Version 2.0 · Last updated: October 1, 2026

This Privacy Policy explains how We collect, use, share and protect Your Personal Data when You use CED (Capacity Exchange DAO), and the rights You have over that data. Please read it together with the CED Terms of Use and the CED User Guide.

If You do not agree with this Privacy Policy, please do not use the Service. Where We rely on Your consent for a specific use of Your data, We will ask for it separately, and You can withdraw it at any time.

 

1. Who we are

The CED platform is developed by Kambria and co-run with the Capacity Exchange DAO, the community of members who help operate it. As the platform developer, Kambria International, a company incorporated in the Cayman Islands ("the Company", "We", "Us" or "Our"), is the data controller for Your Personal Data processed through CED, meaning it sets the purposes for which that data is used and how it is handled.

You can contact Us about privacy at any time at [email protected].

 

2. Definitions

Account means a unique account created for You to access the Service.

Affiliate means an entity that controls, is controlled by, or is under common control with the Company, where "control" means ownership of 50% or more of the voting shares or other voting interests.

Connection Session (or Session) means a scheduled one-to-one call between a Guide and an Explorer through the Service.

Device means any device that can access the Service, such as a computer, mobile phone or tablet.

Explorer means a user who books a Session to learn from a Guide. Guide means a user who shares knowledge or experience in a Session. The same person may act as a Guide in one Session and an Explorer in another.

Gift Code means a code issued by or through CED that grants access to Sessions or subscriptions.

Partner means an organisation that works with CED, including Community Partners, which introduce CED to their members, and Theme Partners, which sponsor Sessions or contribute Guides.

Personal Data means any information relating to an identified or identifiable individual.

Service means the CED application and website.

Service Provider means a company or individual that processes Personal Data on Our behalf and under Our instructions.

Session Recording means the recording and live transcript of a Connection Session described in Section 4.

Usage Data means data collected automatically when the Service is used, such as device and diagnostic data.

You means the individual using the Service, or the organisation on whose behalf that individual uses it.

 

3. Personal Data we collect

3.1 Data You provide

•       Account data: name, email address, phone number, password (stored in encrypted form).
•       Profile data: profile photo, introduction, expertise, Guide level, topics, languages and other information You choose to add. Parts of Your profile are visible to other users (see Section 7).
•       Verification data: if You apply to become a verified Guide, the image of the identity document You submit so that We can verify You.
•       Reports and communications: reports You submit about other users or topics, and messages You send to Us.

 

3.2 Data created when You use CED

•       Session data: bookings, Session topic and time, join and leave times, participation duration, completion status, and Explorer confirmations.
•       Evaluations: ratings and feedback given after a Session.
•       Gift Code and subscription data: codes redeemed, subscriptions purchased and their use.
•       Referral data: the Partner or referral link through which You registered, if any.
•       Session Recordings: see Section 4.

 

3.3 Payment and wallet data

Payments and Guide remuneration on CED are made in cryptocurrency. We collect Your wallet address and transaction details (such as amounts and transaction hashes). We never ask for or store Your private keys or recovery phrases — never share them with anyone, including people claiming to represent CED.

 

3.4 Device and Usage Data

When You use the Service, We collect Usage Data such as device type and identifier, operating system, browser type and version, pages and features used, time and date of use, and diagnostic data.

With Your permission, the app accesses Your camera, photo library, microphone and speakers so that You can set a profile photo and take part in Sessions. You can change these permissions in Your Device settings at any time, but You cannot take part in a Session without microphone access.

 

4. Session Recordings

What We record. Sessions are held through Zoom. CED records the audio and video of every Connection Session, and Sessions are transcribed in real time using Zoom's live transcription service. You are informed that Sessions are recorded in this Privacy Policy, in the CED User Guide and in the onboarding email You receive after registering.

Why We record. We use Session Recordings and transcripts only to:

•       verify that a Session took place as registered, since completed Sessions are the basis for Guide remuneration;
•       handle reports, complaints and disputes between users;
•       detect, investigate and prevent fraud, misuse of Gift Codes or payments, and other violations of Our Terms and policies — whether these are reported by a user or identified through Our own checks, including checks on a sample of Sessions; and
•       protect the safety of users. The AI Assistant, developed by Kambria using OpenAI models, analyses the live transcript to detect inappropriate language and issue warnings during the Session.

Who can access them. Session Recordings are stored with Zoom. They are opened by people only when needed for the purposes above, and only by authorised Kambria staff bound by confidentiality.

How long We keep them. Session Recordings and transcripts are kept for 90 days from the date of the Session and then deleted. A recording is kept longer only while it is needed as evidence in an open report, investigation, dispute or legal claim, or where the law requires it, and is deleted when that need ends.

What We do not do. We do not use Session Recordings or transcripts for advertising, and We do not use Session content to train AI models.

 

5. How we use Personal Data and our legal basis

We only use Personal Data where We have a legal basis to do so. The main uses and bases are:

Purpose	Legal basis
Create and manage Your Account; provide Sessions, subscriptions and Gift Codes	Performance of our agreement with You
Verify the identity and expertise of Guides	Performance of our agreement with You; our legitimate interest in a trusted Service
Schedule Sessions, record attendance and completion, and calculate and pay Guide remuneration	Performance of our agreement with You
Verify Sessions and detect, investigate and prevent fraud, Gift Code or payment misuse, and violations of our Terms (including Session Recordings)	Our legitimate interest in keeping the Service honest and payments accurate; compliance with legal obligations
Handle reports and protect user safety, including the AI Assistant's language warnings	Our legitimate interest in a safe Service; Your vital interests where safety is at risk
Attribute registrations to Partners and report aggregated results to them	Our legitimate interest in running and measuring Partner programmes
Send service messages (booking confirmations, security and policy updates)	Performance of our agreement with You
Send news and offers about CED and the Kambria ecosystem	Your consent, or our legitimate interest for existing users, with an unsubscribe option in every message
Analyse use of the Service to improve it, using aggregated data where possible	Our legitimate interest in improving the Service
Keep accounting and tax records; respond to lawful requests from authorities	Legal obligation

 Where We rely on legitimate interests, We balance them against Your rights, and You can object as described in Section 11.

 

6. Automated processing

Some outcomes on CED are decided automatically:

•       Session completion is recorded automatically based on participation time and lateness rules set out in the CED User Guide. Where the minimum duration is not met, the Explorer is asked to confirm completion; if the Explorer does not respond within 3 days, the Session is recorded as completed. Completion status determines Guide remuneration.
•       Language warnings are issued automatically by the AI Assistant during a Session.

If You disagree with an automated outcome, contact Us at [email protected] and a person will review it.

 

7. How we share Personal Data

We do not sell Your Personal Data. We share it only as follows:

•       With other users: Your public profile (name, photo, introduction, expertise, level, topics and ratings) is visible to other users. The participants in a Session see each other's profile.
•       With Service Providers who help Us run the Service, under terms that require them to protect the data and use it only to provide their services to Us: Amazon Web Services (hosting and storage of app data, including verification documents), Zoom (video and audio calls, cloud recording and live transcription), OpenAI (AI models used by the AI Assistant), and providers of email and analytics services.
•       On public blockchains: Your wallet address and transaction details for payments are recorded on a public blockchain. This information is visible to anyone and cannot be changed or deleted by Us or anyone else.
•       Within Kambria: with Kambria Vietnam Co., Ltd., which supports the operation of CED, and which must handle Your data in line with this Privacy Policy.
•       With Partners: Community Partners and Theme Partners receive only aggregated or de-identified information about the participants and Sessions linked to them — for example, the number of registrations, Sessions completed and average feedback scores. We share an individual's story or feedback with a Partner only with that person's consent. We never share Your contact details, verification data or Session Recordings with Partners.
•       For legal reasons: where required by law or a valid request from a court or authority, or where needed to establish, exercise or defend legal claims, investigate wrongdoing, or protect the rights, property or safety of users, the public or the Company.
•       In a business transfer: if the Company is involved in a merger, acquisition or sale of assets. We will notify You before Your data becomes subject to a different privacy policy.
•       With Your consent for any other purpose.

 

8. International transfers

The Company, Kambria Vietnam Co., Ltd. and Our Service Providers process Personal Data in several countries, which may be different from the country where You live. In particular, Session Recordings are stored in Singapore; app data, including verification documents, is stored in the United States; and live transcription and AI Assistant processing take place in the United States. When We transfer Personal Data across borders, We comply with the applicable transfer requirements, rely on the data protection commitments of the recipient, and only transfer to recipients that apply adequate security measures.

 

9. How long we keep Personal Data

We keep Personal Data only as long as needed for the purposes in this Privacy Policy:

Data	Retention
Account and profile data	While Your Account is active, then deleted or anonymised within 30 days of closure, unless needed for a purpose below
Identity verification documents	While Your Account is active; deleted together with Your Account data
Session Recordings and transcripts	90 days from the Session; longer only while needed as evidence in an open report, investigation, dispute or legal claim
Session, evaluation, Gift Code and referral records	3 years, to support remuneration, complaints, Partner reporting and audits
Payment and remuneration records	7 years, for accounting and tax purposes. On-chain transactions are permanent and cannot be deleted
Reports, investigation files and enforcement records	3 years after the matter is closed. Details needed to enforce an account ban are kept while the ban applies
Usage and diagnostic data	12 months, unless needed for security
Marketing preferences	Until You unsubscribe or withdraw consent

 

10. Security

We protect Personal Data with technical and organisational measures appropriate to the risk, including encryption of data in transit, restricting access to Session Recordings and verification data to authorised Kambria staff who need it, and confidentiality obligations for those staff and Our Service Providers. No method of transmission or storage is completely secure, but We work to protect Your data and will notify You and the relevant authorities of a data breach where the law requires it.

 

11. Your rights

Subject to applicable law, You have the right to:

• access the Personal Data We hold about You;
• correct inaccurate or incomplete data;
• delete Your data;
• object to certain uses of Your data, such as marketing; and
• withdraw Your consent where We rely on it, for example by unsubscribing from marketing emails.

You can update much of Your data in Your Account settings. For other requests, email [email protected]. Once We have verified Your identity, We will respond within 30 days, either confirming the action taken or explaining why We cannot fully act on the request. If You are not satisfied with Our response, You may also complain to the data protection authority in the country where You live.

 

12. Account suspension and termination

If an Account is suspended or terminated for a violation of Our Terms or policies, We keep the data needed to investigate the violation, enforce Our decision (including preventing the same person from registering again), resolve disputes and meet legal obligations, for the periods set out in Section 9. Other data is deleted or anonymised as described in that section.

 

13. Children

The Service is not intended for anyone under 18, and We do not knowingly collect Personal Data from children. If You believe a child has given Us Personal Data, please contact Us and We will delete it.

 

14. Links to other websites

The Service may link to websites and services We do not operate, including wallets and blockchain explorers. Their privacy practices are their own, so please review their privacy policies.

 

15. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The latest version is always available at https://kambria.io/docs/ced/ced-privacy-notice/. For material changes, We will also notify You by email or in the app before they take effect. 

 

16. Contact us

For questions about this Privacy Policy or to exercise Your rights, email [email protected].

You can also write to Us at: 

Kambria International, 

Floor 4, Willow House, Cricket Square, Grand Cayman

Cayman Islands.