# Privacy Policy

Last updated: 4 October 2026

## 1. Introduction

This Privacy Policy explains how information is collected, used, stored, disclosed, and protected when you access or use PumpPoly, including the PumpPoly website, application interface, token launch tools, trading tools, decentralized exchange features, reward-related functionality, social or community features, and related software services.

PumpPoly is a non-custodial software platform and protocol interface.

PumpPoly develops and operates its website, application interface and related software services. The on-chain protocol is designed to be fully decentralized and non-custodial; it remains under development. Planet Mining accounts, accepted actions and point balances are managed by separate application services.

For personal data processed through the PumpPoly website, application interface and related software services, PumpPoly acts as the responsible operator and, where applicable under relevant data protection law, the data controller. Privacy requests can be sent to contact@pumppoly.com.

References in this Privacy Policy to “PumpPoly”, “we”, “us”, or “our” refer to PumpPoly as the operator of the website, interface and related software services, unless the context specifically refers to decentralized blockchain infrastructure.

PumpPoly is non-custodial.

We do not take custody of user funds and we do not request or intentionally collect private keys, seed phrases, recovery phrases, or wallet passwords.

By using PumpPoly, you acknowledge that blockchain activity is public by design and that certain information may be permanently recorded on Solana, Base, Robinhood Chain, or other supported blockchain networks.

## 2. Information We May Process

We aim to collect and process only information reasonably necessary to operate, secure, maintain, improve, and provide PumpPoly.

Depending on how you use PumpPoly, this may include the categories described below.

### 2.1 Wallet and Blockchain Information

We may process:

* Public wallet addresses;

* Public blockchain transaction hashes;

* Public transaction history;

* Public token balances;

* Public smart contract or blockchain program interactions;

* Public token ownership information;

* Public reward-related activity;

* Public trading activity;

* Public token launch activity; and

* Other information publicly available on supported blockchain networks.

Blockchain information may be obtained directly from supported networks or through blockchain infrastructure providers, RPC providers, indexers, explorers, or similar services.

### 2.2 Token and Creator Information

If you create or manage content through PumpPoly, we may process information you voluntarily provide, including:

* Token name;

* Token ticker;

* Token description;

* Images or media;

* Website links;

* Social links;

* Creator profile information;

* Community information; and

* Other token-related metadata submitted through the platform.

Information submitted for a public token launch may become publicly visible.

### 2.3 Trading and Reward Information

We may process information required to provide or display trading and reward-related functionality, including:

* Wallet trading activity;

* Eligible transaction data;

* Trading volume;

* Reward eligibility;

* Reward accrual information;

* Reward claim status;

* Reward epochs;

* Claim transactions;

* Graduation-related activity;

* Liquidity-related activity; and

* Other protocol accounting information.

Some of this information may be derived entirely from public blockchain records.

### 2.4 Technical and Usage Information

When you access the PumpPoly website or application interface, we may receive certain technical information, including:

* IP address;

* Device type;

* Browser type;

* Operating system;

* Approximate location derived from IP or similar technical information;

* Language or regional settings;

* Referral source;

* Pages or screens visited;

* Feature interactions;

* Session information;

* Error logs;

* Performance information;

* Security logs; and

* Other technical information reasonably necessary to operate and secure the service.

We do not use technical location data to determine your precise physical location unless expressly disclosed and legally permitted.

### 2.5 Communications

If you contact PumpPoly, we may process information contained in your communication, including:

* Email address;

* Name, if voluntarily provided;

* Support request;

* Message content;

* Technical information relating to your request; and

* Previous correspondence relating to the same matter.

### 2.6 Information You Voluntarily Provide

You may voluntarily provide additional information when using features such as:

* Email subscriptions;

* Notifications;

* Social features;

* Creator profiles;

* Community features;

* Support forms;

* Feedback forms; or

* Other optional PumpPoly functionality.

We will process such information only for purposes reasonably connected with the feature for which it was provided.

## 3. Information We Do Not Request

PumpPoly does not request, and its services are not intended to collect:

* Private keys;

* Seed phrases;

* Recovery phrases; or

* Wallet passwords.

You should never provide this information to PumpPoly support personnel, community members, or anyone claiming to represent PumpPoly.

Anyone requesting this information while claiming to represent PumpPoly should be treated as potentially fraudulent.

## 4. Public Blockchain Data

Public blockchain networks are designed to make transaction information publicly available.

When you:

* Connect a wallet;

* Create a token;

* Buy or sell a token;

* Provide or interact with liquidity;

* Claim rewards;

* Graduate a token;

* Interact with smart contracts or blockchain programs; or

* Perform other blockchain transactions,

your wallet address, transaction details, token activity, and other blockchain information may be publicly visible.

This information may be accessed by:

* Blockchain explorers;

* Validators;

* Node operators;

* Indexers;

* Analytics platforms;

* Wallet providers;

* Researchers;

* Other blockchain participants; and

* Members of the public.

PumpPoly generally cannot delete, modify, reverse, conceal, or erase information that has already been recorded on a public blockchain.

Requests relating to deletion or correction of personal data therefore may not apply to immutable public blockchain records where modification is technically impossible or outside our control.

## 5. How We Use Information

We may process information for purposes including:

* Operating the PumpPoly website and application interface;

* Providing wallet connectivity;

* Facilitating interaction with supported blockchain networks;

* Displaying token information;

* Providing token launch functionality;

* Displaying trading activity;

* Providing decentralized exchange functionality;

* Displaying liquidity information;

* Calculating or displaying reward-related information;

* Processing or displaying reward eligibility;

* Supporting token graduation mechanics;

* Providing portfolio or watchlist functionality;

* Providing social or community features;

* Maintaining user preferences;

* Improving platform performance;

* Monitoring system reliability;

* Detecting technical errors;

* Debugging software;

* Preventing fraud;

* Detecting abuse;

* Protecting reward accounting;

* Detecting duplicate or fraudulent reward claims;

* Detecting malicious automation;

* Protecting PumpPoly infrastructure;

* Protecting users;

* Responding to support requests;

* Analyzing aggregated platform usage;

* Developing new features;

* Communicating important service or security updates;

* Complying with applicable legal obligations; and

* Establishing, exercising, or defending legal claims.

We do not use wallet activity as a basis for guaranteeing investment outcomes or recommending specific digital assets.

## 6. Legal Bases for Processing

Where applicable data protection law requires a legal basis for processing personal data, we may rely on one or more of the following.

### 6.1 Performance of a Contract or User-Requested Service

We may process information where necessary to provide functionality or services requested by you.

This may include providing access to PumpPoly features, responding to support requests, maintaining preferences, or enabling functionality initiated through the interface.

### 6.2 Legitimate Interests

We may process information where reasonably necessary for legitimate interests, including:

* Operating PumpPoly;

* Maintaining platform security;

* Preventing fraud and abuse;

* Protecting protocol accounting;

* Debugging technical problems;

* Improving platform functionality;

* Preventing malicious activity;

* Protecting infrastructure; and

* Understanding how the platform is used.

Where required by applicable law, we consider whether these interests are overridden by the rights and interests of affected users.

### 6.3 Legal Obligations

We may process or disclose information where necessary to comply with applicable legal or regulatory obligations.

### 6.4 Consent

We may rely on your consent where required, particularly for:

* Non-essential cookies;

* Certain analytics technologies;

* Marketing communications; or

* Other optional processing activities requiring consent.

Where processing is based on consent, you may withdraw your consent at any time.

Withdrawal of consent does not affect processing lawfully carried out before withdrawal.

## 7. Cookies and Similar Technologies

PumpPoly may use cookies, local storage, session storage, or similar browser technologies.

### Essential Technologies

Certain technologies may be necessary to:

* Maintain application functionality;

* Store user preferences;

* Maintain security controls;

* Remember network selections;

* Support wallet interaction; or

* Provide other requested functionality.

### Analytics and Non-Essential Technologies

Where used, non-essential analytics or tracking technologies will be handled in accordance with applicable law.

Where consent is legally required, such technologies should not be activated until appropriate consent has been obtained.

Users may be able to manage preferences through a cookie banner, consent-management interface, or browser settings.

Disabling certain browser technologies may affect the functionality of some PumpPoly features.

## 8. Analytics

PumpPoly may use analytics to understand how the website and application are used.

Analytics information may include:

* Page views;

* Navigation patterns;

* Device types;

* Browser information;

* Referral sources;

* General feature usage;

* Performance information; and

* Error information.

Where reasonably possible, we seek to limit analytics collection to information necessary to understand and improve the service.

Where applicable law requires consent for analytics technologies, consent will be requested before such technologies are used.

## 9. Security and Fraud Prevention

We may process technical, usage, wallet, and blockchain information to detect and prevent:

* Fraud;

* Phishing;

* Reward manipulation;

* Duplicate reward claims;

* Replay attempts;

* Exploitation;

* Artificial or deceptive activity;

* Malicious automation;

* Infrastructure attacks;

* Unauthorized access;

* Smart contract abuse;

* Spam;

* Security incidents; and

* Other prohibited activity.

Security measures may include automated detection systems, technical logs, blockchain analysis, rate limiting, monitoring systems, and manual investigation where reasonably necessary.

## 10. How We Share Information

We may disclose limited information to service providers or professional advisers where reasonably necessary to operate PumpPoly.

These may include providers of:

* Hosting infrastructure;

* Cloud infrastructure;

* RPC services;

* Blockchain indexing;

* Blockchain analytics;

* Wallet connectivity;

* Security monitoring;

* Error monitoring;

* Analytics;

* Communications;

* Customer support;

* Content delivery;

* Technical infrastructure;

* Legal services;

* Accounting services; and

* Compliance services.

Service providers may process information only as permitted by applicable agreements and applicable law.

We may also disclose information where reasonably necessary to:

* Comply with applicable law;

* Respond to valid legal process;

* Respond to a lawful court order;

* Respond to a legally binding government request;

* Investigate fraud or security incidents;

* Protect the rights or safety of users;

* Protect PumpPoly;

* Enforce applicable terms; or

* Establish, exercise, or defend legal claims.

## 11. Sale of Personal Data

PumpPoly does not sell personal data to advertisers in exchange for monetary payment.

If our practices materially change in the future, this Privacy Policy will be updated and any rights required under applicable law will be provided.

## 12. Third-Party Services

PumpPoly may interact with independent third-party services, including:

* Wallet providers;

* Blockchain networks;

* Blockchain explorers;

* RPC providers;

* Indexers;

* Analytics providers;

* Hosting providers;

* Security providers;

* Liquidity infrastructure;

* Social networks;

* Community platforms;

* Token metadata providers; and

* Other blockchain or software infrastructure.

Third parties operate under their own terms and privacy policies.

PumpPoly does not control the privacy practices, data processing, security, availability, or conduct of independent third-party services.

You should review the privacy policies of third-party services before using them.

## 13. Social and Community Features

PumpPoly may introduce social, profile, community, reputation, activity-feed, notification, or similar features.

Information you intentionally publish through public social features may become publicly visible.

This may include:

* Profile information;

* Public wallet information;

* Posts;

* Comments;

* Creator information;

* Public trading activity;

* Public token activity;

* Social links; and

* Other information you choose to publish.

You should not publish information that you want to remain private.

Public content may be viewed, copied, shared, indexed, or otherwise processed by other users or third parties outside the control of PumpPoly.

## 14. Data Retention

We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by applicable law.

Retention periods may depend on:

* The nature of the information;

* The reason it was collected;

* Security requirements;

* Fraud-prevention requirements;

* Support requirements;

* Legal obligations;

* Accounting requirements;

* Dispute-resolution requirements; and

* Technical requirements.

Technical and security logs may be retained where reasonably necessary for:

* Cybersecurity;

* Debugging;

* Fraud prevention;

* Abuse prevention;

* Incident investigation; and

* Infrastructure protection.

Support communications may be retained where reasonably necessary to manage requests, resolve disputes, maintain records, or protect legal rights.

Public blockchain information may remain publicly accessible indefinitely because it is maintained by decentralized networks outside the control of PumpPoly.

## 15. Data Security

PumpPoly uses reasonable technical and organizational measures intended to protect information processed through PumpPoly.

Security measures may include, where appropriate:

* Access controls;

* Infrastructure security;

* Encryption;

* Secure development practices;

* Monitoring;

* Logging;

* Vulnerability management;

* Rate limiting;

* Separation of production systems;

* Authentication controls; and

* Incident-response procedures.

However, no website, application, blockchain system, smart contract, wallet, network, or internet-based service can be guaranteed to be completely secure.

Users remain responsible for securing:

* Their wallets;

* Their devices;

* Their passwords;

* Their private keys;

* Their seed or recovery phrases; and

* Their transaction approvals.

PumpPoly will never request your private key, seed phrase, recovery phrase, or wallet password.

## 16. Your Privacy Rights

Depending on your location and applicable law, you may have rights relating to your personal data.

These may include:

* The right to request access to personal data;

* The right to request correction of inaccurate personal data;

* The right to request deletion of certain personal data;

* The right to restrict certain processing;

* The right to object to certain processing;

* The right to data portability where applicable;

* The right to withdraw consent where processing is based on consent; and

* The right to lodge a complaint with an applicable data protection authority.

These rights are not absolute and may be subject to legal limitations.

Certain rights may not be technically capable of being applied to immutable public blockchain records.

We may need to verify your identity before responding to certain privacy requests.

Where a request concerns a wallet address, verification may require reasonable evidence that you control the relevant wallet.

## 17. EEA, UK, and Similar Data Protection Rights

Users located in the European Economic Area, United Kingdom, or other jurisdictions with comparable data protection laws may have additional rights under applicable law.

Where such laws apply, PumpPoly will process personal data in accordance with applicable legal requirements.

Users may have the right to contact the relevant supervisory or data protection authority if they believe their personal data has been processed unlawfully.

Nothing in this Privacy Policy is intended to restrict rights that cannot legally be waived or limited.

## 18. International Data Transfers

PumpPoly may use infrastructure, service providers, blockchain networks, and technical systems located in multiple countries.

As a result, information may be processed outside the country where you are located.

Where applicable law requires safeguards for international transfers of personal data, appropriate legal or contractual safeguards will be used where required.

Public blockchain networks are global by nature.

Information recorded on public blockchains may be replicated, processed, and accessed worldwide.

## 19. Children

PumpPoly is not intended for children.

You must not use PumpPoly if you are below the minimum legal age required to use the service in your jurisdiction.

PumpPoly does not knowingly seek to collect personal data from children.

If we become aware that personal data has been collected from a child in circumstances prohibited by applicable law, we will take reasonable steps to address the matter.

This does not necessarily include data permanently recorded on public blockchain networks that cannot technically be deleted by PumpPoly.

## 20. Marketing Communications

PumpPoly may send marketing or promotional communications only where a user has voluntarily subscribed or where another lawful basis exists under applicable law.

Where consent is required, marketing communications will be sent only after consent has been obtained.

You may unsubscribe from marketing communications at any time using the unsubscribe mechanism provided in the communication or by contacting us.

Unsubscribing from marketing communications does not necessarily prevent us from sending necessary:

* Security notices;

* Legal notices;

* Service notices;

* Transaction-related information; or

* Other important non-marketing communications.

## 21. Security Incidents

If we become aware of a security incident involving personal data, we may investigate the incident and take reasonable measures to limit or mitigate its effects.

Where required by applicable law, affected individuals and relevant authorities will be notified.

Blockchain-specific incidents may involve information or transactions that cannot be reversed or deleted.

## 22. Business Changes

If responsibility for the PumpPoly website or related services changes, information associated with those services may be transferred where legally permitted.

Where required, users will be informed of material changes affecting the processing of personal data.

## 23. Changes to This Privacy Policy

We may update this Privacy Policy from time to time.

The current version will be published on the official PumpPoly website with an updated “Last updated” date.

Where required by applicable law, we may provide additional notice regarding material changes.

If a change requires new consent under applicable law, we will request that consent before conducting the relevant processing.

Previous processing will remain governed by the version of the Privacy Policy applicable at the relevant time, subject to applicable law.

## 24. Relationship With the PumpPoly Terms of Use

This Privacy Policy should be read together with the **PumpPoly Terms of Use**.

The Terms of Use govern use of the PumpPoly interface and related software services.

This Privacy Policy explains how personal data and related information are processed in connection with those services.

## 25. Operator and Privacy Contact

The PumpPoly website, application interface, and related software services are developed and operated by Konrad Bastek, an individual operating under the PumpPoly name. PumpPoly is the product and brand name; it is not currently a separately incorporated company.

PumpPoly

**Product:** PumpPoly

**Website:** pumppoly.com

**Email:** [contact@pumppoly.com](mailto:contact@pumppoly.com)

For privacy questions, requests relating to personal data, or security concerns, contact:

**[contact@pumppoly.com](mailto:contact@pumppoly.com)**

When submitting a privacy request, please provide sufficient information for us to understand and respond to the request.

Do not send private keys, seed phrases, recovery phrases, or wallet passwords.

Always verify that you are using official PumpPoly websites, social accounts, and links before connecting a wallet.

26. PumpPoly Browser Companion

This section applies specifically to PumpPoly Browser Companion version 0.2.2. Its purpose is to help you inspect public token addresses, keep a local watchlist and open the corresponding PumpPoly page. The extension-specific restrictions below apply even where other sections describe broader website or application features.

Information processed when you use the extension

When you request a token inspection, search or conversation context, the extension sends the selected chain and token address, or the search terms you submit, to PumpPoly's public API at https://dex.pumppoly.com. These requests retrieve the relevant token information. Selecting a token link does not upload its surrounding page or post.

The extension stores preferences, your last selected token or candidate address, up to 20 recently inspected tokens and a watchlist of up to 100 addresses per supported chain in your browser's local extension storage. Recent entries include token information and the time of inspection. A short search selection made through the context menu may remain as the last local query. These records are separate from your website watchlist and are not synchronized with a PumpPoly account or other devices.

Public token responses are held in a bounded memory cache. A separate browser-session record contains request timestamps to enforce request limits; it does not contain token addresses, post text or page URLs.

Website access and X

Optional integrations for pump.fun, DexScreener, Birdeye and GeckoTerminal are disabled initially. If you enable a site and grant its Chrome permission, the extension processes visible public token text and recognized links locally to offer an inspection control. Detection alone does not send that content or an API request to PumpPoly. You can disable each integration and revoke its permission.

The extension does not scan X timelines, monitor posts while you scroll or collect the profiles and posts you view. X interaction requires you to select text or a link and choose a PumpPoly context-menu action, or enter information into the extension yourself. The surrounding X page is not read.

In this version, an X post URL you submit is validated locally and held temporarily in memory. Post import is unavailable: submitting the URL does not fetch the post or send it to PumpPoly as a token search.

When you request public conversation or X context for a token, the extension sends its canonical token identity to PumpPoly. It does not directly access the X API.

Sharing and external destinations

Share on X first lets you review and edit a local draft. Only after you choose Continue to X does the extension open X with your message and the PumpPoly token link. You decide whether to publish. The extension does not store X credentials or post automatically.

Opening PumpPoly or X takes you to that website, where its own privacy practices apply. The extension does not connect a wallet, sign a transaction or submit a trade.

Technical data and restricted use

API requests use HTTPS and omit authentication credentials. PumpPoly's servers and infrastructure providers, including Cloudflare, may receive your IP address and ordinary request metadata, including the requested API path and parameters, to deliver the service and protect it against abuse.

The extension contains no advertising, analytics or telemetry client. It does not access your general browser history, authentication cookies, passwords, private keys or seed phrases. It does not automatically read your clipboard or access X direct messages or private timelines.

PumpPoly Browser Companion's use of user data complies with the Chrome Web Store User Data Policy, including its Limited Use requirements. Extension data is used only for the disclosed extension functionality and permitted related operational purposes. It is not sold, used for personalized advertising, used for creditworthiness or lending, or transferred outside the exceptions allowed by that policy. Human access is limited to the exceptions permitted by that policy, such as specific user consent, security investigation or legal obligations. The broader website provisions in this policy do not expand these permitted uses.

Your controls and retention

You can remove individual watchlist entries and choose Clear recent tokens. Clearing recent tokens removes that list only; it does not remove the last selection, settings, watchlist or infrastructure logs. Local preferences and selections otherwise remain until replaced or removed. Uninstalling the extension removes its local extension storage. Clearing ordinary browsing history does not remove that storage.

Share drafts remain in the current popup or panel memory and are cleared when you cancel, continue to X, change the selected token or close that window. Temporary worker memory, including cached token responses and a submitted X post reference, is discarded when Chrome stops that worker. Browser-session request-budget data is cleared when the browser restarts.

Technical and security logs are handled under the retention and privacy-rights sections of this policy. Removing local extension data does not remove server or Cloudflare records. For privacy questions or requests, contact contact@pumppoly.com.