# PRIVACY POLICY **Last updated:** 2026-08-15 This Privacy Policy describes how Neutral Trade ("**we**", "**us**", or "**our**"), collects, uses, and discloses personal data in connection with the website at ****, any associated mobile applications, and any related smart contracts, vaults, and interfaces operated by Neutral Trade (collectively, the "**Interface**"). Neutral Trade is the controller of your personal data within the scope of this Privacy Policy. If you have questions or wish to exercise any right described below, contact us at ****. ### 1. Changes to this Policy If our data processing practices change, we will update this Privacy Policy and revise the date above. Where the change is material, we will use reasonable means to notify you (such as a notice on the Interface). Your continued use of the Interface after an update constitutes acknowledgement of the revised policy. If you do not agree with our practices, your remedy is to stop using the Interface. ### 2. Eligibility You must be at least 18 years old, or the legal age of majority in your jurisdiction of residence, whichever is higher, to use the Interface. By accessing or using the Interface, you represent and warrant that you meet this requirement. The Interface is not offered to, and may not be used by, persons or entities located in any jurisdiction in which the relevant products or services are not available, including jurisdictions subject to comprehensive sanctions administered by the United States, the United Kingdom, the European Union, or the United Nations, or any other jurisdiction in which use of the Interface would be unlawful or restricted. Accessing the Interface from such a jurisdiction is a breach of our Terms of Use. Eligibility, restricted jurisdictions, and prohibited persons are set out in detail in our Terms of Use. ### 3. Applicability This Privacy Policy applies to all of your interactions with us through the Interface. Your use of the Interface is also governed by our **Terms of Use**, available at , which contain additional terms regarding eligibility, restricted jurisdictions, prohibited uses, and dispute resolution. This Privacy Policy does not apply to: * Third-party wallets and Web3 utilities (as defined in the Terms of Use), blockchains, exchanges, fiat on-ramps, or other third-party services that you may use in connection with the Interface. Those services are governed by their own privacy policies. * Information you share with us through channels other than the Interface (for example, in-person meetings, recruiting, or business development conversations), which may be subject to separate notices. * Public blockchain data, which is by design transparent, immutable, and not within our control. ### 4. Data Processing in Connection with the Interface #### 4.1 Personal data we collect We aim to collect the minimum personal data necessary to operate, secure, and improve the Interface. The categories of personal data we may process include: * **Technical and device data** — IP address, approximate location derived from IP, MAC address (where exposed by your device), browser type and language, operating system, device identifiers, referrer URLs, log files, timestamps, and similar technical information, collected automatically when you access the Interface. * **Usage data** — pages viewed, features used, clicks, navigation paths, session duration, and similar behavioural data about how you interact with the Interface. * **Wallet and on-chain data** — public wallet addresses you connect to the Interface, transaction history visible on the blockchain, balances, and similar on-chain information accessible when you interact with the Interface. * **Voluntary inputs** — information you choose to provide, such as an email address for newsletter subscription, support requests, or feedback. * **Authentication data** — where you choose to sign in using a third-party identity provider, the limited account information that provider shares with us in accordance with your authorization. We do not, and will never, ask you for your wallet seed phrase, private key, or any equivalent secret. Anyone asking you for these credentials in the name of Neutral Trade is acting fraudulently. We do not intentionally collect special-category personal data (such as data revealing racial or ethnic origin, political opinions, religious beliefs, health, or biometric data). #### 4.2 How we use wallet addresses Public wallet addresses are used to identify a user's journey through the Interface for product analytics, fraud and abuse prevention, and compliance with applicable restrictions (including geo-restrictions). We analyse wallet-level usage in aggregate to improve the Interface and do not use this data to construct individual profiles for marketing purposes. The legal basis for this processing is our legitimate interest in operating, securing, and improving the Interface, and, where applicable, the performance of a contract with you. #### 4.3 Purposes of processing We use the personal data described above for the following purposes: * **Operating and securing the Interface** — including authenticating sessions, preserving language and display preferences, applying geographic restrictions, detecting and preventing fraud, abuse, and security incidents, and protecting the integrity of the Interface. * **Improving the Interface** — analysing aggregated and pseudonymised usage data to understand product performance and inform product development. * **Communicating with you** — responding to inquiries, providing support, and, where you have opted in, sending product updates or newsletters. * **Enforcing our Terms of Use** — including suspending or restricting wallet addresses and blocking IP addresses where we determine, in our reasonable discretion, that use of the Interface is in breach of our Terms of Use or applicable law. * **Legal compliance** — meeting our obligations under applicable laws, responding to lawful requests from regulators or law enforcement, and enforcing our Terms of Use. #### 4.4 Legal bases for processing (GDPR / UK GDPR) Where the EU General Data Protection Regulation or UK GDPR applies, we rely on the following lawful bases: * **Contractual necessity** — to provide the Interface to you and respond to requests you make. * **Legitimate interests** — to secure, monitor, improve, and develop the Interface, prevent fraud and abuse, enforce our Terms of Use, and operate our business, where these interests are not overridden by your rights and freedoms. * **Consent** — where we ask you specifically (for example, for non-essential cookies, marketing communications, or where required by law). * **Legal obligation** — to comply with applicable laws and respond to valid legal requests. #### 4.5 Categories of processors We engage third-party service providers ("**processors**") that process personal data on our behalf, under contractual obligations to safeguard that data. We engage processors in the following categories: 1. **Hosting and technical infrastructure vendors** — for serving the Interface, network metadata, and storage. 2. **Wallet connectivity and authentication vendors** — for enabling wallet connection, optional social or email sign-in, and related on-ramp features. 3. **Analytics and product performance vendors** — for measuring and understanding aggregate usage of the Interface. 4. **Communication and email delivery vendors** — for sending transactional and subscription emails. 5. **Identity providers** — where you choose to sign in using a third-party account, that provider processes the relevant authentication data. We may update this list of processor categories as our vendor stack evolves. #### 4.6 Disclosure of personal data We may disclose personal data: * To the categories of processors described in §4.5, strictly for the purposes set out in this Policy. * To affiliates and subsidiaries of Neutral Trade, where they assist us in operating the Interface. * In connection with a merger, acquisition, reorganisation, or sale of assets, in which case we will require the recipient to honour this Policy. * In response to enquiries from regulatory or governmental authorities, including by passing relevant information to our nominees or affiliates, custodians, infrastructure participants, network participants, or government agencies, as set out in our Terms of Use. * To comply with applicable law, regulation, court order, or lawful request from a governmental authority, or where we have a good-faith belief that disclosure is necessary to protect our rights, the rights of users, or the public. We do not sell your personal data and we do not share it for cross-context behavioural advertising. #### 4.7 Data retention We retain personal data only for as long as necessary to fulfil the purposes described in this Policy, satisfy our legal and regulatory obligations, resolve disputes, and enforce our agreements. Aggregated and pseudonymised data that no longer identifies you may be retained for as long as commercially useful. Note that **public blockchain data is immutable and outside our control**. Transactions made through the Interface and recorded on a blockchain cannot be deleted, modified, or erased by us, regardless of any request you make. This is an inherent characteristic of public blockchains and is not specific to Neutral Trade. ### 5. Cookies and Similar Technologies We use strictly necessary cookies and similar technologies (including browser local storage) to operate the Interface, remember your preferences, and apply geographic restrictions. Where we use non-essential analytics technologies, we will seek your consent where required by applicable law. You can manage cookies through your browser settings. Blocking strictly necessary cookies and local storage may impair the functioning of the Interface, including language selection, geo-restriction logic, and wallet connectivity. ### 6. Your Rights Under GDPR / UK GDPR If you are located in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to your personal data: * **Right to be informed** — to know what personal data we process and why (this Policy serves that purpose). * **Right of access** — to request a copy of the personal data we hold about you. * **Right of rectification** — to correct inaccurate or incomplete data. * **Right to erasure** ("right to be forgotten") — to have your personal data deleted, subject to legal or legitimate-interest exceptions, and subject to the blockchain-immutability limit described in §4.7. * **Right to restriction of processing** — to ask us to limit how we process your data in certain circumstances. * **Right to data portability** — to receive your data in a structured, commonly used, machine-readable format and to have it transmitted to another controller where technically feasible. * **Right to object** — to object to processing based on our legitimate interests, including profiling. * **Right to withdraw consent** — where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing. * **Right to lodge a complaint** — with your local data protection authority. To exercise any of these rights, contact us at ****. ### 7. International Transfers Our processors are located in various jurisdictions, including outside the EEA and the UK. Where we transfer personal data outside the EEA, the UK, or Switzerland to a country that does not provide an adequate level of data protection under applicable law, we rely on appropriate safeguards, including Standard Contractual Clauses approved by the relevant authority, supplemented by additional measures where required. A copy of the safeguards in place can be requested by contacting ****, subject to reasonable confidentiality protections. ### 8. Data Security We implement technical and organisational measures designed to protect personal data from loss, misuse, and unauthorised access, alteration, or disclosure. These include encryption in transit, access controls, vendor due diligence, and contractual safeguards with our processors. No system is perfectly secure, and we cannot guarantee that our security measures will never be defeated. Use of the Interface is at your own risk, and you are responsible for safeguarding your wallet, keys, and credentials. We will never ask you for your wallet seed phrase or private key. Treat any such request as fraudulent. ### 9. Blockchain Disclosures The Interface enables you to interact with public blockchains, including Solana. You should understand that: * Blockchain transactions are **public, permanent, and immutable**. We cannot reverse, erase, or modify transactions recorded on a blockchain. * Public wallet addresses and on-chain activity are visible to anyone and may be subject to forensic analysis that could de-anonymise you, particularly when combined with off-chain data. * We do not control blockchains and are not responsible for the processing of your data by blockchain networks, validators, or other participants. ### 10. Children The Interface is not directed to, and may not be used by, persons under 18, as set out in §2 (Eligibility). We do not knowingly process personal data of children under 18. If you believe we have collected personal data from a child, contact us at **** and we will take reasonable steps to delete it. ### 11. Contact For any questions about this Privacy Policy or to exercise your rights, contact us at ****. --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://docs.neutral.trade/legal/privacy-policy.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. 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