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The policy states that Uniswap Labs is unable to edit or delete transaction data, wallet addresses, or asset information stored on blockchain networks, and characterizes this data as beyond the company's control.
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 a structural limitation on the company's ability to fulfill GDPR erasure requests and CCPA deletion requests for on-chain data. Compliance teams and supervisory authorities may need to evaluate whether this limitation is consistent with applicable data protection obligations, as the document asserts rights for users that cannot be operationally fulfilled for this category of data.
Interpretive note: Whether blockchain-stored wallet addresses constitute personal data subject to GDPR erasure rights is subject to ongoing regulatory interpretation and varies by EU member state supervisory authority guidance.
Under this clause, GDPR and CCPA rights to deletion or rectification of personal data do not extend to transaction data, wallet addresses, or asset information stored on blockchain networks, as the policy states this data is beyond Uniswap Labs' control.
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"Nevertheless, we cannot edit or delete information that is stored on a particular blockchain. Information such as your transaction data, blockchain wallet address, and assets held by your address that may be related to the data we collect is beyond our control.Excerpt from Uniswap's Privacy Policy
1) REGULATORY LANDSCAPE: This provision directly engages GDPR erasure rights (the right to be forgotten) and CCPA deletion rights. The tension between blockchain immutability and GDPR Article 17 has been the subject of guidance from several European data protection authorities, though no definitive pan-EU resolution has been established. The FTC may also have relevance where deletion representations are assessed against actual operational capability. 2) GOVERNANCE EXPOSURE: High. The policy asserts GDPR and CCPA deletion rights in general terms but then carves out on-chain data from those rights due to technical limitations. This structural gap between stated rights and operational fulfillment may attract scrutiny from GDPR supervisory authorities, particularly where blockchain wallet addresses are assessed as personal data under applicable law. 3) JURISDICTION FLAGS: EU/EEA users face the highest exposure, as GDPR supervisory authorities in multiple member states have issued guidance on the treatment of blockchain-stored data as personal data. The enforceability of the deletion limitation against GDPR Article 17 requirements is jurisdiction-dependent and subject to ongoing regulatory interpretation. 4) CONTRACT AND VENDOR IMPLICATIONS: Organizations relying on Uniswap Labs services and processing their own users' wallet data should assess whether the on-chain data limitation affects their own data subject request fulfillment obligations. B2B contracts referencing Uniswap Labs data handling should account for this structural limitation. 5) COMPLIANCE CONSIDERATIONS: Legal teams should document the on-chain data carve-out in data subject request response procedures and assess whether the company's legitimate interests or compliance legal basis for retaining on-chain data references is adequately documented. Privacy notices directed at EU users should clearly distinguish between off-chain data subject to deletion and on-chain data that is not.
This provision establishes a structural limitation on the company's ability to fulfill GDPR erasure requests and CCPA deletion requests for on-chain data. Compliance teams and supervisory authorities may need to evaluate whether this limitation is consistent with applicable data protection obligations, as the document asserts rights for users that cannot be operationally fulfilled for this category of data.
Under this clause, GDPR and CCPA rights to deletion or rectification of personal data do not extend to transaction data, wallet addresses, or asset information stored on blockchain networks, as the policy states this data is beyond Uniswap Labs' control.
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