Syndicate Privacy Policy

1. Who is responsible for your data

Cyclopes Inc., a Delaware corporation, is the data controller for personal data processed through the Services.

• Address: 2810 N Church St, STE 90770, Wilmington, DE 19802, US
• Privacy contact: contact@syndicate.trade
• Phone: +1 (302) 208-8824

We have not appointed a representative in the UK or EU. UK and EU residents can contact us directly at the address above.

2. Information we collect

2.1 Information you provide directly

We do not collect private keys, seed phrases, or wallet passwords. The app is designed so that we cannot see them. Never share them with anyone claiming to represent Syndicate.

2.2 Information collected automatically

2.3 Public blockchain data

Blockchain networks are public. When you connect a wallet, we read and index on-chain data associated with that address, including balances, transaction history, and token holdings. We also index on-chain wallets that have not connected to Syndicate in order to build public leaderboards and performance analytics (see Section 5).

On-chain data is not controlled by us, cannot be edited or deleted by us, and is visible to anyone with access to the blockchain. Please consider this before linking a wallet to a profile that identifies you.

2.4 Information from third parties

• Wallet providers and signing services: confirmation that a signature or delegation was authorised.
• Analytics and crash reporting providers: aggregated and event-level usage data (see Section 6).
• Identity verification providers: if and only if a feature requires it (for example, manager verification or fiat on-ramp), we may receive verification status and limited identity data from a KYC provider. We do not run identity checks on followers using core non-custodial features.
• Social platforms: if you link a Telegram, X, or other social account, we receive the public identifiers and profile data you authorise.

3. How we use information

We do not sell your personal data, and we do not use it for automated decision-making that produces legal or similarly significant effects on you.

4. Copy-trading and delegation specifics

Syndicate routes trading authority between users, so some data is shared between them:

• Managers can see aggregate information about capital delegated to their strategy and the trades executed under it. Managers cannot see followers' private keys, full wallet contents, or personal details beyond what a follower chooses to make public.
• Followers can see a manager's public profile, on-chain track record, and the trades executed on their behalf.
• Delegation scope is enforced on-chain. Revoking a delegation stops future trades; it does not reverse trades already executed.

Trade and delegation events are recorded on-chain and in our systems. We retain these records to display history, compute metrics, resolve disputes, and meet legal obligations.

5. Public leaderboards and profiles

Syndicate publishes leaderboards ranking wallet addresses by on-chain performance. These are built from public blockchain data and may include addresses that have never used Syndicate.

• Ranked entries show the wallet address (or a linked username, if the owner has claimed the address on Syndicate), performance statistics, and derived metrics.
• If you claim an address, your chosen display name is publicly associated with that address and its full on-chain history.
• You can ask us to hide a claimed profile or delist an address you control by contacting contact@syndicate.trade. We will honour reasonable requests, but the underlying on-chain data remains public regardless.

6. Who we share information with

Service providers that process data on our behalf under contract, including cloud hosting and infrastructure, blockchain node and RPC providers, product analytics (PostHog Cloud, posthog.com/privacy), crash and performance monitoring, push notifications (Apple Push Notification service, Firebase Cloud Messaging), customer support tooling, identity verification (feature-specific only), and email delivery.

Other users, to the extent described in Sections 4 and 5.

Wallet and signing providers you choose to connect, which operate under their own privacy policies.

Legal and safety: courts, regulators, law enforcement, or others when required by law, to enforce our Terms, or to protect the rights, safety, or property of users, the public, or Cyclopes.

Corporate transactions: a buyer or successor in a merger, acquisition, financing, or asset sale, subject to this policy.

With your consent, for any other purpose you authorise.

7. International transfers

Cyclopes is headquartered in the United States, and our service providers operate globally. If you are in the UK, EEA, or Switzerland, your data may be transferred to countries that do not provide the same level of protection. Where we do so, we rely on the UK International Data Transfer Agreement, EU Standard Contractual Clauses, or another lawful mechanism, and apply supplementary safeguards where appropriate. You can request a copy of the relevant safeguards by contacting us.

8. Data retention

We may keep data longer where required by law or to resolve disputes.

9. Your rights

Depending on where you live, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate data
• Delete your data (subject to legal retention requirements and the on-chain limitations described above)
• Restrict or object to certain processing, including profiling based on legitimate interests
• Port your data to another service in a machine-readable format
• Withdraw consent at any time, where consent is the legal basis
• Opt out of marketing communications via the unsubscribe link or app settings
• Lodge a complaint with a supervisory authority: in the UK, the Information Commissioner's Office (ico.org.uk); in the EU, your local data protection authority

To exercise any right, email contact@syndicate.trade. We may ask you to verify control of a wallet address or account before acting. We respond within one month, extendable by two months for complex requests.

California residents: you have the right to know, delete, correct, and opt out of sale or sharing of personal information. We do not sell personal information. We do not discriminate against you for exercising your rights.

10. Security

We use encryption in transit and at rest, access controls, logging, and regular security review to protect data we hold. However, no system is perfectly secure, and we cannot protect your wallet itself. You are responsible for safeguarding your keys, devices, and any delegation you grant. If you believe your account or wallet has been compromised, revoke active delegations immediately and contact us.

11. Children

The Services are not directed to anyone under 18, and we do not knowingly collect data from minors. If you believe a minor has provided data to us, contact us and we will delete it.

12. Third-party links and services

The Services link to trading terminals, wallets, block explorers, and social platforms we do not control. Their privacy practices are governed by their own policies.

13. Changes to this policy

We may update this policy from time to time. Material changes will be announced in the app or by email before they take effect. The “Last updated” date at the top shows the current version. Continued use after changes take effect means you accept the updated policy.

14. Contact