Privacy Policy
1. Data Controller
The data controller responsible for your personal data is:
Cathedral s.r.l.s
Via Casino Fondrini 6
25080 Padenghe Sul Garda (BS)
Italy
VAT Number (P.IVA): IT03939260984
Email: privacy@cathedral.technology
2. Personal Data We Collect
We collect and process the following categories of personal data:
2.1 Account Data
- Email address - Required for account creation and communication
- Space name - The name of the space you create at signup; also used as your initial display name in the platform UI
- Password - Stored in hashed form for account security (or omitted entirely if you sign in with Google, in which case authentication is handled by your Google account)
2.2 Profile Data
- Biography - Optional description you provide
- Avatar image - Optional profile picture
- Organization affiliations - Your membership in organizations
2.3 Idea Challenge Participation Data
- Date of birth - For age verification (16+ requirement)
- Location - City and country for challenge eligibility
- Idea submissions - Content you submit to challenges
- Votes - Your voting activity on ideas
2.4 Proposal Voting Data
- Email address (opt-in sharing with the Organization) - When you cast a vote, you may tick a separate, per-vote checkbox (default OFF) authorising Cathedral to transmit your email address, together with your choice and the timestamp of the vote, to the Organization that owns the proposal. The legal basis is Art. 6(1)(a) GDPR (explicit consent); proof of consent is retained by Cathedral under Art. 7 GDPR in a dedicated audit record. If you do not tick the box, the Organization receives only aggregate, non-identifying tallies. You may withdraw this consent at any time, with immediate effect, through your account profile (Privacy tab) or by writing to privacy@cathedral.technology. Withdrawal stops further use by Cathedral but does not, by itself, oblige the Organization to erase data it has already lawfully received and processed under its own responsibility (see §6.3).
- Vote choices - Your votes on proposals
- Voting power - Calculated based on token holdings
2.5 On-Chain Audit Log Data
For the purpose of independently verifiable governance integrity, Cathedral records cryptographic commitments related to voting activity on a public distributed ledger. The on-chain audit log contains only the following technical artefacts, none of which constitute personal data within the meaning of GDPR Article 4(1):
- Merkle root commitments — a single 32-byte cryptographic root summarising a batch of vote hashes per proposal. Individual votes are not written to the blockchain as separate transactions.
- Proposal results hashes — SHA-256 hashes of aggregated, anonymised tally outcomes.
- Transaction metadata — block number, transaction hash, timestamp.
The on-chain audit log is currently recorded on Base Mainnet (Chain ID: 8453) at smart contract address 0xeC0a2d350e133BA9A144340844A803FDdFfe4a77 (VoteAuditLog).
The audit log is a write-only, append-only transparency mechanism. It does not constitute the issuance of any crypto-asset within the meaning of Regulation (EU) 2023/1114 (MiCA) and does not create any token, balance, claim, or right of any kind in favour of any Member. Because no personal data is recorded on chain, the immutability of the underlying ledger does not affect your right to erasure under GDPR Article 17 in respect of personal data held in our databases.
2.6 No Wallet Required for Ordinary Use
Members do not need to hold, connect, or disclose any blockchain wallet address in order to register an account, vote, submit ideas, claim rewards, or otherwise participate in the Platform. Vora does not collect wallet addresses from Members for ordinary participation, does not require Members to sign blockchain transactions, and does not custody any crypto-asset on behalf of Members.
2.7 E-Commerce Integration Data
When a Shopify merchant installs and configures the Vora app on their store, we may receive the following data about the merchant's customers:
- Email address - Used to create a loyalty profile and enable account claiming
- Shopify customer identifier - A pseudonymized ID to link purchases to loyalty profiles
- Order amounts - Purchase totals used to calculate XP rewards
This data is received from the Shopify merchant's store on the merchant's behalf. Until you voluntarily claim a Vora account, we act as a data processor for the merchant.
2.8 Technical Data
- IP address - For security and fraud prevention
- User agent - Browser and device information
- Access logs - Timestamps of your interactions
- Browser timezone and language - Used client-side only to localise the interface (e.g. Italian for Italy). This data is processed entirely in your browser and is never transmitted to our servers.
2.9 Payment Data
The Platform is currently provided free of charge. Cathedral does not collect, process, or store any payment data, credit-card details, IBAN, or other financial identifiers from Customers or Members through the Platform. Should Cathedral introduce paid tiers in the future (see Terms of Service §5), this Section 2.9 will be updated to identify the payment processor in advance, and no payment data will be collected unless you expressly subscribe to a paid tier.
3. Legal Basis for Processing
We process your personal data based on the following legal grounds under GDPR Article 6:
| Purpose | Legal Basis |
|---|---|
| Account creation and management | Contract performance (Art. 6(1)(b)) |
| Processing votes and idea submissions | Contract performance (Art. 6(1)(b)) |
| Security and fraud prevention | Legitimate interest (Art. 6(1)(f)) |
| Marketing communications | Consent (Art. 6(1)(a)) |
| Analytics and service improvement | Legitimate interest (Art. 6(1)(f)) |
| Blockchain vote verification | Contract performance (Art. 6(1)(b)) and Legitimate interest (Art. 6(1)(f)) |
| Legal compliance | Legal obligation (Art. 6(1)(c)) |
| E-commerce loyalty profiles (Shopify) | Legitimate interest of the merchant (Art. 6(1)(f)); Consent upon account claiming (Art. 6(1)(a)) |
| Post-vote email notifications (results, outcome summaries) | Contract performance (Art. 6(1)(b)) — delivery of governance results as part of the voting service accepted via Terms of Service |
| Voter reward notifications (reward claims, redemption codes, QR verification links) | Contract performance (Art. 6(1)(b)) — delivery of earned rewards as part of the voting service accepted via Terms of Service |
| Sharing voter email with the proposal's Organization | Explicit consent (Art. 6(1)(a)) — per-vote opt-in checkbox at the time of casting the vote, default OFF; proof of consent retained under Art. 7 |
| AI-based content moderation of notification messages | Legitimate interest (Art. 6(1)(f)) — protecting platform integrity, transactional-email sender reputation, and preventing spam or harmful content |
4. Purposes of Processing
We use your personal data for the following purposes:
- Service provision - To provide the Vora governance platform
- Account management - To create and manage your user account
- Voting verification - To verify your identity and eligibility to vote
- Challenge participation - To process your idea submissions and votes
- Communication - To send service-related email notifications, including post-proposal-close voter notifications containing results and outcome summaries authored by the Organization
- Security - To protect against fraud and unauthorized access
- Analytics - To understand and improve our services
- Compliance - To meet legal and regulatory requirements
5. Data Retention
We retain your personal data for as long as necessary for the purposes outlined in this policy:
| Data Category | Retention Period |
|---|---|
| Account data | Duration of account + 30 days after deletion request |
| Voting records (database) | Permanently (anonymized after account deletion) |
| Blockchain verification hashes | Permanent and immutable (no personal data stored on-chain) |
| Idea submissions | Duration of challenge + 2 years |
| Security logs | 2 years |
| Audit logs | 1 year |
| Marketing consent records | Duration of consent + 3 years |
| E-commerce loyalty profiles (unclaimed) | 12 months after last purchase activity |
| E-commerce loyalty profiles (claimed) | Duration of Vora account + 30 days |
| Voter email shared with an Organization (per-vote opt-in) | Until you withdraw consent or delete your Vora account; the Organization may continue to retain copies it has lawfully received under its own retention policy as joint controller |
| Per-vote consent records (Art. 7 proof of consent) | 10 years from the date of the vote, in line with Italian limitation periods for civil and administrative claims |
7. International Transfers
Some of our service providers are located outside the European Economic Area (EEA). When we transfer your data internationally, we ensure appropriate safeguards are in place:
| Provider | Location | Safeguard |
|---|---|---|
| AWS | EU (Ireland) | No transfer required |
| Resend | USA | Standard Contractual Clauses (SCCs) |
| Alchemy | USA | Standard Contractual Clauses (SCCs) |
| Shopify Inc. | Canada / USA | Standard Contractual Clauses (SCCs) |
| OpenAI | USA | Standard Contractual Clauses (SCCs); no personal data transferred (notification text content only) |
| Base / Ethereum Public Distributed Ledger | Decentralized (global) | No personal data transferred (pseudonymous hashes only) |
8. Your Rights
Under GDPR, you have the following rights regarding your personal data:
Right of Access (Art. 15)
You can request a copy of all personal data we hold about you.
Right to Rectification (Art. 16)
You can request correction of inaccurate personal data.
Right to Erasure (Art. 17)
You can request deletion of your personal data, subject to legal retention requirements. Note: cryptographic hashes stored on blockchain are permanent but contain no personal data and cannot be linked back to you after erasure.
Right to Restriction (Art. 18)
You can request restriction of processing in certain circumstances.
Right to Data Portability (Art. 20)
You can receive your data in a structured, machine-readable format.
Right to Object (Art. 21)
You can object to processing based on legitimate interests or direct marketing.
To exercise any of these rights, please visit your account settings or contact us at privacy@cathedral.technology.
8.1 Right to Lodge a Complaint
You have the right to lodge a complaint with the Italian Data Protection Authority:
Garante per la Protezione dei Dati Personali
Website: www.garanteprivacy.it
9. Security Measures
We implement appropriate technical and organizational measures to protect your personal data:
- Encryption - Data is encrypted in transit (TLS) and at rest
- Password hashing - Passwords are stored using secure hashing algorithms
- Access controls - Role-based access with two-factor authentication
- Audit logging - All access is logged for security monitoring
- Regular security assessments - We conduct periodic security reviews
11. Children's Privacy
Our services are not intended for individuals under 16 years of age. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete that information.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on this page
- Updating the "Last updated" date
- Sending an email notification for significant changes
13. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us:
Privacy Inquiries
Email: privacy@cathedral.technology
Address: Cathedral s.r.l.s, Via Casino Fondrini 6, 25080 Padenghe Sul Garda (BS), Italy