Netty respects your privacy. This Privacy Policy explains what information we collect, how we use it, and your rights.

Introduction

This Privacy Policy ("Policy") explains how [Netty Labs Inc.] ("Company," "we," "us," or "our") collects, uses, maintains, and discloses information through Netty.xyz (the "Site") and our professional prediction market platform (the "Platform").

This Policy applies to all information we collect through the Site, Platform, and associated services (collectively, the "Services").

Please read this Policy carefully. By accessing or using our Services, you agree to this Policy. If you do not agree, please do not use our Services.

Information Collection and Use

Information We Collect

Wallet Information

• Public wallet addresses when you connect your self-hosted wallet

• Transaction history and on-chain activity

• Public blockchain data associated with your wallet

Account Information (if you create an account)

• Email address

• Username

• Profile preferences

• Trading preferences and settings

Technical Information

• IP address and geolocation data

• Browser type and version

• Device information

• Access times and usage patterns

• Pages viewed and features accessed

Trading Activity

• Order history and trade execution data

• Position data and portfolio composition

• Margin and collateral levels

• Liquidation events

• P&L and account performance metrics

Financial Information

• We do not directly collect or store banking or credit card information

• Payment processing is handled by third-party providers

• Wallet balances and cryptoasset holdings are read from blockchain data

Communications

• Support tickets and correspondence

• Feedback and survey responses

• Community forum participation (if applicable)

How We Collect Information

We collect information:

• Directly from you when you provide it

• Automatically through your use of the Services

• From blockchain networks (public transaction data)

• From third-party services like wallet providers and oracle feeds

Use of Your Information

We use collected information to:

Platform Operations

• Provide and maintain the Platform

• Process and execute your trading instructions

• Calculate margin requirements and liquidation triggers

• Monitor risk management systems

• Ensure FIFO matching integrity

• Facilitate oracle-based settlement

Security and Compliance

• Detect and prevent fraud, manipulation, or abusive trading

• Verify your identity and prevent unauthorized access

• Comply with legal obligations and regulatory requirements

• Enforce our Terms of Use

• Respond to legal process and government requests

Analytics and Improvement

• Analyze platform performance and user experience

• Monitor system health and latency metrics

• Improve trading features and risk management systems

• Develop new markets and functionality

• Generate anonymized market statistics

Communications

• Send account-related notifications

• Provide customer support

• Notify you of platform updates or security issues

• Deliver marketing communications (with your consent)

Cookies and Tracking Technologies

We use cookies, web beacons, and similar technologies to:

• Recognize you when you return to the Site

• Remember your preferences and settings

• Analyze usage patterns and performance

• Measure effectiveness of features

• Enhance security and prevent fraud

You can control cookies through your browser settings. However, disabling cookies may limit functionality of the Services.

Do Not Track: We do not currently respond to Do Not Track signals.

How We Share Information

Public Blockchain Data

Your wallet address and on-chain transactions are public by nature of blockchain technology. Anyone can view:

• Your public wallet address

• Transaction history involving your wallet

• Positions and trades recorded on-chain

• Settlement outcomes

Third-Party Service Providers

We share information with service providers who assist us in operating the Platform:

• Hosting and infrastructure providers

• Analytics services

• Customer support tools

• Security and fraud prevention services

• Oracle providers for market settlement

• Data availability layer providers

Legal and Regulatory Compliance

We may disclose information:

• To comply with legal obligations, court orders, or government requests

• To enforce our Terms of Use

• To protect our rights, property, or safety

• To prevent fraud or illegal activity

• To investigate Terms violations

• In connection with legal proceedings

Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

Aggregate and Anonymized Data

We may share aggregate, anonymized data that does not identify you personally for:

• Market statistics and analytics

• Research and development

• Marketing and business development

• Public reporting on platform metrics

With Your Consent

We may share information with your explicit consent or at your direction.

Data Security

We implement reasonable technical and administrative safeguards to protect your information, including:

• Encryption of sensitive data

• Secure socket layer (SSL) technology

• Access controls and authentication

• Regular security audits

• Employee training on data protection

However, no method of transmission or storage is 100% secure. We cannot guarantee absolute security, and you acknowledge that you provide information at your own risk.

You are responsible for:

• Securing your wallet and private keys

• Maintaining confidentiality of account credentials

• Using secure connections when accessing the Platform

• Monitoring your account for unauthorized activity

Data Retention

We retain your information for as long as necessary to:

• Provide the Services

• Comply with legal obligations

• Resolve disputes

• Enforce our agreements

Trading and transaction data may be retained for extended periods for regulatory compliance and historical analysis.

When information is no longer needed, we will delete or anonymize it in accordance with our data retention policies.

International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws.

By using the Services, you consent to the transfer of your information to other jurisdictions, including jurisdictions that may not provide the same level of data protection as your home country.

We will take reasonable steps to ensure your data is treated securely and in accordance with this Policy.

Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

Access: Request access to 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 and operational constraints)

Objection: Object to processing of your information

Restriction: Request restriction of processing

Portability: Request a copy of your information in a portable format

Withdraw Consent: Withdraw consent for processing (where we rely on consent)

To exercise these rights, contact us at privacy@netty.xyz using the email address associated with your account.

We may need to verify your identity before responding to requests. Some requests may not be honored if doing so would compromise security, violate legal obligations, or harm others' rights.

Marketing Communications

You may opt out of marketing emails by:

• Clicking the "unsubscribe" link in marketing emails

• Adjusting your account settings

• Contacting hello@nettyx.org

You cannot opt out of transactional or administrative communications related to your account, security, or the Platform.

Children's Privacy

The Services are not intended for individuals under 18 years of age. We do not knowingly collect information from children. If we learn we have collected information from a child under 18, we will delete it promptly.

Third-Party Links and Services

The Platform may contain links to third-party websites or integrate with third-party services. This Policy does not apply to third-party services, and we are not responsible for their privacy practices.

We encourage you to review the privacy policies of any third-party services you use.

Changes to This Policy

We may update this Policy from time to time. We will post the updated Policy on the Site with a new "Last Updated" date. Your continued use of the Services after changes constitutes acceptance of the updated Policy.

For material changes, we may provide additional notice such as email notification.

Contact Us

For questions about this Privacy Policy or our privacy practices, contact us at:

Email: hello@nettyx.org

For data subject rights requests, use the same email address with "Privacy Rights Request" in the subject line.

Jurisdiction-Specific Provisions

European Economic Area (EEA) and UK

If you are located in the EEA or UK, you have additional rights under GDPR, including the right to lodge a complaint with your local supervisory authority.

Our lawful basis for processing includes:

• Performance of contract

• Legitimate interests (platform operation, security, improvement)

• Legal compliance

• Your consent (where applicable)

California

If you are a California resident, you have rights under the California Consumer Privacy Act (CCPA), including the right to know what information we collect and the right to request deletion.

Other Jurisdictions

Users in other jurisdictions may have rights under applicable local privacy laws. Contact us to exercise any applicable rights.

For privacy questions or requests, email us at hello@nettyx.org.