Analyses the main legal requirements in the California Consumer Protection Act (CCPA), general data protection regulation (GDPR) and the intersections between privacy laws, genomic data and smart contracts (such as fungible and non-fungible tokens (NFTs). The CCPA and GDPR laws impose several restrictions on the storing, accessing, processing and transferring of personal data. This has generated some challenges for lawyers, data processors and business enterprises engaged in blockchain offerings, especially as they pertain to high-risk data sets such as genomic data. The technical features of NFT, distributed storage and wallets to trace and govern genomic (DNA) data sets will allow data donors to establish digital ownership and control in line with privacy laws using ‘programmable privacy smart contracts’. To be legally compliant, the design of blockchain value propositions should include privacy-by-design capabilities in the smart contract coding language itself. This article describes three domains (privacy laws, genomics and NFTs) and begins to explore how data engineers can address the challenges of coding privacy laws, the legal requirements into smart contracts. This current approach focuses on NFTs and genomic data requirements which include the selection of genetic metadata borrowing from developing ERC specifications and their programming logic. Programmable privacy is a unique way to write and design computer code, which can automatically check the legal compliance of the smart contract in a trust-less and decentralised way. We exemplify the approach by describing the conceptual value proposition, privacy-preserving genomic data platform.

1. NFT- Privacy Laws
Abstract:
Analyses the main legal requirements in the California Consumer Protection Act (CCPA),
general data protection regulation (GDPR) and the intersections between privacy laws,
genomic data and smart contracts (such as fungible and non-fungible tokens (NFTs). The
CCPA and GDPR laws impose several restrictions on the storing, accessing, processing
and transferring of personal data. This has generated some challenges for lawyers, data
processors and business enterprises engaged in blockchain offerings, especially as they
pertain to high-risk data sets such as genomic data. The technical features of NFT,
distributed storage and wallets to trace and govern genomic (DNA) data sets will allow
data donors to establish digital ownership and control in line with privacy laws using
‘programmable privacy smart contracts’. To be legally compliant, the design of
blockchain value propositions should include privacy-by-design capabilities in the smart
contract coding language itself. This article describes three domains (privacy laws,
genomics and NFTs) and begins to explore how data engineers can address the challenges
of coding privacy laws, the legal requirements into smart contracts. This current approach
focuses on NFTs and genomic data requirements which include the selection of genetic
metadata borrowing from developing ERC specifications and their programming logic.
Programmable privacy is a unique way to write and design computer code, which can
automatically check the legal compliance of the smart contract in a trust-less and
decentralised way. We exemplify the approach by describing the conceptual value
proposition, privacy-preserving genomic data platform.
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2. ● Introduction:
This Privacy Policy describes how Coinbase Technologies, Inc. (“Coinbase
Technologies,” “we”, “us” or “our”) handles personal information that we collect through

3. the Coinbase NFT websites (nft.coinbase.com, coinbase.com/nft) that link to this Privacy
Policy, as well as through social media, our marketing activities, and other activities
described in this Privacy Policy (collectively, the “Coinbase NFT Service”). Please take
a moment to read this Privacy Policy carefully. If you have any questions about this
Policy, please submit your request via our Support Portal. We may modify this Privacy
Policy from time to time which will be indicated by changing the date at the top of this
page. If we make any material changes, we will notify you by email (if you have an email
address specified in your account), by means of a notice on our website prior to the
change becoming effective, or as otherwise required by law.
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1. ACCEPTANCE OF THIS PRIVACY POLICY:
By accessing and using the Coinbase NFT Service, you signify acceptance to the terms of
this Privacy Policy. We may provide additional "just-in-time" disclosures about certain
data processing practices within the Coinbase NFT Service; these disclosures may
supplement or clarify the privacy practices described here, or may provide you with
additional choices about how we process your personal information.
If you do not agree with or you are not comfortable with any aspect of this Privacy
Policy, you should immediately discontinue access or use of the Coinbase NFT Service.
2. THE PERSONAL INFORMATION WE COLLECT
Information you provide to us. Personal information you may provide to us through the
Coinbase NFT Service or otherwise includes: Contact information, such as your first and
last name, and email address. Personal Identification Information: Full name, date of
birth, nationality, gender, signature, phone number, home address
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3. Formal Identification Information:
Government issued identity documents and photographs such as Passport, Driver’s
License, National or State Identity Card. Biometric Information: information generated to
create a print or template of an individual’s face or voice, including from a photograph.
Profile information, such as your username that you may set to establish an online
account on the Coinbase NFT Service, biographical details, links to your profiles on
social networks, interests, preferences, and any other information that you add to your

4. account profile. Communications that we exchange with you, including when you contact
us through the Coinbase NFT Service, social media, or otherwise. Transactional
information, such as information relating to or needed to complete non-fungible token
(NFT) purchases or sales on or through the Coinbase NFT Service which includes

5. transactional details, fees, and sales prices. Marketing information, such as your
preferences for receiving our marketing communications and details about your
engagement with them. User-generated content, such as profile pictures, photos, images,
music, videos, comments, questions, messages, works of authorship, and other content or
information that you generate, transmit, or otherwise make available on the Coinbase
NFT Service, as well as associated metadata. Metadata includes information on how,
when, where and by whom a piece of content was collected, how that content has been
formatted or edited, and information that you can add or can have added to your content,
such as keywords, geographical or location information, and other similar data. Financial
information, such as your linked virtual currency or wallet accounts, stored value
accounts, and associated details. Third-party sources. We may combine personal
information we receive from you with personal information we obtain from these other
sources: Public sources, such as government agencies, public records, social media
platforms, public blockchain(s), and other publicly available sources.
Marketing partners, such as joint marketing partners and event co-sponsors. Third-party
services, such as social media services, that you use to log into, or otherwise link to, your
Coinbase NFT account. This information may include your username, profile picture and
other information associated with your account on that third-party service that is made
available to us based on your account settings on that service. Please note that your use of
third-party services is governed by the terms and privacy policies of those services, not
ours. Information collected automatically. We, our service providers, and our business
partners may collect certain types of information automatically, such as information about
your device, your usage of and interaction with the Coinbase NFT Service, and
interaction with other online services. This information helps us address customer support
issues, improve the performance of the Coinbase NFT Service, provide you with a
streamlined and personalized experience, and protect your account from fraud or abuse,
such as by detecting unauthorized access. Information collected automatically includes:
Device information: such as your IP address (which can indicate your general geographic
location), device type, operating system and version, manufacturer and model, browser
name and version, screen resolution, device event information, hardware settings,
memory usage), device identifiers, language settings.
Online Identifiers, activity, and usage information: engagement with content on the
Coinbase NFT Service or with communications from us, authentication data, click-stream
data, public social networking posts, pages and links accessed on the Coinbase NFT
Service or used to access the Coinbase NFT Service from a third party site.
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● Privacy Legislation:

6. Current privacy legislation was not drafted with blockchain and Web 3.0 in mind. Any
attempts to apply the existing legal framework to Web 3.0 technology and crypto assets
result in unsatisfactory outcomes. For instance, the fact that data cannot be deleted from
the blockchain runs contrary to basic data subject rights under California Consumer
Privacy Act and EU General Data Protection Regulation, (which has effect in the UK
through the Data Protection.
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● Solution Of Privacy:
As noted, traditional transactions involve varying degrees of information about the parties
being shared with intermediaries and/or made public. In contrast, blockchain transactions
avoid the need to share personal information with intermediaries, thus reducing the risk
of exposure of personal information. Moreover, some have proposed that NFTs could
contain tokenized information to be used in conjunction with smart contracts such that
smart contracts could use the NFTs to “verify necessary information without ever
exposing it to a third party. This would allow the use of a tokenized identity to enter into
a smart contract without sharing personal information with intermediaries or others.
However, as is considered further below, a new, tokenized identity that is distinct from an
individual’s real life identity may not be an effective solution to privacy issues.
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● Risk to Privacy:
If it is accepted that Web 3.0 is about individual ownership of online content (including
crypto assets on the blockchain), the notion of identity in this new age risks becoming
heavily intertwined with the assets held by individuals. There are several ways in which
owning, acquiring and disposing of NFTs could give rise to privacy risks in the Web 3.0
era including.

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● Conclusion:
NFTs may be an exciting medium for those who wish to inhabit a seemingly anonymous
and private life online, it is clear that there are several inherent potential threats to
privacy. It remains to be seen how NFTs and blockchain technology will adapt with more

8. widespread use and technological advances. However, as Web 3.0 continues to grow, it is
likely that we will see an increasing tension between true anonymity and privacy on one
hand, and the public aspects of NFTs and blockchain technology on the other. It will be
equally important as the space develops to ensure that any privacy law frameworks are
adhered to (to the extent they may already apply) and monitored (in case the law is
updated to specifically address privacy.
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