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The policy states that Uniswap Labs does not collect or store personal identifiers including names, IP addresses, street addresses, or dates of birth in connection with use of the Services.
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
This provision establishes the foundational data minimization claim of the policy, limiting the categories of personal data Uniswap Labs asserts it retains. Compliance teams should note that the policy separately discloses collection of wallet addresses, device data, and correspondence, and should assess whether any of these categories constitute personal data under applicable law including GDPR.
Interpretive note: Whether blockchain wallet addresses and device identifiers qualify as personal data under GDPR or CCPA is jurisdiction-dependent and subject to regulatory interpretation.
The agreement states that users are not required to provide personal data to use the Services, and that Uniswap Labs does not store personal identifiers such as names or IP addresses, though device information, browser data, and wallet addresses are collected as described elsewhere in the policy.
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"We do not maintain user accounts and do not collect and store personal data, such as your name or internet protocol ("IP") address. Uniswap Labs does not collect and store personal data, such as first name, last name, street address, date of birth, email address, or IP address, in connection with your use of the Services.Excerpt from Uniswap's Privacy Policy
1) REGULATORY LANDSCAPE: This provision engages GDPR definitions of personal data (which may include pseudonymous identifiers such as wallet addresses when linkable to individuals), CCPA definitions of personal information, and FTC expectations around accurate data practice representations. Supervisory authorities in several EU jurisdictions have considered blockchain wallet addresses to be personal data under GDPR, which may create tension with the policy's framing of wallet addresses as non-personally identifying. 2) GOVERNANCE EXPOSURE: Medium. The policy's assertion that blockchain addresses are not personally identifying by themselves may require evaluation against GDPR's broad definition of personal data, which includes any information relating to an identified or identifiable natural person. The adequacy of the no-personal-data claim depends on jurisdictional interpretation. 3) JURISDICTION FLAGS: EU/EEA users face the greatest exposure given GDPR's broad personal data definition. Supervisory authorities in Germany, France, and other member states have indicated that pseudonymous data including blockchain addresses may qualify as personal data where re-identification is possible. 4) CONTRACT AND VENDOR IMPLICATIONS: Organizations integrating Uniswap Labs services should assess whether the no-personal-data claim is consistent with their own data mapping obligations, particularly where their users' wallet addresses may be linkable to identifiable individuals in their own systems. 5) COMPLIANCE CONSIDERATIONS: Legal teams should document their assessment of whether wallet addresses and device data collected by Uniswap Labs constitute personal data under each applicable jurisdiction's definition, and update privacy notices and data inventories accordingly.
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This provision establishes the foundational data minimization claim of the policy, limiting the categories of personal data Uniswap Labs asserts it retains. Compliance teams should note that the policy separately discloses collection of wallet addresses, device data, and correspondence, and should assess whether any of these categories constitute personal data under applicable law including GDPR.
The agreement states that users are not required to provide personal data to use the Services, and that Uniswap Labs does not store personal identifiers such as names or IP addresses, though device information, browser data, and wallet addresses are collected as described elsewhere in the policy.
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