PRIVACY POLICY

This Privacy Policy explains how CrowdCent collects, uses, and protects your personal information when you participate in the CrowdCent Challenge, our open data science competition. We take your privacy seriously and are committed to protecting your data in accordance with applicable privacy laws.

1. INFORMATION WE COLLECT

1.1 PARTICIPANT INFORMATION

When you register for the CrowdCent Challenge, we collect:

• Contact information (name, email, professional affiliation)
• Account credentials
• Professional background and expertise
• IP address and browser information
• Communication preferences

1.2 PREDICTION DATA

When you participate in the Challenge, we collect:

• Your submitted prediction files (CSV or Parquet format)
• Performance metrics of your submissions
• Any documentation you provide about your approach
• Timestamps and frequency of submissions
• File metadata

Note that we do not collect your actual model code, algorithms, or the specific methodologies you use to generate your predictions unless you voluntarily choose to share this information.

1.3 PLATFORM USAGE DATA

As you use our platform, we collect:

• Comments, forum posts, and other contributions
• Interaction with training datasets
• Communication with other participants
• Feedback you provide about the Challenge
• Technical data such as browser type, device information, and cookies

1.4 WALLET AND TRADING INFORMATION

If you connect a crypto wallet or enable live trading through CrowdCent, we additionally collect and process:

• Public wallet addresses you connect or verify (your linked identity wallet and, if different, the wallet you designate as your trading account)
• The public address of the trading agent key described below, approval and expiry timestamps, and the version and timestamp of the Trading Services Terms you accepted
• Your trading configuration (mandates, strategy sleeves, schedules, leverage and execution settings)
• Records of rebalance runs, orders, fills, cancellations, fees, and positions associated with your trading account, including data we retrieve from the Hyperliquid API about your account
• Your trading-related API activity (which of your API keys are enabled for trading and the requests made with them)

Trading agent key: when you enable trading, we generate a cryptographic keypair whose private key is held by CrowdCent in encrypted form. This key can sign trading actions on your Hyperliquid account but cannot withdraw or transfer funds. We never collect or store the private key of your own wallet.

Blockchain and venue data associated with your wallet addresses, including your trading activity on Hyperliquid, is public by the nature of those systems, is not controlled by CrowdCent, and cannot be deleted by CrowdCent.

2. HOW WE USE YOUR INFORMATION

2.1 ADMINISTRATION

We use your information to:

• Verify your eligibility for participation
• Evaluate your prediction submissions
• Calculate and distribute rewards
• Create leaderboards and performance rankings
• Communicate important challenge updates

2.2 PLATFORM IMPROVEMENT

Your data helps us:

• Enhance the quality of our training datasets
• Improve the competition structure and evaluation metrics
• Fix technical issues and bugs
• Develop new features based on participant feedback
• Protect against fraudulent or abusive activity

2.3 RESEARCH AND STRATEGY

We may use your predictions to:

• Create aggregate prediction sets combining top-performing approaches
• Conduct research on collective intelligence in investment strategies
• Publish anonymized insights about prediction accuracy
• Guide actual capital allocation based on competition results

2.4 TRADING OPERATIONS AND GEOLOCATION

If you use the Trading Services we use the information above to execute your configured trading instructions, monitor and reconcile orders against the venue, calculate and record fees, provide you with run and order history, secure the service, and keep records of your authorization.

Geolocation: each time you attempt an action that adds trading risk (such as enabling trading or executing a rebalance), we evaluate the country — and, where available, the first-level region (state or province) — associated with your current request, as reported by our network edge provider based on your IP address. We use this signal at the moment of the request to allow or refuse the action. The application does not persist this location decision and does not build a location history from these checks; however, the infrastructure and security providers that operate our network edge and request logging may process request metadata, including IP addresses and derived country and region, as part of ordinary security and operational logging under the retention framework of this policy. If your location cannot be determined or is a restricted region, actions that add trading risk are refused; actions that reduce risk (pausing, revoking, canceling orders, closing positions) are not geo-restricted. Scheduled trading that you previously authorized runs in the background and is not re-evaluated against your live location on every run.

3. LAWFUL BASIS FOR PROCESSING

We process your personal data on the following legal grounds:

• Contractual Necessity: Processing necessary for the performance of our contract with you (the Terms and Conditions you accept when joining the Challenge)
• Legitimate Interests: Processing necessary for our legitimate interests, such as improving our services, protecting against fraud, and conducting research
• Consent: Where you have explicitly given us permission to process your data for specific purposes, such as for marketing communications
• Legal Obligation: Processing necessary to comply with our legal obligations

4. DATA SHARING AND DISCLOSURE

We may share your information with:

• Service Providers: Third parties who help us operate the platform (hosting, network edge, storage, analytics, etc.)
• Trading Venue: If you use the Trading Services, orders signed with your trading agent key are transmitted to the Hyperliquid API and become associated with your public wallet address on a public system
• Research Partners: Academic or industry partners for analysis of anonymized data
• Legal Authorities: When required by law or to protect our rights

We will never sell your personal information to third parties or share your prediction methodologies without your express consent.

5. INTERNATIONAL DATA TRANSFERS

Your personal information may be processed in countries outside your country of residence, including countries that may have different data protection standards. When we transfer your data internationally, we implement appropriate safeguards in accordance with applicable law, such as standard contractual clauses, to ensure the protection of your information.

6. YOUR PRIVACY RIGHTS

Depending on your location, you may have the right to:

• Access the personal data we hold about you
• Correct inaccurate information
• Request deletion of your data
• Restrict certain processing activities
• Export your data in a portable format
• Object to certain uses of your information
• Withdraw consent where processing is based on consent

To exercise these rights, please contact us at [email protected].

7. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

If you are a California resident, the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA) grants you specific rights regarding your personal information:

• The right to know what personal information we collect and how it is used and disclosed
• The right to delete personal information (subject to certain exceptions)
• The right to correct inaccurate personal information
• The right to opt-out of the sale or sharing of personal information
• The right to limit the use and disclosure of sensitive personal information

We do not sell or share your personal information as those terms are defined under California law. To exercise your California privacy rights, contact us at [email protected].

We will not discriminate against you for exercising your CCPA/CPRA rights.

8. EUROPEAN PRIVACY RIGHTS (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have certain rights under the General Data Protection Regulation (GDPR) and similar laws:

• Right to access your personal data
• Right to rectification of inaccurate data
• Right to erasure ("right to be forgotten")
• Right to restriction of processing
• Right to data portability
• Right to object to processing based on legitimate interests
• Right to withdraw consent
• Right to lodge a complaint with a supervisory authority

To exercise these rights, contact us at [email protected]. We will respond to your request within 30 days or inform you if we require additional time.

9. DATA SUBJECT ACCESS REQUESTS

To submit a request to exercise your privacy rights:

• Email us at [email protected]
• Include "Privacy Rights Request" in the subject line
• Specify which right(s) you wish to exercise
• Provide sufficient information for us to verify your identity

We will verify your identity before fulfilling your request by matching information you provide with information we have on file. In some cases, we may request additional verification documents. We will respond to your request within the timeframes required by applicable law.

10. DATA RETENTION AND SECURITY

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. For Challenge participants, we typically retain account information for the duration of your participation plus three years.

If you use the Trading Services, we retain trading records — including mandate configurations, rebalance runs, orders, fills, fee records, and your recorded acceptance of the Trading Services Terms — for as long as necessary as evidence of your authorization and for audit, dispute-resolution, and legal-compliance purposes.

Prediction files and performance data may be retained indefinitely in anonymized form for research and investment strategy development purposes.

We implement appropriate technical and organizational measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These include:

• Encryption of sensitive data at rest and in transit
• Access controls and authentication requirements
• Regular security assessments and vulnerability testing
• Staff training on data protection and security practices
• Incident response procedures

11. DATA BREACH NOTIFICATION

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will:

• Notify relevant supervisory authorities without undue delay and, where feasible, within 72 hours of becoming aware of the breach
• Notify affected individuals promptly when the breach is likely to result in a high risk to their rights and freedoms
• Provide information on the nature of the breach, likely consequences, measures taken to address the breach, and contact information for inquiries

12. COOKIES AND TRACKING

Our platform uses cookies and similar technologies to enhance your experience, analyze usage patterns, and deliver personalized content. We use the following types of cookies:

• Essential cookies: Necessary for the website to function properly
• Functional cookies: Enable enhanced functionality and personalization
• Analytics cookies: Help us understand how visitors interact with our website
• Marketing cookies: Used to track visitors across websites for advertising purposes (only with your consent)

13. CHILDREN'S PRIVACY

Our services are not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us at [email protected]. If we become aware that we have collected personal information from a child without verifiable parental consent, we will take steps to delete that information.

14. UPDATES TO THIS POLICY

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of any material changes by posting the new policy on our platform and updating the "Last Updated" date. For significant changes, we will provide more prominent notice, such as an email notification to registered users. Your continued use of the platform after changes to the Privacy Policy constitutes acceptance of the updated terms.