Tradevo Privacy Policy
DRAFT v0.1 — In-house draft. Not legally reviewed. Counsel must review and revise before launch.
Last updated: [DATE] Effective: [DATE]
1. Overview
This Privacy Policy describes how Tradevo, LLC ("Tradevo," "we," "us") collects, uses, shares, and protects information about you ("you," "User") in connection with the Tradevo platform.
We've designed Tradevo to collect as little personal information as possible. We never have access to your wallet's master private keys, and we cannot move your funds without permissions you explicitly grant.
By using Tradevo, you agree to the practices described in this Privacy Policy.
2. What We Collect
2.1 Information you provide directly
- Account information: email address, optional display name
- Authentication credentials: passkey identifiers (we never see your biometric data; only a public key)
- Payment information: wallet addresses you designate for USDC payouts (if you are a Partner Algo author)
- Support communications: messages you send to Tradevo support
2.2 Information collected automatically
- Wallet addresses you connect to Tradevo or that Tradevo creates for you (via Coinbase Smart Wallet)
- On-chain transaction data related to your wallet's interactions with Tradevo (public information)
- Algo allocations and configurations you set
- Session Key authorizations you grant
- Device and usage information: IP address, browser type, operating system, pages viewed, timestamps, referrer URLs
- Cookies and similar technologies (see §7)
2.3 Information we do NOT collect
- Wallet master private keys — Tradevo never holds these. They live in your device (passkey) or your self-custodial wallet (Phantom, Solflare).
- Biometric data — Passkey authentication is handled by your device's secure enclave. Tradevo only ever sees a public key.
- Government-issued IDs — Tradevo does not perform KYC on users. (Partner Algo authors are subject to a separate KYC process described in the Author Terms of Service.)
- Bank account numbers or credit card numbers — Fiat-to-crypto onramps are handled by Coinbase Onramp or MoonPay; those providers collect this information directly under their own privacy policies.
3. How We Use Information
We use the information we collect to:
- Provide and operate the Tradevo platform
- Execute algorithmic strategies within the permissions you grant
- Process Partner Algo subscription payments and author payouts
- Respond to support inquiries
- Detect and prevent fraud, abuse, and security incidents
- Comply with legal obligations
- Improve the platform (in aggregated, anonymized form)
- Send transactional and (optionally) marketing email communications
We do not:
- Sell your personal information
- Share your information with data brokers
- Use your information to target advertising on third-party platforms
4. How We Share Information
We share information only with the following parties:
4.1 Service providers
We share limited information with third-party service providers that help us operate Tradevo:
| Provider | Purpose | Information shared | |---|---|---| | Coinbase (Coinbase Smart Wallet, Onramp, Paymaster) | Wallet creation, fiat onramp, gas sponsorship | Wallet address, transaction parameters | | Privy | Embedded wallet fallback | Email, wallet address | | Clerk | Email authentication | Email, passkey identifiers | | Helius | Solana RPC and webhooks | Public wallet addresses (no personal data) | | Alchemy | Base RPC and webhooks | Public wallet addresses (no personal data) | | Sentry | Error monitoring | Anonymized error context, no PII | | Vercel | Frontend hosting | IP addresses, request logs | | Railway | Backend hosting and database | Application data |
Each provider is contractually required to protect your information and use it only for the services they provide to Tradevo.
4.2 Public blockchain information
Cryptocurrency transactions are inherently public. When Tradevo executes a swap on your behalf, that transaction appears on the Base or Solana blockchain and is permanently visible to anyone. We have no ability to make on-chain activity private.
4.3 Legal compliance
We may disclose information when we believe in good faith that disclosure is required by:
- A subpoena, court order, or other legal process
- A regulatory request from a government authority
- A need to protect Tradevo, our Users, or the public from harm
- A merger, acquisition, or sale of Tradevo's assets (in which case we will notify affected Users)
5. Data Security
We implement industry-standard security measures, including:
- Encryption in transit (HTTPS/TLS) for all communications between your device and Tradevo
- Encryption at rest for sensitive data in our databases
- Access controls limiting which Tradevo personnel can access which data
- Logging and monitoring to detect unauthorized access
- Regular security reviews and dependency updates
No system is perfectly secure. While we take precautions, we cannot guarantee absolute security. You are responsible for keeping your device, authentication credentials, and any wallet seed phrases you may have (for wallet-connect accounts) secure.
6. Data Retention
We retain personal information for as long as your account is active or as needed to provide the platform. After account closure:
- Account email and credentials: deleted within 30 days
- Transaction history: retained for 7 years for legal and tax compliance
- Support communications: retained for 3 years
- Aggregated and anonymized data: retained indefinitely
You may request earlier deletion of your personal information (see §8).
7. Cookies and Similar Technologies
Tradevo uses cookies and similar technologies for:
- Essential functionality (session management, authentication) — required, cannot be disabled
- Analytics (page views, feature usage) — anonymized; you may opt out
- Preferences (UI settings, theme) — set only with your consent
We do not use third-party advertising cookies.
8. Your Rights
Depending on your jurisdiction, you may have the following rights:
- Access: Request a copy of the information we hold about you
- Correction: Correct inaccurate information
- Deletion: Request deletion of your information (subject to legal retention requirements)
- Portability: Receive your information in a portable format
- Objection: Object to certain processing of your information
- Opt-out of marketing communications (transactional communications cannot be opted out)
To exercise these rights, contact us at [privacy@tradevo.co]. We will respond within the time period required by applicable law.
8.1 California Residents (CCPA / CPRA)
California residents have additional rights under the California Consumer Privacy Act and California Privacy Rights Act. We do not sell or share personal information for cross-context behavioral advertising. To exercise your California rights, contact [privacy@tradevo.co].
8.2 European Residents (GDPR)
If you are located in the European Economic Area, the United Kingdom, or Switzerland, the General Data Protection Regulation applies to our processing of your data. The legal bases for our processing are:
- Performance of our contract with you (to provide Tradevo services)
- Compliance with legal obligations
- Our legitimate interests (security, fraud prevention, platform improvement)
- Your consent (where required for marketing or non-essential cookies)
You have the right to lodge a complaint with your local data protection authority.
9. Children's Privacy
Tradevo is not directed to and may not be used by persons under 18. We do not knowingly collect information from minors. If you believe we have inadvertently collected information from a minor, contact us at [privacy@tradevo.co] for prompt deletion.
10. International Transfers
Tradevo operates from the United States. If you access Tradevo from outside the United States, your information may be transferred to, stored, and processed in the United States and other jurisdictions. By using Tradevo, you consent to such transfers, which may include transfers to jurisdictions with different data-protection laws than your own.
11. Changes to This Policy
We may update this Privacy Policy from time to time. Material changes will be communicated by email and posted on the Tradevo website with a revised "Last updated" date.
12. Contact
Privacy questions, data subject requests, and complaints:
Tradevo, LLC [Address] Email: [privacy@tradevo.co]
END OF PRIVACY POLICY
Drafting notes (remove before publishing)
- Placeholders:
[DATE],[Address],[privacy@tradevo.co] - Coordinate with ToS — ensure consistent terminology
- Reviewer should confirm CCPA/CPRA and GDPR sections are complete for your specific data processing
- If you add fiat payments directly (not through Coinbase/MoonPay), expand §2 to cover payment information
- If you add KYC for users (currently only for authors), expand §2 and §4 accordingly