personal data from unauthorized access, loss, or alteration.
May attention: Upon first launching the Mobile App, it creates an encrypted digital wallet (private key) for each User. urble does not have access to your private keys or funds. You are responsible for keeping your private key confidential. Loss of your private key results in loss of your crypto assets.
13. If I am a minor, can I use the Apps?
Minors may use the urble Apps with prior consent and supervision of a parent or legal guardian. Where required by law, urble will verify parental consent. Parents/legal guardians are responsible for monitoring their child’s use.
14. Is the Privacy Policy subject to change or update?
This Privacy Policy may be modified due to regulatory changes. We invite you to review it periodically for the latest information.