Privacy notice
Version 2026-10-18. This notice covers hodlflow: Scope, the HTTP API, the MCP server and the key page at api.hodlflow.app/key.
In short: we keep your account, a count of what you use, and the annotations you choose to send from Scope. We do not keep the addresses, transactions or search text you look up. Usage records are deleted after 90 days.
Who is responsible
Section titled “Who is responsible”Hansung Onchain Data Lab, Seoul, Republic of Korea, decides how this data is used (the controller). Privacy officer (privacy questions and complaints): the Hansung Onchain Data Lab privacy office, privacy@hodlflow.app.
What we keep, why, and for how long
Section titled “What we keep, why, and for how long”| Data | Why | Legal basis (GDPR) | How long |
|---|---|---|---|
| Account: your Google e-mail address (passed on by Cloudflare Access), user id, tier, status, sign-up and decision dates, the terms version you accepted; organisation and purpose if you give them | Run your account, apply your tier and limits, answer you | Contract | While your account exists. If we decline or revoke an account, we keep its e-mail address and the decision for 1 year so that it cannot sign up again |
| Sign-up check: keyed hashes of your IP address and of its network (/24 or /48), and the country Cloudflare reports | Stop automated and repeated sign-ups | Legitimate interests | 90 days. The IP address itself is never stored, and the result of the human check is not kept |
| Usage records: time, account, tool or page, chain, the number of inputs, the option names, result status, processing time, error code, request id, and a keyed hash of your network | Apply limits and budgets, keep the service secure, find abuse, fix faults, count use | Contract; legitimate interests | 90 days |
| What you look up: addresses, transaction hashes, cluster ids, search text | Answer the request | Contract | Not kept. Used only to compute the answer. A large MCP answer is stored for 24 hours so that your AI client can read it in parts; only your account can read it |
| Scope annotations: the personal labels, confidence, risk flags and notes you add, with the addresses they refer to, your account and the time of each change | Provide your annotations, investigate faults and abuse, and review and improve the service and our labels. Authorised operators may read them for these purposes | Legitimate interests | Until you ask us to delete them or close your account. We do not publish your annotations or show them to other users |
| API keys: a keyed hash of each key, its name, creation and expiry dates, last use | Authenticate your calls | Contract | Until 90 days after the key expires or is revoked. We cannot show a key again |
| Operator notifications: for a sign-up or an upgrade request, your e-mail address, user id, organisation, purpose and country; for an alert about unusual use, your user id, e-mail address and the counts that set it off | Let the operator decide on access and react to abuse | Legitimate interests | In the operator’s private Telegram chat; deleted on request |
| Server logs: account e-mail address, page path, errors (no looked-up addresses) | Run and secure the server | Legitimate interests | 90 days |
| Backups: a daily copy of the account, key, sign-up and decision records | Recover from a failure | Legitimate interests | 30 days |
We do not sell personal data, use it for advertising, or make profiles of you beyond the limits and alerts described here.
Data about other people: blockchain records and labels
Section titled “Data about other people: blockchain records and labels”hodlflow analyses public blockchain records (addresses, transactions, amounts and times) and labels some addresses: exchanges and other services, sanctioned entities, and wallets tied to confirmed hacks or scams. An address does not name its owner, but it can relate to a person.
- Sources: public blockchains, public sanctions lists, public reports and disclosures, and our own analysis.
- Why: fund-flow analysis for investigations, compliance and security research. We rely on legitimate interests and, in Korea, on the use of information its subject has made public. We label organisations and incident wallets, not private individuals by name.
- How long: blockchain records for as long as the service runs; a label for as long as we believe it is accurate.
- Your rights: if you think a label on an address you control is wrong, or you object to how it is processed, write to us. We review the label and correct or remove it, unless we must keep it (for example, a public sanctions designation).
Who else handles it
Section titled “Who else handles it”Three providers process data for us, and their systems are outside Korea. These transfers are needed to provide hodlflow; under Korea’s Personal Information Protection Act they are disclosed here as entrusted processing (Article 28-8(1)(3)). You can refuse them only by not using hodlflow, because the service cannot run without them.
| Recipient and contact | Where the data is | What | Why | When and how |
|---|---|---|---|---|
| netcup GmbH, Karlsruhe, Germany (mail@netcup.de) | Its data centre in Manassas, Virginia, United States | All the data in the first table | Hosting the server | Continuously, over encrypted connections, while you use hodlflow |
| Cloudflare, Inc., San Francisco, United States (privacyquestions@cloudflare.com) | Its global network | E-mail address at sign-in, IP address, browser data, requests in transit | Sign-in (Access), the human check (Turnstile), protection of the network | At each request, over encrypted connections |
| Telegram (telegram.org/privacy) | Its data centres in several countries | The operator notifications in the first table | Delivering them to the operator | When the event happens, over encrypted connections |
Each keeps the data only as long as that service needs it, under its own terms. When you sign in with Google, Google confirms your e-mail address to Cloudflare under Google’s own privacy policy; we send Google nothing.
From the EU, the EEA or the UK: the European Commission has found that Korea protects personal data adequately. Cloudflare transfers data under its data processing addendum with the EU standard contractual clauses; netcup is an EU company bound by the GDPR.
How we protect it
Section titled “How we protect it”- Every connection is encrypted, and only people signed in through Cloudflare Access reach the service.
- IP addresses are stored only as keyed hashes; API keys only as keyed hashes.
- The data files are readable only by the service accounts, and only the operator can reach the server, with an SSH key.
- Changes to who has access are checked and backed up; sign-ups and key changes are audited.
Deletion
Section titled “Deletion”Records are deleted automatically when their period ends: rotated log files are removed, and backups age out after 30 days. When you close your account, we delete your account record, API keys, sign-up records and annotations within 10 days; your usage records and backups follow within 90 and 30 days.
Your rights
Section titled “Your rights”You can ask to see, correct or delete your data, to stop or restrict its processing, to object to processing based on legitimate interests, to receive your data in a portable form, and to have a person review an automated sign-up decision. Write to privacy@hodlflow.app from your account’s address, or tell us the address and we will confirm by e-mail. We answer within 10 days.
If you think we handle your data wrongly, you can also complain:
- Korea: Privacy Infringement Report Center (privacy.kisa.or.kr, call 118); Personal Information Dispute Mediation Committee (kopico.go.kr, 1833-6972); Supreme Prosecutors’ Office (call 1301); Korean National Police Agency cyber bureau (ecrm.police.go.kr, call 182).
- EU, EEA or UK: the data protection authority where you live or work.
Cookies and browser storage
Section titled “Cookies and browser storage”- Cloudflare Access sets a sign-in cookie (
CF_Authorization). It is needed to use Scope, the key page and MCP sign-in. - Cloudflare Turnstile may use a cookie or browser storage to tell people from bots, under Cloudflare’s terms.
- Scope and the key page keep your settings in your browser’s storage; they stay on your device.
- We use no analytics or advertising cookies, and this site sets none.
You can block cookies in your browser, but sign-in does not work without the Access cookie.
Automated decisions
Section titled “Automated decisions”Sign-ups are admitted, waitlisted or held for review by fixed rules: the places left, and how many sign-ups came from one network. A held sign-up is decided by a person, and you can ask a person to review any sign-up decision.
Children
Section titled “Children”hodlflow is a professional tool and is not for anyone under 16.
Changes
Section titled “Changes”When this notice changes, the version date above changes, and material changes are announced in the changelog.
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