Uniswap Labs can use and share data that has been aggregated or stripped of direct identifiers for any purpose it chooses, with no restrictions under the privacy policy.
This analysis describes what Uniswap's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
The scope of this permission depends entirely on whether de-identification actually meets legal standards, since improperly de-identified data can still be linked back to individuals, particularly in the crypto context where wallet addresses are pseudonymous rather than anonymous.
Interpretive note: Whether data qualifies as properly de-identified under CPRA or GDPR anonymization standards is a factual and technical question not resolvable from the policy text alone.
Data derived from your transactions and usage may be shared or used commercially without restriction once Uniswap Labs determines it is de-identified or aggregated, but the adequacy of that de-identification process is not described in the policy.
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"We may use and share aggregated or de-identified information, which cannot reasonably be used to identify you, for any purpose without restriction under this Privacy Policy.— Excerpt from Uniswap's Uniswap Privacy Policy
(1) REGULATORY LANDSCAPE: Under CPRA, de-identified data must meet specific technical and administrative standards, including a commitment not to re-identify the data and implementation of technical safeguards. GDPR's standard for anonymization is high, and the EDPB has indicated that true anonymization is difficult to achieve, particularly for pseudonymous data sets like wallet transaction histories. The FTC has also addressed de-identification standards in its guidance on data brokers. (2) GOVERNANCE EXPOSURE: Medium. The 'without restriction' language is broad and the policy does not describe the de-identification methodology used. In a crypto context where wallet addresses are already pseudonymous, achieving genuine anonymization may be technically difficult, and regulatory scrutiny of overstated de-identification claims is increasing. (3) JURISDICTION FLAGS: California's CPRA creates heightened exposure because it requires documented de-identification processes and prohibits re-identification attempts. EU/EEA users are protected by GDPR's strict anonymization standard, under which much of what companies call de-identified may still qualify as personal data. (4) CONTRACT AND VENDOR IMPLICATIONS: Downstream recipients of de-identified data from Uniswap Labs should assess whether the data meets applicable de-identification standards before using it for secondary purposes. Contracts with analytics vendors receiving this data should include re-identification prohibitions. (5) COMPLIANCE CONSIDERATIONS: A de-identification methodology should be documented and reviewed against CPRA and GDPR standards. Technical controls preventing re-identification should be assessed and documented. The policy's 'any purpose without restriction' formulation should be evaluated against CPRA requirements that de-identified data not be used to re-identify individuals.
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The scope of this permission depends entirely on whether de-identification actually meets legal standards, since improperly de-identified data can still be linked back to individuals, particularly in the crypto context where wallet addresses are pseudonymous rather than anonymous.
Data derived from your transactions and usage may be shared or used commercially without restriction once Uniswap Labs determines it is de-identified or aggregated, but the adequacy of that de-identification process is not described in the policy.
ConductAtlas has identified this type of provision across 2 platforms. See the full comparison.
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