This Privacy Notice explains how Dlicom Labs Ltd (“Dlicom”, “we”, “us”, or “our”) processes information in connection with participation in the Dlicom Pre-Token Generation Event (Pre-TGE) Airdrop (the “Airdrop”).
Dlicom is a company incorporated in the British Virgin Islands and operates a decentralized, wallet-based ecosystem. The Airdrop is part of this ecosystem and is designed as a participation-driven campaign involving on-chain actions, community engagement, and referral-based activity.
Unlike traditional web platforms, participation in Airdrop does not require users to create an account using personal identifiers such as name or email. Instead, participation is primarily based on blockchain wallet interaction and activity across integrated platforms.
This means that the type of information processed in connection with Airdrop differs from conventional personal data collection models. However, certain forms of data — including wallet addresses, activity signals, and verification status — may still be processed in order to operate, secure, and maintain the integrity of the campaign.
This Notice is intended to provide a clear explanation of:
This document does not attempt to reframe blockchain systems as traditional data environments. Where data is inherently public (such as on-chain activity), this Notice clarifies Dlicom's role in interacting with that data rather than asserting control over it.
This Privacy Notice applies specifically to the Airdrop and any systems, interfaces, or processes directly related to participation in that campaign.
This includes, without limitation:
This Notice should be read together with the general Dlicom Privacy Policy, which applies to the broader Dlicom platform and its services.
Where the Airdrop involves additional or different data processing practices, this Notice takes precedence in relation to those specific activities.
It is important to note that participation in the Airdrop may involve interaction with systems that are not controlled by Dlicom, including blockchain networks and third-party platforms such as X (Twitter), Telegram, and Discord. This Notice applies only to the extent that Dlicom processes or interacts with data in connection with those activities.
Data that is collected or processed directly by third-party platforms is subject to their respective privacy policies and terms, and Dlicom does not assume responsibility for how such platforms handle user data.
Finally, this Notice reflects the operational reality of a decentralized, wallet-based campaign. It does not create or imply any obligation for Dlicom to collect, store, or manage personal identity information where such data is not required for the functioning of the Airdrop.
Participation in the Airdrop is designed to operate on a pseudonymous basis.
Dlicom does not require users to provide personal identity information, such as name, email address, or government-issued identification, in order to participate. Users interact with the Airdrop primarily through blockchain wallet addresses and activity-based signals.
As a result, Dlicom does not seek to identify users as real-world individuals and does not maintain personal identity profiles linked to Airdrop participation.
Users should be aware that while participation may be pseudonymous, it is not anonymous. Blockchain transactions and certain interactions with public platforms may be visible and traceable by third parties outside of Dlicom's control.
Participation in the Airdrop is centered around the use of a blockchain wallet.
When a user connects a wallet to the Airdrop, that wallet address becomes the primary reference point for participation. This address may be used to associate activity within the campaign, including task completion, eligibility signals, and participation status.
Blockchain networks are public by design. As a result:
are publicly accessible and may be visible to anyone, independently of Dlicom.
Dlicom does not control the blockchain and does not have the ability to alter, delete, or restrict access to on-chain data. Any interaction with the blockchain, including signing messages or executing transactions, is permanent and cannot be reversed.
Where relevant to the operation of the Airdrop, Dlicom may reference or process publicly available blockchain data in order to:
Dlicom does not infer real-world identity from wallet addresses and does not require users to link personal identity information to their wallet in order to participate.
Users are solely responsible for the security and control of their wallet. Loss of access, unauthorized use, or exposure of wallet credentials is outside Dlicom's control.
Participation in the Airdrop may require interaction with third-party platforms, including but not limited to X (Twitter), Telegram, and Discord.
These platforms are used as part of the campaign's participation and verification mechanisms. In this context, Dlicom may process limited information necessary to confirm that required actions have been completed.
This may include:
Dlicom does not request or collect login credentials, passwords, private messages, or any non-public account data from these platforms.
Any interaction with third-party platforms is subject to their own terms of service and privacy policies. Dlicom does not control how these platforms collect, process, or store user data.
Where third-party verification tools or bots are used (for example, in Telegram or Discord), those tools may operate under their own technical and data handling processes. Dlicom's role is limited to using the output of such systems (e.g., whether a condition has been met) for the purpose of campaign validation.
Users remain responsible for managing their own accounts on third-party platforms and for understanding how their data is handled by those services.
Information in connection with the Airdrop is collected through a combination of direct user interaction, automated processes, and verification mechanisms.
Some data is provided directly by users through their participation. This includes actions such as connecting a wallet, signing messages, completing campaign steps, or interacting with Airdrop interfaces. These actions generate participation signals that are used to operate the campaign.
In addition, certain data is collected automatically as part of the system's operation. This includes activity records, participation status, referral relationships, and other metrics generated through the use of the platform. These processes are necessary to track engagement, maintain campaign logic, and ensure consistent evaluation across participants.
Where the Airdrop relies on third-party platforms, data may also be obtained through verification processes. This typically involves confirming whether a required action has been completed, such as joining a channel or meeting a specific condition on an external platform. In such cases, Dlicom does not access full account data, but rather relies on confirmation signals or limited identifiers.
Finally, certain information may be derived or inferred from existing data. For example, the system may determine participation status, eligibility, or ranking based on a combination of on-chain activity, completed actions, and ongoing engagement.
Data collection in this context is therefore not based on traditional form-based input, but on interaction with systems, protocols, and campaign mechanics.
Information is processed strictly for the purpose of operating, maintaining, and securing the Airdrop.
This includes verifying that users have completed required actions, confirming eligibility conditions, and ensuring that participation reflects genuine activity rather than automated or manipulative behavior. Without this processing, it would not be possible to run the campaign in a consistent or reliable way.
Data is also used to support the internal logic of the Airdrop, including the calculation of participation metrics such as points, rankings, and tier classifications. These systems depend on ongoing evaluation of user activity and may require periodic updates or recalculations.
In addition, information is processed to detect and prevent abuse. This includes identifying patterns associated with multiple accounts, artificial engagement, or attempts to exploit the system. Such processing is necessary to protect the integrity of the campaign and to ensure fair participation.
Where applicable, data may also be used to improve the performance and functionality of the Airdrop, including refining verification methods, adjusting campaign mechanics, and maintaining system stability.
Dlicom does not use Airdrop-related data for unrelated purposes, and does not sell personal data. Processing is limited to what is necessary to operate the campaign and enforce its rules.
Participation in the Airdrop involves the use of internal systems that evaluate user activity and generate participation-related outcomes.
These systems may analyze information such as:
Based on this analysis, the system may assign or update values such as points, rankings, tiers, or other participation indicators.
This process may involve automated or semi-automated evaluation. However, these outputs are used strictly within the context of the Airdrop and do not produce legal, financial, or similarly significant effects outside the campaign environment.
The purpose of this processing is to:
Dlicom does not use these systems to identify real-world individuals or to make decisions unrelated to the Airdrop.
The criteria and methods used in these systems may evolve over time. While the general structure of the campaign is described publicly, detailed internal logic is not disclosed in order to protect the integrity of the system and prevent abuse.
Dlicom does not sell user data and does not disclose Airdrop-related information for commercial purposes.
Information processed in connection with the Airdrop may be shared only where necessary to operate the campaign or to comply with legal obligations.
This may include:
In addition, certain information associated with participation may be inherently public due to the nature of blockchain systems or user activity on public platforms. Dlicom does not control the visibility of such data once it is recorded on-chain or published externally.
Apart from these limited circumstances, Dlicom does not share Airdrop-related data with third parties.
Information related to the Airdrop is retained only for as long as it is necessary to operate, evaluate, and maintain the campaign, including any post-campaign review, verification, or distribution processes.
Because the Airdrop is dynamic and may involve ongoing validation, certain data — such as participation history, referral relationships, and activity records — may be retained for a period of time after the campaign ends to support reconciliation, audit, or integrity checks.
Where technically feasible, Dlicom may limit or remove internally stored data that is no longer required. However, this does not apply to data recorded on public blockchain networks or to information that has been shared or published on third-party platforms, which remains outside Dlicom's control.
Retention periods may vary depending on the nature of the data and operational requirements. Dlicom reserves the right to retain information where necessary to comply with legal obligations, resolve disputes, or enforce these Terms.
Dlicom implements reasonable technical and organizational measures designed to protect information processed in connection with the Airdrop from unauthorized access, misuse, or alteration.
These measures are aligned with the nature of the system, which relies on decentralized infrastructure, third-party platforms, and public blockchain networks. As such, certain aspects of data exposure — particularly on-chain activity — are inherent to the technology and cannot be fully restricted or controlled.
While Dlicom takes appropriate steps to maintain system integrity, no method of transmission or storage is completely secure. Users acknowledge that participation in the Airdrop involves interacting with systems that may be subject to technical risks, including vulnerabilities, outages, or external interference.
Users are responsible for maintaining the security of their own wallets, devices, and third-party accounts. Dlicom does not have access to private keys or account credentials and cannot recover lost or compromised access.
Users are responsible for ensuring that their participation in the Airdrop is carried out in a secure, lawful, and accurate manner.
This includes maintaining control over their blockchain wallet, safeguarding private keys, and ensuring that any connected third-party accounts (such as X, Telegram, or Discord) are properly managed and not compromised. Dlicom does not have access to private credentials and cannot recover lost access or reverse unauthorized activity.
Users are also responsible for the accuracy of any information or actions associated with their participation. This includes ensuring that wallet connections, referrals, and third-party account linkages are valid and not misleading.
Where participation requires interaction with external platforms, users must comply with the terms and privacy policies of those platforms. Dlicom is not responsible for how third-party services handle user data or enforce their own rules.
Users must not attempt to obscure, falsify, or manipulate participation data. Any such activity may affect eligibility, rankings, or outcomes within the Airdrop.
Participation in a decentralized environment requires a basic understanding of how blockchain systems operate. Users are expected to take appropriate steps to understand the implications of interacting with public networks, including the visibility and permanence of on-chain activity.
Depending on the applicable laws in their jurisdiction, users may have certain rights in relation to data processed by Dlicom in connection with the Airdrop.
These may include the right to request access to information held by Dlicom, or to request correction of inaccurate data where such correction is technically feasible.
However, the nature of the Airdrop imposes certain limitations.
Information recorded on public blockchain networks cannot be modified or deleted by Dlicom. Similarly, data processed or stored by third-party platforms is subject to those platforms' own systems and policies.
In addition, certain data may be required for the operation and integrity of the Airdrop, including verification records, participation history, and anti-abuse mechanisms. As a result, requests to delete or restrict such data may not always be possible where it would undermine the functioning or fairness of the campaign.
Where requests are made, Dlicom will assess them in good faith, taking into account technical feasibility, legal obligations, and the need to maintain the integrity of the Airdrop.
Requests relating to third-party platforms must be directed to those platforms directly.
The Airdrop operates on a global basis and is accessible to users in multiple jurisdictions. As a result, information processed in connection with participation may be transferred across borders and handled in locations outside the user's country of residence.
Dlicom is incorporated in the British Virgin Islands and may rely on infrastructure, service providers, or systems located in other jurisdictions. This means that data associated with participation may be processed in environments where data protection laws differ from those in the user's home country.
In addition, participation in the Airdrop inherently involves interaction with decentralized blockchain networks and global platforms, which are not confined to a single geographic location. Information recorded on such systems may be distributed across multiple nodes or servers worldwide.
By participating in the Airdrop, users acknowledge and accept that their information may be processed, stored, or made available across multiple jurisdictions as part of the normal operation of the campaign.
This Privacy Notice may be updated or revised from time to time to reflect changes in the Airdrop, its underlying systems, or applicable legal and regulatory requirements.
Where changes are made, the updated version will be made available through the relevant Airdrop interface or associated platforms. The “last updated” date may be revised to indicate the effective version.
Users are encouraged to review this Notice periodically to remain informed about how information is processed in connection with the Airdrop.
Continued participation in the Airdrop following any update constitutes acceptance of the revised Notice.
Dlicom Labs Ltd is responsible for the processing of information described in this Privacy Notice.
If you have questions, requests, or concerns regarding this Notice or the way information is handled in connection with the Airdrop, you may contact Dlicom through the official communication channels made available on the Dlicom platform or website.
Due to the pseudonymous nature of the Airdrop, requests should include sufficient information to allow identification of the relevant participation record, such as a wallet address or associated identifier.
Dlicom will review requests in good faith and respond where appropriate, taking into account the technical and operational limitations described in this Notice.