Privacy notice

Who this covers

• Visitors and users who connect a wallet, sign in, mint or trade seats, or use coaching.
• Wallet owners whose public Solana wallets are profiled as brains — including wallets a third party has publicly attributed to a person.

Data about wallet owners (Art. 14 notice)

Wallet addresses can be personal data where they can reasonably be linked to a person. For profiled wallets we process:

• public on-chain transactions of the wallet (swaps, transfers, timestamps, amounts) and derived trading statistics;
• for unclaimed brains, any attribution already published by a third party (name/handle, the publishing platform and its link). Where a public KOL directory the person submitted themselves to (e.g. Kolscan, KOL Explorer, GMGN) lists the wallet, the public name, handle, profile picture and that directory's own published figures are shown with the source named; other attributions are shown only as labelled attributions;
• for claimed brains that linked X: public posts retrieved through the official X API, to compare posts with trades.

Source: the public Solana blockchain, token-data providers (Jupiter, DexScreener), and publicly available attribution pages. Purpose: educational analysis of trading styles. Lawful basis: legitimate interests (Art. 6(1)(f)) in providing transparent, rule-based analysis of public market activity, balanced by: public names and pictures only where the person self-listed on a public KOL directory (always with the source and an "unaffiliated, not endorsed" notice), neutral codenames otherwise, no de-anonymisation or clustering of other wallets, no tweet correlation without the owner's opt-in, deterministic labels with the numbers shown, and an objection channel.

Profiling: archetypes, flags and scores are automated profiling (Art. 4(4)). They produce no legal or similarly significant effects on the wallet owner; their logic is published in the methodology.

Data about users

• wallet address and sign-in records (session cookie, httpOnly, used only to keep you signed in);
• seats, listings and payments you make on-chain;
• coaching messages you send and the replies, stored so you can see your history;
• basic request logs and country (from your IP at the network edge) to enforce geo-restrictions.

We do not use advertising trackers and do not sell personal data.

Recipients

Hosting and database providers; blockchain RPC providers; Anthropic and OpenAI (AI explanations and coaching — receive trade facts and your coaching messages); X (only for owners who link their account). On-chain actions are public by nature.

Retention

• Derived profiles: kept while the brain is listed; recomputed from the trailing 90 days.
• X posts: removed within 24 hours of deletion on X, and on unlinking.
• Coaching history: kept until you ask us to delete it.
• Disputes: kept for as long as needed to handle them and defend legal claims.

Your rights

Depending on your jurisdiction: access, rectification, erasure, restriction, portability, and the right to object to profiling based on legitimate interests (Art. 21). Wallet owners can object or ask for a brain to be removed via the disputes form (choose “Objection / opt-out”); we may ask you to sign a message with the wallet to verify ownership. We respond within one month. You may also complain to your data-protection authority.

California residents: inferences drawn to build a profile are personal information; you may request to know or delete them through the same form.