1. Introduction

Polly ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application ("App") and website (collectively, the "Service"). Please read this policy carefully. By using the Service, you consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Information You Provide

Account Information: Email address, authentication credentials (via Privy)
Wallet Information: Public wallet addresses associated with your account
Preferences: Alert settings, notification preferences, watchlist selections
Communications: Any messages or feedback you send to us

2.2 Information Collected Automatically

Device Information: Device type, operating system, unique device identifiers, mobile network information
Usage Data: Features accessed, screens viewed, actions taken, time spent, interaction patterns
Push Notification Tokens: Required for delivering alerts to your device
Log Data: IP address, browser type, access times, referring URLs
Location Data: Approximate location based on IP address (we do not collect precise GPS location)
Performance Data: App crashes, diagnostics, and performance metrics

2.3 Blockchain Data

When you execute trades or interact with blockchain networks through the Service, transaction data is recorded on public blockchains. This includes wallet addresses, transaction amounts, and timestamps. This data is publicly accessible and immutable—we do not control it once recorded on the blockchain.

2.4 Information from Third Parties

Privy: Authentication data, wallet addresses
Prediction Markets: Public trading data from Polymarket, Kalshi, and other platforms
Analytics Providers: Aggregated usage statistics

3. How We Use Your Information

We use the collected information for the following purposes:

Provide the Service: Deliver whale alerts, market data, and trading functionality
Personalization: Customize alerts and content based on your preferences
Push Notifications: Send alerts about market activity, trades, and updates
Transaction Processing: Facilitate trades and collect applicable fees
Communication: Send service-related notices, security alerts, and support responses
Analytics: Analyze usage patterns to improve the Service
Security: Detect, prevent, and address fraud, abuse, and security issues
Legal Compliance: Comply with applicable laws, regulations, and legal processes
Product Development: Develop new features and improve existing functionality

4. Information Sharing and Disclosure

We may share your information in the following circumstances:

4.1 Third-Party Service Providers

Privy: Authentication and wallet services
Supabase: Database and backend infrastructure
MoonPay: Fiat-to-crypto on-ramp services (when you fund your wallet)
Polymarket: Prediction market data and trading
Kalshi: Prediction market data and trading
Expo: Push notification delivery
Analytics Providers: Usage analytics and crash reporting

4.2 Other Disclosures

Legal Requirements: When required by law, subpoena, court order, or government request
Safety and Rights: To protect the safety, rights, or property of Polly, our users, or others
Business Transfers: In connection with a merger, acquisition, bankruptcy, or sale of assets
With Your Consent: When you have given us explicit permission

We do not sell your personal information to third parties.

5. Third-Party Services

The Service integrates with third-party services that have their own privacy policies. We encourage you to review their policies:

Privy: Provides authentication and embedded wallets - privy.io/privacy
MoonPay: Provides fiat on-ramp services - moonpay.com/privacy_policy
Polymarket: Prediction market platform - polymarket.com/privacy
Kalshi: Prediction market exchange - kalshi.com/privacy
Supabase: Backend infrastructure - supabase.com/privacy

We are not responsible for the privacy practices of these third-party services. When you use features powered by these services, you are also subject to their respective privacy policies.

6. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

Encryption of data in transit (TLS/SSL) and at rest
Secure authentication through Privy
Access controls and authentication for our systems
Regular security assessments and monitoring
Secure storage using industry-standard cloud providers

However, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security.

7. Data Retention

We retain your information for as long as your account is active or as needed to provide the Service. We may also retain certain information as required by law or for legitimate business purposes, including:

Complying with legal obligations and regulatory requirements
Resolving disputes and enforcing our agreements
Preventing fraud and abuse
Maintaining security and integrity of our systems

Blockchain transaction data is permanent and cannot be deleted as it exists on public, decentralized networks outside our control.

8. Your Rights and Choices

Depending on your location, you may have the following rights:

Access: Request a copy of the personal information we hold about you
Correction: Request correction of inaccurate or incomplete information
Deletion: Request deletion of your personal information (subject to legal requirements)
Portability: Request your data in a portable format
Objection: Object to certain processing of your information
Restriction: Request restriction of processing in certain circumstances
Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, you can manage your account settings in the App or contact us using the information provided at the end of this policy.

9. Push Notifications

With your consent, we send push notifications for whale alerts, market updates, and other important information. You can manage notifications by:

Adjusting alert preferences within the App settings
Disabling notifications in your device settings
Unsubscribing from specific notification types in the App

Note that disabling notifications may affect your ability to receive timely alerts about market activity.

10. Children's Privacy

The Service is not intended for users under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn that we have collected information from a child under 18, we will take steps to delete such information promptly. If you believe a child has provided us with personal information, please contact us.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where data protection laws may differ. By using the Service, you consent to such transfers. We take appropriate safeguards to ensure your information remains protected in accordance with this Privacy Policy.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know: Request information about the categories and specific pieces of personal information we collect
Right to Delete: Request deletion of your personal information
Right to Opt-Out: Opt out of the sale of personal information (we do not sell personal information)
Non-Discrimination: We will not discriminate against you for exercising your rights

To exercise these rights, contact us using the information at the end of this policy.

13. European Privacy Rights (GDPR)

If you are in the European Economic Area (EEA), United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR), including access, rectification, erasure, restriction, portability, and objection rights. Our legal bases for processing include:

Contract: Processing necessary to provide the Service
Legitimate Interests: Improving and securing our Service, analytics
Consent: Push notifications, marketing communications
Legal Obligation: Compliance with applicable laws

14. Apple App Tracking Transparency

In accordance with Apple's App Tracking Transparency framework, we will request your permission before tracking your activity across other companies' apps and websites. You can change this permission at any time in your device settings under Privacy > Tracking.

15. Do Not Track Signals

Some browsers have a "Do Not Track" feature that signals to websites that you do not want your online activity tracked. We currently do not respond to Do Not Track signals, as there is no industry standard for how to respond to such signals.

16. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by:

Posting the updated policy in the App and on our website
Updating the "Last Updated" date at the top of this policy
Sending a push notification or email for significant changes

Your continued use of the Service after changes are posted constitutes acceptance of the updated Privacy Policy. We encourage you to review this policy periodically.

17. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, you can reach us through the App's support features or by visiting our website.