TOTA
Privacy Policy
How TOTA handles your data. A starting draft — to be finalized and reviewed by counsel before launch.
This is an initial draft for development and may change before launch. It is not yet legal advice or a final agreement.
Last updated: 23 June 2026 · Draft v0.1
1. Overview
This Privacy Policy explains what information TOTA — the Tokenized Onchain Traders Association ("TOTA", "we", "us") — collects when you use our website, applications, and related services (the "Service"), how we use it, and the choices you have. We keep data collection to the minimum needed to run a non-custodial, simulated trading competition.
2. Information we collect
- Wallet address — your public address, used to sign you in and to check token eligibility for gated features.
- Agents and configurations — the trading agents, patterns, and settings you create, and their resulting simulated performance.
- Usage and analytics — basic, aggregated data about how the Service is used, to operate and improve it.
- Technical and log data — information your browser or device sends automatically, such as IP address, device and browser type, and timestamps, used for security, abuse prevention, and diagnostics.
- Communications — what you send us when you contact support or join the waitlist.
3. What we never collect
TOTA is non-custodial. We never collect or store your private keys, seed phrases, or funds. Signing in uses a wallet signature, not a transfer, and we cannot move assets on your behalf.
4. How we use information
- to authenticate you and operate your account;
- to run your agents, simulations, and leagues, and to show your stats;
- to check eligibility for gated features and seasons;
- to keep the Service secure, reliable, and free from abuse; and
- to communicate with you about the Service and respond to your requests.
We do not sell your personal data.
5. Legal bases
Where data-protection law (such as the GDPR) applies, we process personal data on the bases of: performing our contract with you (providing the Service), our legitimate interests (securing and improving the Service), compliance with legal obligations, and your consent where required. You may withdraw consent at any time where processing relies on it.
6. On-chain data
Your wallet address and token holdings exist on public blockchains. Information recorded on-chain — including balances and transactions we read to check eligibility — is public, permanent, and outside of TOTA's control. We can read this data but cannot alter or delete it.
7. Cookies and local storage
We use the minimum browser storage required for sign-in and core app function. We do not use third-party advertising trackers.
8. Third parties and sub-processors
Operating the Service involves third parties that process only what is necessary to provide it — for example, public Base RPC providers (to read on-chain balances), wallet software you choose, our upstream trading-simulation infrastructure, and hosting and analytics providers. These parties are bound to handle data consistent with this Policy and applicable law.
9. Data retention
We keep personal data only as long as needed for the purposes above — to run your account and the competition, meet legal obligations, and resolve disputes — after which we delete or anonymize it. Aggregated or anonymized data, and data recorded on public blockchains, may persist.
10. International transfers
We may process data in countries other than yours. Where required, we use appropriate safeguards for such transfers consistent with applicable data-protection law.
11. Security
We use reasonable technical and organizational measures to protect your data. No method of transmission or storage is completely secure, and you are responsible for keeping your own wallet and credentials safe.
12. Your rights
Depending on your jurisdiction, you may have rights to access, correct, delete, restrict, or object to the processing of your personal data, and to data portability. To exercise any of these, contact us via Support. Note that we cannot change or remove data recorded on public blockchains.
13. Children
The Service is not directed to anyone under the age of majority in their jurisdiction, and we do not knowingly collect their personal data. If you believe a minor has provided us data, contact us and we will address it.
14. Changes
This policy will evolve with the product; material changes will be reflected here with an updated date.
15. Contact
Questions or requests about your data? Reach us via Support.