PálpitoPrivacy Policy
Effective Date: April 1, 2026
Last Updated: April 1, 2026
Introduction
This Privacy Policy (the "Policy") is made available by SMPL Panama, a corporation organized and existing under the laws of Panama (the "Company," "us," "we," or "our").
This Policy governs the manner in which we collect, use, maintain, and disclose information collected from users (each, a "user," "you," or "your") of the Company's websites, web applications, mobile applications, and all associated sites linked thereto by us or our affiliates (the "Site"). This Policy further applies to all information we collect through our Site and otherwise obtain in connection with products, services, content, features, technologies, and functions we may provide to you or to which we may provide access (collectively with the Site, the "Services").
Please read this Policy carefully. We are committed to protecting your privacy through our compliance with the terms of this Policy.
You may contact us at legal@palpito.com with any concerns or privacy-related questions.
Our Terms of Service ("Terms") govern all use of our Services and, together with this Policy, constitute your agreement with us. If you do not agree with the terms of this Policy, please do not access our Site.
By accessing or using our Services, you agree to the terms of this Policy. Specifically, by (i) using, visiting, or accessing the Services, (ii) using, accessing, or establishing an account through the Services, and/or (iii) clicking "accept," "agree," or a similar term with respect to any of our Terms or similar policies, you consent and agree to be legally bound by each of the terms and conditions contained in this Policy.
In operating the Site and providing the Services, we may collect and/or receive certain information about you and your activities. You hereby authorize us to collect and/or receive such information to operate the Site and provide the Services.
Applicability
This Policy applies to all information we collect from you in connection with the Site and offering the Services. This Policy does not apply to information collected by us offline or through any other means, including on any other website made available by us or by any third party (including our affiliates and subsidiaries).
Throughout this Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
Non-Custodial Architecture and Blockchain Data
Our Services operate on a non-custodial, self-custody model built on the Solana blockchain using USDC for settlement. This means that we do not take possession of, hold, or control your digital assets at any time. Your funds are held in a blockchain wallet that only you control.
When you use our Services, an embedded wallet is created for you through our third-party wallet infrastructure provider, Crossmint. The private keys associated with your wallet are managed through Crossmint's secure infrastructure. We do not have access to your unencrypted private keys at any time.
Important: Certain information is inherently public due to the nature of the Solana blockchain. This includes your wallet's public address and all on-chain transaction data, including market participation, settlements, and USDC transfers. This information is visible to anyone on the Internet regardless of whether they have an account with us, and may be accessed through blockchain explorers, APIs, or third-party services.
Information Collection and Use
When you visit the Site and use the Services, we collect your IP address and standard web log information, such as your browser type and pages you accessed on our Site. We may also collect certain geolocation information. If you do not agree to our collection of this information, you may not be able to use the Services.
We collect information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.
- From third parties, such as our business partners, third-party wallet providers (e.g., Crossmint), identity verification providers, fiat on-ramp and off-ramp providers, or other networks where you have connected your account and authorized the Site to access this information.
If you create an account with us, we may collect the following categories of information:
Personal Information
Information by which you may be personally identified, such as your name, email address, date of birth, and other demographic information that you voluntarily provide to us as part of your registration with the Site to use our Services. There is no obligation for you to provide us with personal information of any kind, but your refusal to do so may prevent you from using certain features of the Services.
Progressive Identity Information
Our platform is designed to operate with the minimum amount of personal data required. Users can interact with core platform functionality with minimal identity information. As you access additional features that require higher levels of assurance, such as fiat on-ramps or off-ramps, additional identity data may be requested. This identity progression is purpose-driven, feature-specific, and explicitly tied to regulatory or operational requirements. Such additional information may include government-issued identity documents (passport, national identity card, or driver's license), proof of address, and other documentation required by applicable law.
Derivative Information
Information our servers may collect automatically when you access the Site, such as your IP address, browser type, operating system, access times, and pages you viewed directly before and after accessing the Site. This may also include other information about your internet connection and the equipment you use to access our Site.
Financial Information
If applicable to your use of the Site and the Services, in order for us to facilitate transactions through fiat on-ramp and off-ramp providers, you may be required to provide certain payment information. You authorize our third-party payment and wallet providers (e.g., Crossmint and applicable on-ramp/off-ramp partners) to collect, process, and store your financial information in accordance with their respective privacy policies. We do not directly store your bank account numbers or credit card details.
Mobile Device Information
If you access the Site from a mobile device, we may obtain information automatically about your device such as your device type, mobile device identification number, geolocation information, time zone, language setting, and browser type.
Geolocation Information
We collect information that identifies, with reasonable specificity, your location by using certain longitude and latitude coordinates obtained through GPS, Wi-Fi, cell-site triangulation, or other locational data. We may collect this data for fraud prevention, risk management, and compliance with geographic access restrictions.
Wallet and On-Chain Information
When you interact with the Services, we may collect and store your Solana wallet public address, on-chain transaction history related to the Services, market participation data (positions, orders, settlements), and USDC balance information associated with your account.
Correspondence and Recordkeeping
We will retain records and copies of your correspondence (including email addresses) if you contact us. We will retain all records for such time period as may be required by applicable law.
We are committed to providing a safe and secure user experience. Before permitting you to use certain features of the Services, we may require additional information from you that we can use to verify your identity, address, or other information, and to prevent fraud or manage risk and compliance throughout our relationship.
Children Under the Age of 18
Our Site is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Site. If we obtain actual knowledge that we have collected personal information from a person under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. If you believe we may have mistakenly or unintentionally collected any information from or about a person under 18, please contact us at legal@palpito.com.
Use of Cookies and Other Tracking Technologies
A cookie is a small file placed on the hard drive of your computer. When you visit our Site and use our Services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, "Cookies"). We use Cookies to recognize you as a user, to customize the Services, to measure the effectiveness of our communications, to perform analytics, to mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.
We use the following types of Cookies:
- Authentication. If you are signed in to our Services, cookies help us show you the right information and personalize your experience.
- Security. We use cookies to enable and support our security features and to help us detect malicious activity.
- Preferences, features, and services. Cookies can tell us which language you prefer and what your communication preferences are. They also provide you with features, insights, and customized content.
- Performance, analytics, and research. Cookies help us learn how well our Services perform. We also use cookies to understand, improve, and research products, features, and services.
Most browsers are set to accept cookies by default. You can remove or reject cookies. However, certain features of the Services are only available through the use of Cookies. If you choose to disable or decline Cookies, your use of the Services may be limited or not possible.
Pages of our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related website statistics.
Do Not Track: Do Not Track ("DNT") is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third parties. We do not currently respond to DNT signals.
Use of Your Information
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. We may use information collected about you via the Site for the following purposes:
- Administer your account and provide you with access to the Services.
- Verify your identity and prevent fraud.
- Process transactions, market participation, and settlement of positions.
- Comply with applicable law, court orders, or regulatory requirements.
- Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity.
- Enforce our Terms of Service and other policies.
- Customize, personalize, measure, and improve our Services.
- Create and manage your account, including a personal profile to make future visits and use more personalized.
- Monitor and analyze usage and trends to improve your experience with the Services.
- Deliver customer support and respond to your inquiries.
- Send you reminders, technical notices, updates, security alerts, support and administrative messages, and service bulletins.
- Improve the security of the Site and, if you share geolocation information, provide you with location-specific options and functionality.
- Compile anonymous statistical data and analysis for our use internally or with third parties.
- Undertake research for technological development and demonstration.
- Debug to identify and repair errors that impair existing intended functionality.
- Fulfill any other purpose for which you provide us with your information.
We may also use the information we have collected from you to enable us to display content or advertisements relevant to our Services. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with content, the provider may assume that you meet its target criteria.
How We Share Personal Information with Other Parties
We take care in protecting the security and confidentiality of your personal information. We may share your personal information in the following circumstances:
- Service Providers. With third-party service providers who assist us in providing the Services to you, including wallet infrastructure providers (e.g., Crossmint), fiat on-ramp and off-ramp providers, identity verification providers, cloud hosting providers, and customer support tools.
- Legal Requirements. With law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order, or similar legal procedure, when it is necessary to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Terms of Service.
- Affiliates. With any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control with us.
- Corporate Transactions. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, liquidation, or bankruptcy, your information may be part of the transferred assets.
- With Your Consent. With other third parties with your consent or at your direction, including if you authorize an account connection with a third-party account or platform.
- Blockchain Data. Some personal information is inherently public due to the nature of blockchain technology. This includes your wallet's public address, on-chain transaction history, and market participation activity. This information is publicly visible on the Solana blockchain and may be seen by anyone, whether or not they have an account with us, and may be accessed through blockchain explorers, APIs, SDKs, or third-party services.
When we share personal information with a third-party service provider performing services on our behalf, we generally enter into a contractual agreement requiring it to maintain the confidentiality of such information and prohibiting it from using or disclosing such information except for the limited purpose of performing services on our behalf.
We do not sell your personal information to third parties.
Third-Party Links
The Services may contain links to unaffiliated third-party services, applications, or websites. We do not control information collection by any third-party services, applications, or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party service or website that collects personal information.
Any information you provide to any third party is not covered by this Policy and we cannot guarantee the safety and privacy of your information. Note that third parties may use cookies or other tracking technologies to collect information about you when you use our Services.
Third-Party Analytics
We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Services, compile reports on activity and events, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage.
These third parties use cookies, pixel tags, and other related tracking technologies to help analyze and provide us the data. By visiting and using the Services, you consent, to the extent permitted under applicable law, to the processing of data about you by these analytics services in the manner and for the purposes set out in this Policy.
How We Protect and Store Your Information
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. We strive to ensure security on our systems and use administrative, technical, and other physical security measures to help protect your personal information.
We also use computer safeguards such as firewalls and data encryption, we enforce access controls to our systems and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities.
Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered, or destroyed by breach of our administrative, managerial, and technical safeguards. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
When we believe that personal information is no longer needed, we will remove any information that can identify you or we will securely destroy the records. However, we may need to maintain records for a period of time to comply with various regulatory obligations.
Your Data Protection Rights
Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information as identified below. Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights may be denied: (a) when denial of access is required or authorized by law; (b) when granting access would have a negative impact on another's privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or vexatious. We may ask you to verify your identity before responding to such requests.
- Right to Access. You have the right to access, update, or delete the information we have on you. You may email us at legal@palpito.com to request a copy of the personal information our databases currently contain.
- Right of Correction or Rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- Right to Object. You have the right to object to our processing of your personal information. When such objections are not possible, we will advise you accordingly.
- Right of Restriction. You have the right to request that we restrict the processing of your personal information.
- Right to Data Portability. You have the right to be provided with a copy of your personal information in a structured, machine-readable, and commonly used format.
- Right to Withdraw Consent. You have the right to withdraw your consent at any time where we rely on your consent to process your personal information. Upon receipt of such withdrawal, we will confirm receipt and proceed to stop processing your personal information.
- Right to Erasure. If you wish to cease use of our Site and have your personal information deleted, you may submit a request by emailing us at legal@palpito.com. Upon receipt of such a request for erasure, we will confirm receipt and confirm once your personal information has been deleted.
To exercise any of the rights listed above, please contact us at legal@palpito.com. Use the same email address associated with your use of the Site or your account and include a clear description of your request in the subject line.
Important: Due to the immutable nature of blockchain technology, transaction data recorded on the Solana blockchain cannot be modified or deleted by us or any party. Your right to erasure applies only to off-chain personal information stored in our databases, not to on-chain transaction data.
If you are located in the European Economic Area, the UK, Switzerland, or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.
Personal Communication Preferences
To the extent you have registered for the Services, you may access, review, make changes to, and delete your personal information by following the instructions found on the Site or by sending an email to us at legal@palpito.com. We reserve the right to ask for information verifying your identity before we begin complying with a request.
In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the "Unsubscribe" link located on the bottom of any marketing email, or by sending us an email at legal@palpito.com. Registered users cannot opt out of receiving transactional or administrative emails related to their account.
Transfer of Data
Your personal information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. By using the Services, you consent to the transfer of your information outside of your country of residence, which may have data protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your personal information.
We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy, and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
Return and Deletion of Personal Data
Upon your request we will endeavor to: (i) return all personal information processed in connection with the Services to you in a structured, commonly used, and machine-readable format, and will delete existing copies and backups; or (ii) destroy and delete all personal information processed in connection with the Services, including materials or media containing such personal information. This is subject to any retention obligations under applicable law and does not extend to on-chain blockchain data.
Changes to Our Policy
We may update this Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about our information practices. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site following the posting of changes to this Policy will be deemed your acceptance of those changes.
Jurisdiction
The Services, including the Site, are made available by us from Panama and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of Panama.
Contact Us
If you have any comments or questions about this Policy, please contact us by email at legal@palpito.com.