Privacy Policy

Effective date: 5 September 2026 · Last updated: 5 September 2026

1. Summary

• You sign in with an email address, a Google account or an Apple account through our authentication provider, Privy. We never see your password, and we do not receive your Google or Apple credentials.
• A self-custodial wallet is created for you at sign-in. Its addresses, and every deposit, trade, settlement and withdrawal you make, are recorded on public blockchains (Polygon and the chains you deposit from). That data is public by nature and cannot be deleted by us or anyone else.
• We collect usage data about how you use the app (which markets you view, how long, what you swipe or tap) to run the feed, size markets sensibly and improve the product. We do not sell personal data.
• We use your IP address to check where you are, because the Service is not available in some countries. We do not track your precise location.
• We do not run third-party advertising trackers in the app.

2. Data we collect

2.1 Account and identity

• Login identifier. Your email address, or the email address and basic profile (name, avatar) returned by Google or Apple when you sign in with them. Apple may give us a relay address instead of your real one.
• Privy identifier. A unique user ID assigned by Privy. This ID, not your email, is how your account is keyed inside the Service.
• Wallet addresses. The embedded wallet address created for you, the smart-contract wallet address used to hold funds and trade, and the deposit addresses assigned to you on each supported deposit chain.
• Settings. Language, default stake, market spread and slippage preferences, category interests, notification preferences, whether automatic redemption is enabled, and referral codes you create or use.

2.2 Financial and trading data

• Deposits and withdrawals. Amounts, tokens, source and destination addresses, chains, transaction hashes and timestamps, including the address you sent funds from on another chain.
• Orders and positions. Every order you submit (market, side, stake, price limits, time), whether and how it filled, fees charged, positions held, settlements and realised profit or loss.
• Balances. Your cash balance, redeemable winnings and funds in transit between settlement and your balance.

2.3 Usage and device data

• Interaction events. Which cards you see, how long you look at them, whether you swipe, tap, open a trade sheet or complete a trade, and search terms you enter. These drive the feed ranking and product analytics.
• Technical data. IP address, approximate country derived from it, browser and operating system, device type, screen size, app version, language, time zone, referring page and crash or error reports.
• Server logs. Requests to our servers, including IP address, user agent, timestamps and response codes, kept for security, abuse prevention and debugging.

2.4 Communications

• Messages you send us by email or through support channels, and our replies.
• Delivery records for one-time login codes and transactional notifications we send you.

2.5 Data we do not collect

• We do not collect government ID documents or run identity verification ourselves. Third parties involved in deposits or withdrawals may apply their own checks under their own policies.
• We do not collect card numbers or bank details. Deposits and withdrawals are on-chain only.
• We do not collect precise GPS location.

3. How we use data

We do not use your personal data for automated decisions that have legal or similarly significant effects on you, other than the eligibility checks described in section 8.

4. Legal bases (where they apply)

Where data-protection law requires a legal basis, we rely on: performance of a contract (providing the Service you asked for); legitimate interests (securing the Service, preventing abuse, improving the product, understanding usage), balanced against your rights; legal obligation (record keeping, responding to lawful requests, sanctions and territorial compliance); and consent, where we ask for it (for example optional product emails), which you can withdraw at any time.

5. Blockchain data is public

The Service is built on public blockchains. Your wallet addresses and every transaction associated with them (deposits, trades, settlements, redemptions, withdrawals) are written to public, permanent ledgers that anyone can read and that we do not control. Anyone who links an address to you can see that history. We cannot edit or delete on-chain records, and rights such as erasure do not extend to them. Please consider this before sending funds to the Service from an address that is publicly associated with your identity.

6. Who we share data with

We share personal data only as described here. We do not sell it and we do not share it with data brokers or advertisers.

• Privy (authentication and embedded wallets): your login identifier, Privy ID, wallet keys held under Privy's custody architecture, and session data. Privy's own privacy policy applies to its processing.
• Polymarket and its exchange infrastructure: orders, wallet addresses and trade data needed to place and settle trades on the markets you choose. Candl operates as a builder on Polymarket rails; Polymarket's terms and privacy policy apply to that processing.
• Deposit and withdrawal infrastructure providers (bridging and stablecoin conversion): deposit addresses, amounts, tokens and transaction data needed to move your funds. These providers may apply their own compliance checks.
• Blockchain networks and node providers: transaction data broadcast to Polygon and other supported chains, which is public.
• Infrastructure and tooling: cloud hosting, databases, error monitoring, email delivery and similar providers that process data on our behalf under contract.
• Price and market data providers: no personal data, but we note them for completeness.
• Legal and safety: regulators, law enforcement or other parties where required by law, to enforce our Terms, or to protect the rights, property or safety of Candl, our users or others.
• Corporate transactions: a buyer or successor in a merger, acquisition or reorganisation, under this policy.

7. Cookies and device storage

The app uses browser storage (local storage, session storage, IndexedDB) and a small number of cookies to keep you signed in, remember your language and trading preferences, remember which market you were looking at, and cache market data so the app opens fast. Privy sets storage needed to maintain your session and wallet. We do not use third-party advertising or cross-site tracking cookies. Clearing site data signs you out and resets local preferences; it does not affect your account, wallet or on-chain funds.

8. Location and eligibility checks

The Service is not offered in certain territories. When you connect, we derive an approximate country from your IP address and apply our territorial restrictions automatically. If you appear to be in a restricted territory, parts or all of the Service are unavailable. We may also decline or restrict access where we detect attempts to evade these checks (for example through VPNs or proxies). We do not collect precise location. The list of restricted territories is maintained by us and may change.

9. How long we keep data

• Account, wallet and trading records: for as long as your account exists and afterwards for as long as needed for legal, accounting, dispute-resolution and fraud-prevention purposes, typically up to [7] years.
• Interaction events and analytics: in identifiable form for up to [24] months, then aggregated or deleted.
• Server logs: typically 30 to 90 days, longer if needed to investigate an incident.
• Support correspondence: up to [3] years after the matter closes.
• On-chain data: permanent and outside our control (section 5).

10. Security

We protect data with encryption in transit, access controls, server-side handling of all venue, wallet-provider and infrastructure credentials, rate limiting and monitoring. Wallet keys are managed by Privy's embedded-wallet architecture; Candl does not hold your private key in plain form. Signing money-out transactions always requires your explicit confirmation. No system is perfectly secure, and you are responsible for keeping your email, Google or Apple account and your devices secure, since anyone who controls them can sign in as you.

11. International transfers

We and our providers process data in [jurisdictions where Candl and its providers operate, e.g. the European Union, the United States and Singapore]. Where data leaves the jurisdiction it was collected in, we rely on lawful transfer mechanisms such as standard contractual clauses or adequacy decisions where those apply.

12. Your rights

Depending on where you live, you may have the right to access the personal data we hold about you, correct it, delete it, restrict or object to its processing, receive a portable copy, and withdraw consent. You can exercise these rights by emailing admin@candl.trade from the address on your account. We will respond within the time required by applicable law and may need to verify your identity first. We cannot delete on-chain data (section 5) and may retain records we are legally required to keep. If you are in the EEA, the UK or Switzerland, you can also complain to your local data-protection authority. If you are a California resident, you have the rights described above under the CCPA; we do not sell or share personal data for cross-context behavioural advertising.

You can also change language, notification and trading preferences in the app under Profile, and disable automatic redemption there, which revokes the signing permission you granted for it.

13. Age limits

The Service is for adults only. You must be at least 18 years old (or the age of majority where you live, if higher) to use it. We do not knowingly collect data from anyone under that age; if we learn we have, we will close the account and delete the data we are able to delete.

14. Changes to this policy

We may update this policy as the Service or the law changes. We will post the new version here with a new effective date and, for material changes, tell you in the app or by email before they take effect. Continued use after that date means the updated policy applies.

15. Contact

[Candl legal entity name]
[registered address]
admin@candl.trade

See also our Terms of Use.