Privacy Policy

1. Scope

This Policy applies to information we process when you visit our websites, install or use our software, or otherwise interact with the Services or with us. It does not apply to third-party tools, networks, wallets, or services that you may use alongside the Services, which are governed by their own policies. It also does not change the inherently public nature of information recorded on a public blockchain.

2. Information We Collect

We collect information in order to operate, secure, and improve the Services. The categories below are described in general terms; the specific data we collect may vary depending on how you interact with the Services, and we may collect additional information reasonably necessary for the purposes described in this Policy.

2.1 Information you provide

This may include, for example, a digital-asset wallet address; contact details such as an email address; information you submit when registering, configuring an account, or participating as a brand (which may include business, billing, and campaign information); content, requests, or materials you submit; and information you provide when you contact us for support or other communications.

2.2 Information collected automatically

When you use the Services, we may automatically collect technical and usage information, such as device, browser, and connection information; Internet Protocol (IP) address and information derived from it, including approximate (for example, country-level) location; identifiers; the software or client you use to access the Services and its version; activity, event, and log data relating to your use of the Services; and similar technical information. On our websites we and our providers may use cookies and similar technologies for functionality, measurement, and analytics, as described in Section 7.

2.3 Blockchain information

Transactions and related data recorded on a public blockchain — which may include wallet addresses, amounts, and timestamps — are public, immutable, and maintained by decentralized networks outside our control. We may read, reference, and process such public on-chain information in connection with the Services.

2.4 Information from third parties

We may receive information from service providers, analytics and infrastructure partners, and publicly available sources, and combine it with other information we hold, for the purposes described in this Policy.

We do not seek, and do not need, access to the contents of your code, prompts, files, or API keys to operate the Services, and we do not collect them for that purpose.

3. How We Use Information

We use information for purposes that include:

• providing, operating, maintaining, and improving the Services and developing new features;
• calculating, validating, processing, and settling amounts, and maintaining records of activity associated with the Services;
• measuring and analyzing usage and performance, including producing aggregated and de-identified statistics and reports;
• protecting the integrity and security of the Services, and detecting, investigating, preventing, and addressing fraud, abuse, security incidents, and violations of our Terms or applicable law;
• communicating with you, responding to inquiries, and providing support and service-related notices;
• complying with legal obligations, enforcing our agreements, and establishing, exercising, or defending legal claims;
• and other legitimate business purposes consistent with this Policy and applicable law.

3.1 Legal bases for processing

Where data-protection law (such as the EU/UK GDPR) requires a legal basis, we rely on the following:

• Contract. To operate your account and the Services you request — including using a wallet address to calculate and settle amounts owed to you.
• Legitimate interests. To secure the Services and detect, investigate, and prevent fraud, abuse, and security incidents — including processing IP address and device information for that purpose, which fraud prevention expressly supports — balanced against your interests and rights.
• Legal obligation. To keep records and comply with applicable law, including tax, accounting, and dispute-resolution requirements.
• Consent. Where we ask for it (for example, where required for certain non-essential technologies); you may withdraw it at any time.

4. How We Share Information

We may share information as follows:

• Service providers. With vendors and partners who process information on our behalf — such as hosting, infrastructure, payment and settlement, analytics, communications, and security providers — under obligations consistent with this Policy.
• Brands and partners.We may provide brands and partners with aggregated, de-identified, or statistical reporting about the performance of the Services. We do not disclose an individual’s wallet address or IP address to brands for this purpose.
• Blockchain networks. Information necessary to effect on-chain transactions is, by design, published to public networks and is visible to anyone.
• Legal, safety, and compliance. When we believe disclosure is reasonably necessary to comply with law, regulation, legal process, or a governmental request; to enforce our Terms; to detect or address fraud, security, or technical issues; or to protect the rights, property, or safety of Sponsored Code, our users, or others.
• Business transfers. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction.
• With your direction or consent. When you ask us to share information or otherwise consent.

We do not sell your personal information for money, and we do not share it for cross-context behavioral advertising in the manner contemplated by certain privacy laws. We may share aggregated or de-identified information, which is not subject to this Policy, for any lawful purpose.

5. Data Retention

We retain information for as long as reasonably necessary to fulfill the purposes described in this Policy, including to operate the Services, maintain accurate records of activity and settlement, comply with our legal obligations, resolve disputes, and enforce our agreements, after which we delete or de-identify it, unless a longer retention period is required or permitted by law. In particular, IP addresses associated with activity records are retained only for a limited period needed for fraud prevention and security, after which they are removed from those records while non-identifying activity information may be kept. Information recorded on a public blockchain is permanent and cannot be altered or deleted by us.

6. Security

We maintain technical and organizational measures designed to protect information against unauthorized access, loss, misuse, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for safeguarding your devices, credentials, wallets, and private keys, which we do not hold and cannot recover.

7. Cookies and Similar Technologies

Our websites may use cookies, local storage, and similar technologies to enable functionality, remember preferences, and measure and analyze usage. You can usually control cookies through your browser settings; disabling certain cookies may affect functionality. Where required by law, we obtain consent for non-essential cookies.

8. Your Choices and Rights

Depending on where you live, you may have rights regarding your personal information, such as the right to request access to, correction of, or deletion of certain information, to request information about our processing, and to opt out of certain processing. Because the Services rely on wallet addresses and on data published to public blockchains, some information cannot be changed or deleted, and exercising certain rights may limit or prevent your use of the Services. You can delete your account yourself at any time from your dashboard profile (under “Danger Zone”): for a brand account this removes your account and your sole-member team and ends your sessions; for an earner account it erases your identity and connected accounts, while earnings already recorded on the public blockchain remain claimable. To request a copy of the personal data we hold about you, email us at support@sponsoredcode.com, and we will provide it as required by applicable law. For any other privacy request, contact us at legal@sponsoredcode.com. When we delete an account, we remove identifying information and retain activity records only in de-identified form where needed for settlement and our legal obligations. We will respond as required by applicable law and may need to verify your request. We will not discriminate against you for exercising your rights.

8.1 U.S. state privacy rights (including California)

Residents of California and certain other U.S. states may have additional rights under applicable state privacy laws, including the rights to know or access the categories and specific pieces of personal information we have collected, the sources, the purposes, and the categories of recipients; to request deletion or correction; and to opt out of any “sale” or “sharing” of personal information and certain profiling. As noted above, we do not sell personal information for money or share it for cross-context behavioral advertising. You may exercise these rights, including through an authorized agent where permitted, by contacting us at legal@sponsoredcode.com.

9. International Users

We operate in the United States, and information we process may be transferred to, stored in, and processed in the United States or other countries that may have data-protection laws different from those of your jurisdiction. By using the Services, you understand that your information may be processed in these locations.

10. Children’s Privacy

The Services are not directed to, and are not intended for, individuals under 18 years of age, and we do not knowingly collect personal information from them. If we learn that we have collected such information, we will take reasonable steps to delete it.

11. Third-Party Links and Services

The Services may reference or link to third-party tools, networks, websites, or services that we do not operate. We are not responsible for their privacy practices, and we encourage you to review their policies.

12. Changes to this Policy

We may update this Policy from time to time. When we do, we will revise the “Last updated” date above and, for material changes, take reasonable steps to provide notice. Your continued use of the Services after the updated Policy takes effect constitutes acknowledgment of the changes.

13. Contact Us

If you have questions or requests regarding this Policy or our privacy practices, contact us at legal@sponsoredcode.com, or by mail at Sponsored Code, LLC, 800 Sixth Avenue, 5K, New York, NY 10001, United States.