Privacy Policy

1. Scope

This Privacy Policy applies to information we collect:

• through the Services;
• from communications with you (e.g., support emails);
• from device, browser, and usage data generated while you use the Services.

This Privacy Policy does not apply to:

• decentralized protocols and blockchain networks (e.g., Kamino Finance) that you interact with; or
• third-party services you use in connection with the Services (e.g., Privy, Bridge, Crossmint, wallet providers, blockchain explorers), which have their own privacy practices.

2. Key Concepts for a Non-Custodial DeFi Platform

• Non-custodial design: Partial.ly does not have access to your private keys or seed phrase and cannot recover them.
• Public blockchain data: Blockchain transactions and wallet addresses may be publicly visible and can be linked to you through analytics or other sources.
• Third-party providers: Identity checks, on/off-ramps, checkout, and wallet/auth infrastructure may be provided by third parties, and information you provide to them is governed by their policies.

3. Information We Collect

We may collect the following categories of information, depending on how you use the Services.

A. Information you provide

• Account information: email address, username, and similar identifiers.
• Support communications: information you provide when you contact us (messages, attachments, and related metadata).
• User preferences: settings and feature selections you choose within the Services.

B. Information collected automatically

• Device and usage information: device type, operating system, browser type, IP address, approximate location (derived from IP), timestamps, pages/screens viewed, clickstream, and performance logs.
• Cookies and similar technologies: cookies, pixels, and local storage used for authentication, security, analytics, and site functionality.

C. Blockchain-related information

• Wallet addresses and transaction metadata: public wallet addresses you connect and public on-chain transaction data (e.g., transaction hashes, timestamps, token movements).

D. Information from third-party providers

Depending on features you use, we may receive limited information from third parties, such as:

• Privy (wallet/auth infrastructure): authentication tokens, device/session identifiers, and other technical signals required to provide login and wallet connectivity.
• Bridge (fiat rails): status signals for transfers (e.g., pending/complete/failed), limited account identifiers, and compliance/transaction outcomes.
• Crossmint (checkout/onramps/offramps): transaction status signals, order identifiers, and compliance/verification outcomes.

4. How We Use Information

We use information for the following purposes:

• Provide and operate the Services: create and manage accounts, deliver features, display balances and positions, and enable integrations.
• Security and fraud prevention: detect suspicious activity, protect users, prevent abuse, and enforce our Terms.
• Customer support: respond to inquiries, troubleshoot issues, and improve support quality.
• Product improvement: analyze usage, debug, improve performance, develop new features, and measure product adoption.
• Compliance and legal obligations: comply with applicable law, respond to lawful requests, and support third-party compliance requirements.
• Communications: send service-related notices, security alerts, policy updates, and administrative messages.

We do not sell personal information in the traditional sense.

5. How We Share Information

We may share information in the following circumstances:

A. With service providers and vendors

We may share information with vendors who help us operate the Services (e.g., hosting, analytics, customer support tooling, error monitoring). These vendors are authorized to process information on our behalf.

B. With integrated third-party providers

If you use features that rely on third parties (e.g., Privy, Bridge, Crossmint), we may share necessary information with them to facilitate transactions and functionality. These providers process information according to their own privacy practices.

C. For compliance, legal, and safety reasons

We may disclose information if we believe disclosure is necessary to:

• comply with law, regulation, legal process, or governmental request;
• enforce our Terms;
• detect, prevent, or address fraud or security issues;
• protect the rights, property, and safety of Partial.ly, our users, or others.

D. Business transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, information may be transferred as part of that transaction.

E. With your direction

We may share information when you instruct us to (for example, if you choose to export data or connect additional integrations).

6. Cookies and Tracking Technologies

We use cookies and similar technologies for:

• authentication and session management;
• security and fraud prevention;
• analytics and performance measurement;
• user preferences and feature functionality.

You can control cookies through your browser settings. Disabling cookies may affect certain functionality.

7. Data Retention

We retain information for as long as reasonably necessary to:

• provide the Services;
• comply with legal obligations;
• resolve disputes;
• enforce agreements; and
• protect the security and integrity of the Services.

Retention periods may vary depending on the type of information and the purpose for which it is processed.

8. Security

We take reasonable administrative, technical, and organizational measures to protect information. However, no system is 100% secure.

9. Your Choices and Rights

Depending on your jurisdiction, you may have rights to:

• access and request a copy of certain personal information;
• correct inaccurate information;
• delete information (subject to legal and operational limitations);
• object to or restrict certain processing.

To exercise rights, contact privacy@partial.ly .

10. U.S. State Privacy Disclosures (Placeholder)

Certain U.S. states provide additional privacy rights (e.g., access, deletion, correction, opt-out of certain data uses).

If applicable, we will provide a state-specific notice describing:

• categories of personal information collected;
• categories of sources;
• purposes for collection;
• categories of disclosures;
• how to exercise rights;
• how we handle sensitive data.

11. Children's Privacy

The Services are not intended for children under 18, and we do not knowingly collect personal information from children.

12. International Users

The Services are U.S.-first and may not be available outside the United States. If we expand to additional jurisdictions, information may be processed in the United States or other countries where our vendors operate.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last Updated" date and may provide additional notice through the Services.

14. Contact Us