Privacy Policy

Last Updated: October 5, 2025

  1. Overview This Privacy Policy explains how we collect, use, disclose, and retain information in connection with the Service.

  2. What We Collect

2.1 Necessary data (no ID at signup)

  • Technical/usage: IP address, coarse geolocation, device/user‑agent, app telemetry, referral codes/UTMs.

  • Wallet signals: addresses you connect, basic on‑chain exposure indicators and heuristics used to detect sanctions/abuse.

2.2 Optional/consented data

  • Cookies/SDKs for analytics/marketing where consent is required. See Cookie Notice.

2.3 Escalation data (risk‑based)

  • Where risk or law requires, we may request additional information (e.g., identity or source‑of‑funds). If declined, service may be restricted or denied.

  1. How We Use Data (Legal Bases)

  • Contract: to provide, operate, and support the Service.

  • Legitimate interests: security, fraud prevention, abuse detection, product analytics, customer support.

  • Legal obligation: respond to lawful requests, maintain financial/ledger records.

  • Consent: cookies/marketing where required.

  1. Sharing & Transfers

  • Processors/partners: security/screening vendors, execution venues, infrastructure providers (including Turnkey/MPC).

  • Transfers: where data is transferred cross‑border, we use standard contractual clauses or other lawful mechanisms.

  • We do not sell personal data.

  1. Retention

  • Screening telemetry: 12–24 months (minimized/pseudonymized where feasible).

  • Financial/ledger records: 5–7 years.

  • Support tickets/rights requests: up to 24 months.

  • Consent logs: Terms version/hash and Fee Schedule version at acceptance.

  1. Your Rights Depending on your jurisdiction: access, correction, deletion, restriction, objection, portability, and appeal. Contact [email protected]. We will verify and respond within applicable timelines.

  2. Children 18+ only; we do not knowingly collect children’s data.

  3. Security We apply administrative, technical, and organizational measures appropriate to the risk (including MPC key‑share protections).

  4. Cookies/SDKs See our Cookie Notice in the interface for details and choices.

  5. Changes We may update this Policy. Material changes will be announced in‑app; continued use after posting indicates acknowledgment.

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