Privacy Policy

1. Information We Collect and How We Use Your Information

When you use or access the Services, we collect information about you from a variety of sources, including directly from you, from third parties, and automatically through your use of our Site or Services. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, as a matter of our legitimate interests, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing our Terms of Service, and protecting our rights and the rights of our employees, users or other individuals.

1.1 Information We Collect Directly From You

Some features of the Services may require you to directly provide certain information. Information that you directly submit to us includes:

• Basic contact details: Such as your email address. We use this information to provide customer support and the Services, as required to perform our contract with you, and because it is in our legitimate interest to communicate with you regarding platform updates.
• Blockchain wallet information: Including your publicly accessible digital asset wallet address and publicly available blockchain address, if you connect your blockchain wallet to the Services. We use this information to provide the Services, to screen your wallet for illicit activity or geographic restrictions, and to enable you to transact through the Services.
• Session Authorization & MPC Policies: When you enable automation features (e.g., “Auto-Swap”), we collect the cryptographic signatures and “Session Policies” you sign. We use this strictly to authorize specific on-chain transactions via our Multi-Party Computation (MPC) architecture as required to perform our contract with you.
• Transaction information: Such as the type of asset you purchase or sell, the amount, and other metadata about transactions made through the Services. We use this information to provide you with the Services, including supporting the execution of trades you initiate.
• Communications: Any other information you choose to provide us or otherwise include in communications with us, for example, when sending a support message, in our legitimate interests to be responsive to your requests.

1.2 Information We Collect Automatically

We and third parties use cookies, pixels or other tracking technologies to automatically collect certain information about your interactions with our Services.

• Device data: Such as device type, operating system, unique device identifier, and internet protocol (IP) address.
• Usage data: Information about your activity in the Services (such as the date/time stamps associated with your usages, searches, and features used), and device event information (such as system activity and error reports).
• Location-based data: Such as approximate location based on IP address, used primarily to enforce Restricted Jurisdictions policies.

1.3 Information We Collect From Other Sources

We may obtain information about you from outside sources, including:

• Public Blockchains: Publicly available or visible information on the Solana blockchain or other public sources, including timestamps of transactions, transaction IDs, amounts, and wallet addresses.
• Social Channels: Information you publicly post on our social channels or social media accounts (e.g., Discord or X), which we use in our legitimate interests to engage in community discussions and improve our Services.

1.4 Deidentified Information

We may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you. We may use such deidentified information for any purpose, including system analytics and performance tracking.

2. How We Disclose Your Information

We may disclose your information for legitimate purposes as set out in this Policy, including:

• 2.1 Transaction Data Sharing: To provide faster execution and better outcomes, we may share certain transaction-related data with third parties, such as liquidity providers, RPC nodes, and trading infrastructure partners.
• 2.2 Business Transactions: In the event that we are acquired by or merged with another company, or as part of an asset transfer, we may transfer the information we have collected from you to counterparties in connection with such transactions.
• 2.3 Legal Requirements and Protection: We may disclose the information we collect as needed to comply with applicable law, judicial orders, regulatory inquiries, or to ensure the safety and security of our business and users.
• 2.4 Third-Party Service Providers: We may share your information with third-party service providers who assist us in operating our Site and Services, including for web hosting, DDoS protection, system administration, and data indexing.
• 2.5 Our Professional Advisors: We may share your information with our professional advisors, such as auditors, law firms, or accounting firms, to assess, protect, and defend our rights.

3. Third-Party Services and Integrations

Our Site and Services may contain links to third-party websites or platforms. We are not responsible for the privacy or security of, or information found on, such third-party websites. Use of social features (e.g., Discord integrations) may allow third parties to collect and/or use your information.

4. Cookies and Tracking Mechanisms

We use cookies to facilitate navigation and save UI preferences (like slippage tolerance). Most browsers automatically accept cookies, but you may modify your settings to block them. Please note that disabling cookies may cause certain areas of the Services to work incorrectly.

5. Your Privacy Rights (EEA/UK/GDPR)

Depending on where you live, you may have specific rights regarding your personal information. If you are a resident of the European Economic Area (EEA) or the United Kingdom, you have rights under the General Data Protection Regulation (GDPR):

• The right to request access to and a copy of the personal information we hold about you.
• The right to correct or update inaccurate personal information.
• The right to request deletion of personal information (the “Right to be Forgotten”).
• Note on Blockchain Data: Because our Services interact with public blockchains, data recorded on-chain (like transaction hashes and wallet addresses) is immutable. We cannot delete or alter information once it is broadcast to the Solana network.
• The right to require us to restrict or object to the processing of your information.
• The right to portability of your personal information.
• The right to lodge a complaint with a supervisory authority.

To exercise these rights regarding data we control (such as support emails), contact us at [email protected].

6. Information for California Residents (CCPA)

This section applies only if you are a California resident. For purposes of this section, “personal information” includes “sensitive personal information” as defined under the California Consumer Privacy Act (CCPA).

6.1 Processing of Personal Information

Since the recent launch of our Services, we collect (and where indicated, disclose for a business purpose) the following categories of information: identifiers (wallet addresses, IP addresses); internet or other electronic network activity information; and account access metadata (cryptographic session policies).

6.2 Selling or Sharing Personal Information

We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so since the inception of the Company. Further, we do not have actual knowledge that we sell or share personal information of residents under 16 years of age.

7. Data Security, Retention and Transfers

7.1 How We Protect Your Information

We implement commercially reasonable precautions, including industry-standard encryption and our MPC (Multi-Party Computation) signing architecture, designed to eliminate single points of failure. Please be aware that no data security measures are impenetrable. We recommend taking steps to protect your own devices and wallet access details.

7.2 How Long We Keep Your Information

We retain information only for as long as is reasonably necessary:

• Public Blockchain Data: Retained indefinitely, as this information is permanently recorded on public blockchains.
• Transaction Data: Metadata and routing details are retained for up to 7 years to comply with financial regulations and support fraud prevention.
• IP Addresses and Session Data: Retained for up to 5 years for security purposes, geographic sourcing requirements, and abuse prevention.
• MPC Session Material: Cryptographic session material is stored only for the duration of its validity (e.g., 7 days) and is permanently deleted upon session expiry or revocation.

7.3 Data Transfers

The Services are operated by Blank Trade Inc., a Delaware corporation. Information we collect may be stored and processed in the United States or other jurisdictions that may not offer the same level of data protection as your home country. By using the Services, you consent to this transfer.

8. Special Considerations

• 8.1 Children's Privacy: Our Services are not intended for individuals under 18.
• 8.2 Changes to this Policy: We may modify this Policy at any time. Your continued use of the Services indicates acceptance of the updated terms.
• 8.3 Language: In the event of any discrepancy between the English version and a local language version, the English version shall prevail.

9. Contact Us

If you have questions about our privacy practices or this Policy, please contact us at:

Blank Trade Inc.
Email: [email protected]