# Privacy Policy

*Last updated: 23 March 2026*

This Privacy Policy ("**Policy**") governs how Probly ("**Company**", "**we**", "**us**", "**our**") collects, uses, and protects your Personal Information when you use the Probly website, mobile applications, and related services (collectively, the "**Services**").

By using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy. If you do not agree to this Policy, do not use, access, or interact with the Services.

{% hint style="info" %}
In this Policy, **"Personal Information"** means information that can be associated with a specific person and used to identify that person. Aggregated or anonymized data that cannot identify a specific user is not considered Personal Information.
{% endhint %}

## 1. Information We Collect

### Information You Provide

Personal Information you may provide to us includes:

* Any **digital asset** you hold or transact
* **Wallet information** and protocol addresses
* **Geolocation data**
* **Transaction data and history**
* Any information associated with a linked address, wallet, or token holdings

This is typically provided when you connect your wallet, sign up, or communicate with us.

### Information Collected Automatically

We also collect information as you navigate the Services, including:

* **Usage details** (pages visited, time spent, actions taken)
* **IP addresses** and device identifiers
* Information collected through **cookies and tracking technologies**

### Information from Third Parties

In certain instances, we may receive information from:

* **Business partners** and third-party providers
* **Networks** where you have connected your account and authorized access
* **Customer support** interactions

## 2. How We Use Your Information

We use your Personal Information to:

* **Deliver the Services** and provide customer support
* **Process transactions** (including payments and refunds) and send related notices
* **Customize, personalize, and improve** the Services
* **Verify information** and compare for accuracy
* **Compile aggregated statistics** for internal or partner use
* **Detect security incidents** and protect against malicious, deceptive, fraudulent, or illegal activity
* **Comply with our legal obligations**, protect your vital interests, or act where required for the public good
* **Enforce our Terms and policies**
* **Notify you of updates** to the Services
* **Provide targeted advertising, newsletters, and promotional content**
* **Research and develop** new products and features

## 3. How We Share Your Information

We may share your Personal Information with:

| Recipient                          | Purpose                                                                |
| ---------------------------------- | ---------------------------------------------------------------------- |
| **Service providers**              | Technical, customer service, fraud detection, and marketing assistance |
| **Business partners**              | To offer products, services, and promotions                            |
| **Affiliates and subsidiaries**    | Joint operation and administration                                     |
| **Law enforcement and regulators** | When required by subpoena, court order, or law                         |
| **Third parties you authorize**    | Via account connections (e.g., linking a social media account)         |
| **Acquirers**                      | In the event of a merger, sale, reorganization, or bankruptcy          |

### Public Blockchain Data

Some information is inherently public due to the nature of the blockchain, including:

* Your Web3 wallet's public address
* Your username and profile details (if set)
* Public transactions you've been involved in

This information may be seen, reshared, or downloaded by anyone, whether or not they have a Probly account.

## 4. Cookies

A cookie is a small file placed on your device. We and certain partners use cookies and similar tracking technologies to:

* Recognize you as a customer
* Customize the Services
* Measure promotional effectiveness
* Perform analytics
* Mitigate fraud and promote trust & safety

Most browsers accept cookies by default. You can remove or reject cookies, but certain Services may be limited or unavailable if you do.

## 5. Third-Party Services and Wallets

The Services may contain links to, or integration with, third-party applications, websites, or wallets.

* We **do not control** these third parties or their privacy practices
* Your use of any third-party service is **at your own risk** and subject to their terms and privacy policies
* We **disclaim responsibility** for issues arising from your use of external wallets or services

Please review any applicable third-party terms and privacy policies before using them.

## 6. How We Protect Your Information

We strive to ensure security on our systems and use administrative, technical, and physical security measures to help protect your Personal Information. This includes computer safeguards such as firewalls and data encryption, access controls to our offices and files, and authorizing access to Personal Information only for those employees who require it to fulfill their job responsibilities.

{% hint style="warning" %}
Despite our efforts, no method of transmission over the Internet or electronic storage is absolutely secure. We cannot guarantee that your Personal Information will not be accessed, disclosed, altered, or destroyed by breach of our safeguards. Any transmission of Personal Information is at your own risk.
{% endhint %}

## 7. Minors

The Services are not intended for individuals **under 18 years of age**. If we discover that we have inadvertently collected information from anyone under 18, we will take reasonable steps to delete it.

## 8. International Transfers

Your Personal Information may be transferred to and maintained on servers located outside of your country of residence, where data protection laws may differ.

By using the Services, you consent to the transfer of your information internationally. We take reasonable steps to ensure your information is treated securely and in accordance with this Policy.

## 9. Your Rights

Depending on your jurisdiction, you may have certain rights regarding your Personal Information, including the right to:

* **Access** — View your held Personal Information, its usage details, and sharing recipients
* **Correct** — Seek fixes to erroneous or partial Personal Information, subject to our checks
* **Delete** — Demand Personal Information erasure under specific conditions
* **Object** — Contest Personal Information handling in select cases
* **Restrict** — Limit handling to mere storage in certain situations
* **Withdraw consent** — Revoke permission for consent-based handling, without impacting prior or alternate-basis activities

{% hint style="info" %}
These rights apply only in certain circumstances and may be limited by law. They are also contextual and may face legal constraints — e.g., if they harm other users, our proprietary information, public welfare, or retention mandates. Identity confirmation will precede responses, and we have the sole and absolute discretion to deny requests under lawful grounds.
{% endhint %}

## 10. Retention

We retain your Personal Information for as long as necessary for the purposes described in this Policy. After that, we may delete or anonymize it, except where retention is required to:

* Comply with legal obligations
* Resolve disputes
* Enforce our agreements

## 11. Jurisdiction

The Services, including the website, are made available from **Panama** and are not intended to subject us to the laws or jurisdiction of any other state, country, or territory.

## 12. Changes to This Policy

We may update this Policy at any time. When we do, we will revise the "Last updated" date at the top of this page. Your continued use of the Services following any changes constitutes your acceptance of the updated Policy.

We encourage you to review this page periodically to stay informed about our information practices.

## 13. Contact

For inquiries or concerns about our Personal Information practices, your information, or this Policy, contact **\[-]**.

***

*This page is the binding Privacy Policy. By using the Probly Platform, you agree to this Policy in full.*


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