Privacy Policy

1. Information We Collect

We may collect the following categories of information.

Information you provide to us.
This may include your email address, username, display name, profile photo, biography, communications with us, and other information you choose to provide through the Services.

Authentication information.
If you sign in using a third-party authentication provider, we may receive certain information from that provider, such as your email address, name, profile image, or account identifier, depending on the permissions you grant.

Wallet and blockchain information.
We may collect or associate your Clue account with public wallet addresses and publicly available blockchain or trading information, including transactions, positions, balances, and trading history.

Usage and device information.
We may automatically collect information such as your IP address, device type, operating system, app version, log data, approximate location derived from your IP address, and information about how you interact with the Services.

Social activity.
If you use social features, we may collect information such as posts, comments, follows, likes, and other interactions within the Services.

We do not collect, access, or store your private keys, seed phrases, or wallet recovery credentials.

2. How We Use Your Information

We may use the information we collect to:

• provide, operate, and maintain the Services;
• create, manage, and authenticate your account;
• enable wallet and blockchain functionality;
• display publicly available trading and blockchain information;
• provide social and trader discovery features;
• personalize your experience;
• provide customer support;
• monitor and improve the performance and security of the Services;
• prevent fraud, abuse, or unauthorized activity; and
• comply with applicable legal and regulatory obligations.

3. How We Share Your Information

We may share information with third parties that help us operate the Services, including providers of:

• authentication and wallet infrastructure;
• cloud hosting and infrastructure;
• blockchain and trading infrastructure;
• communications;
• security and fraud prevention; and
• payment or fiat on-ramp services.

We may also disclose information:

• when you direct or consent to the disclosure;
• when necessary to provide a feature or transaction you request;
• to comply with applicable law or legal process;
• to protect Clue, our users, or others; or
• in connection with a merger, acquisition, financing, or sale of assets.

We do not sell your personal information.

4. Public Blockchain and Public Information

Certain blockchain and trading information displayed through Clue is obtained from publicly available blockchain networks and third-party protocols.

Such information may include wallet addresses, transactions, positions, trading activity, and related performance information.

Blockchain records may be public and immutable. Clue does not control public blockchain networks and cannot modify or delete information recorded on them.

Deleting your Clue account therefore does not remove information that remains publicly available on a blockchain or third-party protocol.

Information you choose to make public through Clue, such as your profile, posts, or social activity, may also be visible to other users.

5. Security

We take the security of your information, account, and digital assets seriously. We use reasonable technical, administrative, and organizational safeguards designed to protect the information we process against unauthorized access, loss, misuse, alteration, or disclosure.

Clue is designed to be non-custodial. Wallet key infrastructure is provided through Privy, which is designed to enable users to maintain control of their wallets and digital assets. Privy protects wallet keys using encrypted key sharding and hardware-backed trusted execution environments (TEEs). Key shares are stored across separate security boundaries, and signing operations are performed within isolated environments designed to prevent private keys from being exposed.

Clue does not take custody of your digital assets. However, no security system, method of electronic transmission, or method of storage is completely secure, and we cannot guarantee absolute security.

You are responsible for protecting your account credentials, authentication methods, wallet recovery information, and devices, and for preventing unauthorized access to your account. You should promptly notify us if you believe your account or device has been compromised.

6. Data Retention

We retain personal information for as long as reasonably necessary to provide the Services, comply with legal obligations, prevent fraud and abuse, resolve disputes, and enforce our agreements.

When information is no longer required, we may delete or anonymize it in accordance with applicable law.

Public blockchain information is not controlled by Clue and may remain publicly available indefinitely.

7. Your Privacy Rights

Depending on where you live, you may have rights regarding your personal information, including the right to:

• access your information;
• correct inaccurate information;
• request deletion;
• restrict or object to certain processing;
• request data portability; and
• withdraw consent where applicable.

You may exercise applicable rights by contacting us at the address below.

We may need to verify your identity before processing certain requests.

8. International Data Transfers

Clue Labs Pte. Ltd. is incorporated in Singapore, and our users and service providers may be located in different countries.

Your information may therefore be transferred to or processed in countries other than the country where you live.

Where required by applicable law, we take appropriate measures to protect personal information transferred internationally.

9. Children’s Privacy

The Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18.

If we learn that we have collected personal information from an individual under 18, we will take reasonable steps to delete it, subject to applicable law.

10. Changes to This Privacy Policy and Contact Us

We may update this Privacy Policy from time to time. When we do, we will update the effective date below and provide additional notice where required by applicable law.

If you have questions about this Privacy Policy or would like to exercise your privacy rights, please contact us at:

Effective Date: September 15, 2026