Privacy Policy

We may collect two basic types of information: personal information and anonymous information. We may use personal and anonymous information to create a third type of information: aggregate information. Personal and anonymous information may be collected directly from you through the use of our services and through this site.

We collect information from you when you:

• Create an account on the Platform;
• Connect a non-custodial cryptocurrency wallet to the Platform;
• Use AI agents (including Luma, Meridian, Riven, Brix, Koda, Lucid, Mentor, Vanta, or others) or other tools available on the Platform;
• Respond to a communication such as an e-mail;
• Participate in our chat rooms, message boards, or other interactive features; or
• Otherwise interact with the Platform or any of its features.

When creating an account, you may enter your name, e-mail address, and other identifying information.

Because the Platform operates as a productivity and analytics layer on top of third-party perpetual futures exchanges (“Perpetual DEXs”), we also collect certain information generated in the course of your use of the Platform, including:

• Wallet addresses connected to the Platform. Please note that wallet addresses used through the Platform are recorded on public blockchains and are inherently public;
• IP addresses and approximate geolocation data;
• Session data, including login times, browser type, operating system, device information, and referring URLs;
• Usage information, including AI agent interactions, strategy inputs, trade proposals reviewed, and Platform features accessed;
• Prompts, feedback, strategy designs, and other content you submit to the Platform or its AI agents; and
• Information generated by our proprietary data aggregation feed, to the extent it processes information associated with your account or wallet activity.

Like many websites, we may use “cookies” and other tracking mechanisms to enhance your experience and gather information about visitors and visits to our websites. Please refer to the “Do we use ‘cookies’?” section below for information about cookies and how we use them.

We may use information collected on the website and Platform, which may include your personal information, for various purposes. In general, we use the personal information we collect to operate the Platform, pursue our mission and operations, and engage in related activities. You should assume that we will use all information for all lawful purposes.

We reserve the right, but do not undertake a duty, to notify you of court orders, subpoenas, or other legal process if allowed. If you do not want us to respond to legal process compelling us to disclose your information, you need to seek a valid order permitting us to refuse to disclose it and serve the order on us at least three business days before the response deadline.

We reserve the right to use, disclose, retain, share, sell and otherwise deal with all information collected via the site or Platform internally or to third parties, for any lawful purpose or to prevent harm to us or others. For example, and without limitation, in our discretion we may use the information to:

• Understand how visitors navigate through our website and Platform, to enhance your experience while using the Platform, and to make the materials we post as valuable to visitors as possible;
• Operate, maintain, and improve the Platform and its AI agents, analytics, strategy tools, and related features;
• Train, fine-tune, or evaluate AI models and agents that power Platform features, using content you submit such as prompts, feedback, and strategy inputs;
• Process your account registration and verify your eligibility, including compliance with our geographic and jurisdictional restrictions;
• Verify that you are not located in a Restricted Jurisdiction (as defined in our Terms of Service), including through the use of IP address geolocation and wallet address screening;
• Screen wallet addresses and account information against applicable sanctions lists, including those maintained by OFAC, the UN Security Council, and equivalent authorities;
• Send you periodic e-mails or electronic information. (If you would no longer like to receive communications from us, please refer to the “How can you remove or modify information you have provided to us?” section below.);
• Disclose information to service providers and others in order to deal with requests and questions from you and to assist or respond to our agents (including auditors);
• Disclose information to government regulators, law enforcement authorities, or alleged victims of identity theft, as well as through voluntary disclosures; and
• Disclose any matter relating to the site or Platform not listed in this Policy, but which is not prohibited by law from being disclosed.

We do not purport to have listed all possible disclosures that we might make. This Policy is intended to help you understand our general practices. This Policy is not a promise that your information will never be disclosed except as described above. For example, third parties may unlawfully intercept or access information transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse, or misuse information despite a lack of permission. Although we use what we believe to be commercially reasonable practices to protect your privacy, that does not mean, and you should not expect it to mean, that your information or communications will always be private or protected.

We generally will retain information for as long as required, allowed, or for as long as we believe it useful. If you cease using the Platform, or your permission to use the Platform is terminated, we may continue to use and disclose your personal information in accordance with this Policy as amended from time to time. We do not undertake retention obligations through this Policy. We may dispose of information in our discretion without notice, subject to applicable law.

WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION OR OTHER INFORMATION IN ANY FORM. We do implement a variety of security measures to maintain the safety of your personal information. Your personal information is contained behind secured networks and is only accessible by a limited number of persons. All sensitive information you supply is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our databases to be only accessed as stated above.

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow them) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. Subject to the capabilities of the web browser you use, you may restrict the use of certain cookies.

We also use Google Analytics, which is a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies to help the website analyze how individuals use the website. The non-personal information generated by the cookie about your use of the site will be transmitted to and stored by Google on its servers. Google will use this information for the purpose of evaluating your use of the site, compiling reports on site activity for our purposes, and providing other services relating to site activity and Internet usage. For information on how Google collects and processes data, please refer to Google’s privacy policy and its “How Google Uses Information from Sites or Apps that Use Our Services” page. You may disable cookies within your browser; however, please note that if you do so you may not be able to use the full functionality of the site. By using this site, you consent to the processing of data about you by Google as described above and in Google’s privacy policy.

Some browsers allow you to choose to have your computer warn you each time a cookie is being sent, and some browsers enable you to choose to turn off all cookies. You do this through the settings on your browser (like Chrome, Safari, or Internet Explorer). Each browser is a little different, so look at your browser’s Help menu or other features to learn the correct way to modify the manner in which your browser handles cookies. If you turn cookies off, you may not have access to certain features on the site or Platform.

As noted in our Terms of Service, the Platform operates as a non-custodial productivity layer. We do not custody, hold, or have access to your private keys, seed phrases, or digital assets. However, wallet addresses you connect to the Platform are transmitted to us and recorded in our systems for the purpose of providing Platform features, conducting sanctions screening, enforcing geographic restrictions, and complying with applicable law.

You acknowledge that wallet addresses connected to or used through the Platform are recorded on public blockchains and are inherently public. On-chain transaction data associated with your wallet address may be accessible to third parties independently of our Platform.

We may release your information when we believe release is appropriate to comply with the law; enforce our site policies; protect ours or others’ rights, property, or safety; screen for sanctions compliance or jurisdictional eligibility; or as otherwise described in the “How do we use your information?” section above.

We may also share information with:

• Third-party service providers who assist us in operating the Platform, processing data, or delivering services, subject to confidentiality obligations where applicable;
• Perpetual DEX protocols and their underlying infrastructure to the extent necessary to provide connectivity features of the Platform (note that such protocols are decentralized and may process your data independently of our instructions);
• Analytics providers, including Google Analytics;
• Sanctions screening and compliance service providers; and
• Government regulators, law enforcement authorities, courts, and other authorities as required by applicable law, including in connection with our regulatory cooperation obligations described in our Terms of Service.

To change or delete your online account information from our database, please contact us directly through one of the means identified in the “How to contact us” section below. Please note that we may retain certain information as required by applicable law, for legitimate business purposes, or to complete any pending transactions. Additionally, wallet addresses associated with on-chain transactions cannot be removed from public blockchain records.

If you are visiting our website from outside of the United States or otherwise contacting us from outside of the United States, please be aware that your personal information may be transferred to, stored, or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our site or Platform, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Policy.

Please also note that the Platform is not available to users in Restricted Jurisdictions, as defined in our Terms of Service. We may use your IP address, wallet address, and other information to detect and enforce these geographic restrictions. If you attempt to access the Platform from a Restricted Jurisdiction, we may block your access and retain records of the attempt to the extent required by applicable law.

This notice applies only to California residents and is made pursuant to California Civil Code § 1798.83. As noted above, we may disclose personal information about you, such as your email address, to third parties. If we disclose personal information about you to a third party and the third party will use that information for direct marketing purposes, you have the right to contact us at legal@perpdesk.xyz to request that we notify you as to: (1) what categories of personal information we shared with the direct marketer; and (2) the name and address of the direct marketing businesses with whom we shared such information, and if the nature of the direct marketing businesses cannot be reasonably determined from its name, examples of the products or services marketed.

We may include third-party links on our site, including links to Perpetual DEX protocols and other external platforms that integrate with the Platform. Many of these linked sites have separate and independent privacy policies. Except for sites controlled by us, we have no responsibility or liability for the content and activities of linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these linked sites (including if a specific link does not work).

If we are required to provide notice of unauthorized access or other invasion of certain security systems, you agree that we may do so when required (or voluntarily) by posting notice on our website or sending notice to any email address we have for you, in our good faith discretion, to the extent permitted by applicable law. You agree that notice to you will count as notice to others for whom you are acting, and agree to pass the notice on to them.

We do not want to collect information from children. You must be at least 18 years of age (or older if the age of majority in your jurisdiction is greater than 18) to use the Platform, consistent with the eligibility requirements set forth in our Terms of Service. Do not provide any personal information unless you meet the minimum age requirement. If a person under the age of 18 has provided personal information, a parent or guardian may so inform us by contacting us through any means offered in the “How to contact us” section below, and we will use reasonable efforts to delete it from our database, subject to applicable law and this Policy.

If you believe you are a victim of identity theft entitled by law to request information from us, write us at the address below and we’ll explain what information we require in order to respond. After receiving that information, we’ll supply (without charge) information we then have that we are legally required to provide (subject to applicable law and reserving all rights and defenses).

If we decide to change our Policy, we will post those changes on this page. Unless otherwise noted, the updated Policy will apply to all information we hold at the time the updated Policy takes effect, except to the extent permitted by applicable law.

We welcome your questions, comments, and concerns about privacy. Please send us any and all feedback pertaining to privacy, or any other issue, to PerpDesk Inc. at legal@perpdesk.xyz.

This Policy applies only to information collected online, including through our website and Platform.