Privacy Policy

Last Updated: 19 October 2026

• Creation and management of non-custodial Agent Wallets;
• Automated execution, data of the trades, strategy rules, leverage, and risk parameters you configure and authorize, including perpetual futures referencing crypto assets and perpetual futures referencing equities, commodities, and indices;
• Strategy mirroring and copy trading of traders you select, and optional strategy templates, on protocols such as Hyperliquid, including perpetual futures;
• AI-generated data, analytics, automations, notifications, and developer-integrated skills (presented for your interpretation);
• Risk-management tools you may enable, such as stop-loss, dynamic/ratchet stops, and profit ladders.

OpenFinance does not take custody of funds, does not exercise independent investment discretion beyond the parameters you set, and does not provide financial, legal, investment, or tax advice or any trading suggestion or recommendation. AI features present data and analytics for you to interpret and act on at your own discretion.

Because OpenFinance operates over non-custodial wallets and public blockchain networks:

• Much of the information you provide or generate while using OpenFinance is stored on public blockchains and is not under our direct control.
• Information stored on the blockchain is public, immutable, and cannot be deleted or modified by us.

We are committed to protecting your privacy and handling any personal information we collect in a transparent, lawful, and secure manner, in compliance with applicable data protection laws and regulations.

01Data We Collect

When you interact with the Services, we collect:

• User-Provided Information: Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, social media, or otherwise.
• Publicly-available blockchain data: When you connect your non-custodial blockchain wallet to the Services, we collect and log your publicly available blockchain address and transaction history. Note that blockchain addresses are publicly available data that are not created or assigned by us or any central party and by themselves are not personally identifying.
• Transactional data, such as blockchain transaction history and other information associated with your linked cryptocurrency wallet. This also includes your trades executed using the platform and trade history.
• Device and Usage Information: Information from localStorage and other tracking technologies, including but not limited to browser type, device information, operating system, mobile deviceID, web beacons, cookies, usage patterns within our Services and other similar technologies.
• Marketing data: Your preferences for receiving our marketing communications and details about your engagement with them.
• Survey or usability information. If you participate in a survey or usability study with us, we will record any biographical information you directly provide to us (for example, your name, email, and job title), the responses you provide to us, and your interactions with the Services.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
• Third-party sources. We may combine the personal information you provide with information obtained from other sources. These sources include public records, government agencies, social media platforms, public blockchains and ledgers, data providers, information services, marketing partners, event co-sponsors, and service providers that assist in operating our Service or business. This combined information helps us enhance our services, improve user experience, and maintain accurate records.

02Data We Do Not Collect

As a non-custodial wallet provider, OpenFinance is committed to maintaining the highest standards of user privacy and security. In line with this commitment, there are several types of sensitive information that we deliberately do not collect, store, or have access to:

• Private Keys: We do not collect, store, or have access to the private keys associated with your wallet. Private keys are the cryptographic keys that give direct control over your digital assets on the blockchain. These remain solely in your possession and control.
• Recovery Phrases: Also known as seed phrases or mnemonic phrases, these are typically a series of 12 to 24 words that can be used to recover access to your wallet. We do not collect, store, or have any access to your recovery phrases.
• Biometric Data: If you use biometric authentication (such as fingerprint or face recognition) to access your wallet on your device, this data is processed locally on your device and is not collected or stored by OpenFinance.

It's important to understand that because we do not collect this information, we are unable to recover, reset, or provide access to your wallet if you lose your private keys, recovery phrases, or other access credentials. You are solely responsible for securely storing and managing this critical information.

03Tracking Technologies

Some of the automatic data collection described above is facilitated by the following technologies:

• Cookies are small text files that websites store on user devices and that allow web servers to record users' web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both "session cookies" that are deleted when a session ends, "persistent cookies" that remain longer, "first party" cookies that we place, and "third party" cookies that our third-party business partners and service providers place.
• Local storage technologies, like HTML5, which provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
• Google Analytics, we also use Google Analytics and similar services to collect information about your use of the Service. Google Analytics collects information such as how often users visit the Service, what pages they visit when they do so, and what other sites they used prior to coming to the Service. We use the information we get from Google Analytics to improve the Service. Google Analytics collects only the IP address assigned to you on the date you visit the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Service, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to the Service is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.

04How We Use Data

We use the data we collect in accordance with your instructions, including any applicable terms in our Terms of Service, and as required by law. We may also use data for the following purposes:

• Providing the Services: We use the data we collect to provide, maintain, customize, and improve our Services and features of our Services.
• Customer support: We may use information to provide customer support for and answer inquiries about the Services.
• Safety and security: We may use data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users and Company.
• Legal compliance: We may use the information we collect as needed or requested by regulators, government entities, and law enforcement to comply with applicable laws and regulations.
• Aggregated data: We may use some of the information we collect or access to compile aggregated data that helps us learn more about how users use the Services and where we can improve your experience.
• Direct marketing: We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of communications section below.
• To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:

• Technical operation: To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
• Functionality: To enhance the performance and functionality of our services.
• Analytics: To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails.

05How We Share Data

• With service providers: We may share your information with our service providers and vendors to assist us in providing, delivering, and improving the Services. For example, we may share your wallet address with service providers like Infura and Cloudflare to provide technical infrastructure services, your wallet address with blockchain analytics providers to detect, prevent, and mitigate financial crime and other illicit or harmful activities, and your activity on our social media pages with our analytics provider to learn more about how you interact with us and the Services.
• To comply with our legal obligations: We may share your data in the course of litigation, regulatory proceedings, compliance measures, and when compelled by subpoena, court order, or other legal procedure. We may also share data when we believe it is necessary to prevent harm to our users, our Company, or others, and to enforce our agreements and policies, including our Terms of Service.
• Safety and Security: We may share data to protect against, investigate, and stop fraudulent, unauthorized, or illegal activity. We may also use it to address security risks, solve potential security issues such as bugs, enforce our agreements, and protect our users, Company, and ecosystem.
• Business changes: We may transfer or share data to another entity in the event of a merger, acquisition, bankruptcy, dissolution, reorganization, asset or stock sale, or other business transaction.
• Affiliates: We may share your data with our corporate parent, subsidiaries, and affiliates to facilitate our services, enhance our offerings, and for administrative purposes. This may include but is not limited to, sharing for joint marketing activities, improved customer support, and operational efficiency.
• With your consent: We may share your information any other time you provide us with your consent to do so.
• Other users and the public: Your profile and other user-generated content data may be visible to other users of the Service. This information can be seen, collected, and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Other users may be able to view your profile information, certain transactional information related to your recent trades, and chats. Your profile, ETH price of your keys, follower count, and other profile information may also be available to all users of the Service.

06Your Rights and Choices Regarding Your Information

• Access or update your information: If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
• Opt-out of communications: You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
• Cookies: We use services provided by Google and other third parties that use tracking technology, such as cookies, deviceID, and localStorage, to collect information about your use of the Services and our interactions with you. You can opt out of having your online activity and device data collected through these third-party services, including by:
  • Blocking cookies in your browser by following the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see the cookies on your device, manage them, and delete them, visit www.allaboutcookies.org.
  • Blocking or limiting the use of your advertising ID on your mobile device through the device settings.
  • Using privacy plug-ins or browsers. Certain browsers and browser extensions can be configured to block third-party cookies and trackers.
  • Using the platform opt-out provided by Google at https://adssettings.google.com. You can learn more about how Google uses your information by reviewing Google's privacy policy at https://policies.google.com/privacy.
  • Using advertising industry opt-out tools on each device or browser where you use the Services, available at http://optout.aboutads.info and http://optout.networkadvertising.org.
• Blocking images/clear gifs: Most browsers and devices allow you to configure your device to prevent images from loading. To do this, follow the instructions in your particular browser or device settings.
• Do Not Track: Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

07Third-Party Links and Sites

We may integrate technologies operated or controlled by other parties into parts of the Services. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us. Please note that when you interact with these other parties, including when you leave the Site, those parties may independently collect information about you and solicit information from you. You can learn more about how those parties collect and use your data by consulting their privacy policies and other terms.

08Wallet Creation

OpenFinance utilizes Privy, a third-party service provider, to facilitate the creation of email, and embedded wallets. When you connect to OpenFinance using email, a non-custodial wallet is created for you. This wallet's private key and recovery phrase are accessible to you through the wallet settings.

It is important to note that OpenFinance does not have access to, nor can it access, your private key or recovery phrase at any time. The security and management of your wallet credentials are solely your responsibility.

09Security

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. You are responsible for all of your activity on the Services, including the security of your blockchain network addresses, cryptocurrency wallets, and their cryptographic keys.

You are solely responsible for the security of your wallet, including safeguarding your private keys and recovery phrases. We use third-party services like Privy to facilitate secure wallet creation, but the ultimate responsibility for wallet security lies with you.

10International Data Transfer

We are headquartered in the British Virgin Islands and may use service providers that operate in other countries. Your personal information may be transferred to the British Virgin Islands or other locations where privacy laws may not be as protective as those in your state, province, or country.

11Age Restriction

The Service is not intended for use by anyone under 18 years of age. If you are under 18, you may not use the Service. If we learn that we have collected personal information from someone under 18, we will promptly delete that information.

12Changes to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically for any changes.

13Contact Us

If you have any questions about this Policy or how we collect, use, or share your information, please contact us at dev@openfinance.tech.