trade

Privacy Policy

Last Updated: February 22, 2026

Effective Date: 02/22/2026  |  Last Updated: 02/22/2026

WHAT THIS POLICY COVERS

This Privacy Policy explains how Many Labs Inc., collects, uses, and protects personal information when Users access or use the Platform and Services.  This Privacy Policy forms part of and should be read in conjunction with the Company Terms of Service. Unless otherwise defined herein, all terms shall have the meaning assigned to them in the Terms of Service. 

By accessing the Platform or using the Services (as defined in the Company Terms of Service), the User acknowledges and agrees to the collection, use, and disclosure of the User's information in accordance with this Privacy Policy. The Platform operates on blockchain technology where transaction data, wallet addresses, and other interactions are publicly accessible and immutable. By accessing or using the Platform or Services, Users acknowledge and consent to the public nature of the blockchain data associated with Their activities. If a User does not agree with the Company’s practices, the User must not use the Platform or Services, and the User is not authorized to access them.

This Policy does not apply to the data practices of third-party Decentralized Protocols, blockchain networks, or other external services accessible through the Platform, each of which is governed by its own privacy terms.

The Company is aware of its responsibilities to handle the User personal data with care, to keep it secure, and comply with applicable privacy and data protection laws, including the Law 81 of 2019 on “Personal Data Protection” and Executive Decree No. 285 of May 28, 2021, which regulates Law 81 of 2019 on Personal Data Protection

THE USER UNDERSTANDS, ACKNOWLEDGES AND AGREES THAT THE COMPANY USES SERVICE PROVIDERS TO MAKE ITS SERVICES AVAILABLE TO THE USER, AND THAT THESE SERVICE PROVIDERS MAY INTERCEPT USER COMMUNICATIONS OR TRACK THEIR ACTIVITIES.  BY USING THE COMPANY’S SERVICES, THE USER SPECIFICALLY CONSENT TO THIS INTERCEPTION, TRACKING AND DATA COLLECTION BY THIRD PARTY SERVICE PROVIDERS.

  • On and through the Services or Platforms; 
  • In email, text and other messages transmitted through the Services or Platforms; 
  • Through any mobile and desktop applications that the User downloads from the Services or Platform; 
  • When the User interacts with the Company’s advertising and applications on third party websites and services, where such advertising or applications include links to this policy; and 
  • Through any other means associated with, or relating to, the Services or Platforms. 

THIS POLICY DOES NOT APPLY TO INFORMATION COLLECTED BY: 

  • The Company offline or through any other means other than as set out above, including on any other website operated by the Company or any third party (including the Company affiliates and subsidiaries); or 
  • Any third party, including through any application or content (including advertising) that may link to the Platforms or Services or is accessible from or on the Platform.
  • DEFINITIONS

For the purposes of this Policy:

    • "Applicable Data Protection Law" means all laws, regulations, directives, and binding guidance relating to the processing of Personal Data applicable to the Company or the Platform, including (to the extent applicable) the Panama's Law 81 of 2019 on Personal Data Protection, General Data Protection Regulation (EU) 2016/679 ("GDPR"), the UK Data Protection Act 2018, the California Consumer Privacy Act as amended by the California Privacy Rights Act ("CCPA/CPRA"), Brazil's Lei Geral de Proteção de Dados ("LGPD"), and equivalent legislation in other jurisdictions.
    • "Blockchain Data" means data recorded on a public blockchain, including wallet addresses, transaction hashes, transaction amounts, timestamps, smart-contract interactions, and other on-chain activity that is publicly accessible by design and outside the Company's ability to modify, delete, or control.
    • "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to names, email addresses, device identifiers, IP addresses, wallet addresses (where linkable to an identified individual), and any other information defined as "personal data," "personal information," or equivalent under Applicable Data Protection Law.
  • INFORMATION ABOUT PERSONS UNDER 18
    • The Platform is not intended for, directed at, or designed to be accessed or used by, any person under the age of eighteen (18) years, or such higher age as may constitute the age of legal majority in the applicable jurisdiction of residence (a "Minor"). No Minor may access, use, register on, or interact with the Platform or any of its features, functionalities, or services in any capacity.
    • No Minor may provide any Personal Data to the Company, whether on or through the Platform, including through account registration, interactive or social features, purchases, customer support communications, or any other mechanism. This prohibition extends to, without limitation, names, email addresses, telephone numbers, residential addresses, wallet addresses, usernames, display names, and any other information that constitutes Personal Data under Applicable Data Protection Law.
    • The Company does not knowingly collect, solicit, or receive Personal Data from Minors. In the event that the Company becomes aware, or has reasonable grounds to believe, that it has collected or received Personal Data from a Minor, the Company shall take prompt and reasonable steps to: (a) identify and isolate such data; (b) permanently delete or destroy such data from the Company's systems and records; and (c) where technically feasible, terminate any account or access associated with such Minor.
    • Any User who believes that the Company may have inadvertently collected or received Personal Data from or about a Minor should promptly contact the Company at team@legend.trade, providing sufficient detail to enable the Company to investigate and take appropriate remedial action.
  • CATEGORIES OF PERSONAL DATA COLLECTED
    • Personal Data Provided Directly by Users: The Company may collect the following categories of Personal Data submitted directly by Users through the Platform:
      • Identifiers such as name, display name, username, date of birth, residential address, password, email address, telephone number, or any other information that the Company collects and/or which applicable law may consider personally identifiable, personal information, personal data and other such designations.
      • User activity on the Services and Platform, including posts and any information contained in them;
      • Any information the User provides when raising queries, reporting issues, or submitting feedback regarding the Platform, which may include the content of the User’s communications and any contact information provided to facilitate a response. 
    • Personal Data Collected Automatically: When a User accesses or interacts with the Platform, the Company and its third-party service providers may automatically collect the following categories of data:
      • Device and Browser Information: IP address, device type, operating system, browser type and version, screen resolution, device identifiers (e.g., advertising identifiers, UDID), language settings, and time zone.
      • Usage Data: Pages and features accessed, clickstream data, session duration, frequency and timing of visits, navigation paths, referring and exit URLs, and interaction patterns with Platform features.
      • Location Data: Approximate geographic location inferred from IP address. The Company does not collect precise GPS-based geolocation data unless explicitly authorized by the User through device-level permission settings, and only for fraud prevention, compliance, or jurisdictional verification purposes.
      • Cookie and Tracking Data: Data collected through cookies, web beacons, pixels, embedded scripts, and similar tracking technologies, as further described in the Company's Cookie Policy.
    • Blockchain and Wallet Data: When a User connects a Self-Custodial Wallet to the Platform or initiates on-chain transactions through the Platform, the Company may collect and process:
      • Public wallet addresses connected to the Platform;
      • On-chain transaction data, including transaction hashes, timestamps, counterparty addresses, and transaction values;
      • Participation data, including entry parameters, performance metrics, and Smart Contract interaction data;
      • Token balances and asset holdings visible through on-chain queries (to the extent necessary for Platform functionality).
    • Important Notice Regarding Blockchain Data: Users acknowledge that Blockchain Data is recorded on public, immutable, decentralized ledgers that are not owned, operated, or controlled by the Company. The Company has no ability to modify, delete, restrict, or erase Blockchain Data once it has been confirmed on a blockchain network. The public and permanent nature of Blockchain Data is inherent to blockchain technology and is not a function of the Company's data processing activities. Users are advised to consider this immutability before initiating any on-chain transaction through the Platform.
    • Personal Data Obtained from Third Parties: The Company may obtain Personal Data from the following third-party sources:
      • Identity verification and KYC/AML service providers;
      • Sanctions screening and adverse-media databases;
      • Wallet-screening and blockchain analytics service providers;
      • Analytics and advertising partners; and
      • Publicly available sources, including public blockchain explorers and social media platforms (where a User has made information publicly available).
  • PURPOSES OF PROCESSING
    • Platform Operation and Service Delivery: The Company processes Personal Data for the following operational purposes:
      • Registering, authenticating, and managing User accounts;
      • Enabling Users to connect Self-Custodial Wallets and interact with Decentralized Protocols through the Platform;
      • Facilitating User participation, including entry processing, performance tracking, and leaderboard generation with respect to Platform activities;
      • Generating and displaying performance rankings, statistics, and analytics;
      • Processing and collecting applicable fees through and protocol-level fee allocation mechanisms; and
      • Providing technical support and responding to User inquiries.
    • Security, Fraud Prevention, and Compliance: The Company processes Personal Data for the following security and compliance purposes:
      • Detecting, investigating, and preventing fraudulent activity, market manipulation, and other violations of the Terms of Service;
      • Enforcing jurisdictional access restrictions and identifying Users accessing the Platform from Restricted Jurisdictions;
      • Conducting identity verification, sanctions screening, and risk assessments as required or permitted by Applicable Law;
      • Monitoring Platform activity for suspicious or unauthorized behavior;
      • Responding to law enforcement requests, regulatory inquiries, and valid legal process; and
      • Maintaining audit logs and records required by Applicable Law.
    • Analytics and Platform Improvement: The Company processes Personal Data for the following analytical purposes:
      • Analyzing Platform usage patterns, feature engagement, and User behavior to improve Platform design, functionality, and user experience;
      • Conducting internal research and development;
      • Measuring the effectiveness of marketing campaigns and communications; and
      • Aggregating and anonymizing data for statistical analysis, benchmarking, and reporting.
    • Communications: The Company may process Personal Data to:
      • Send transactional and operational communications related to the Platform, including account notifications, updates, security alerts, and service changes (these communications are non-marketing and do not require separate consent);
      • Send promotional and marketing communications, where the User has provided consent or where otherwise permitted by Applicable Data Protection Law; and
      • Conduct surveys, request feedback, and distribute informational content.
  • DISCLOSURE AND SHARING OF PERSONAL DATA
    • Categories of Recipients: The Company may disclose Personal Data to the following categories of recipients, subject to appropriate contractual, technical, and organizational safeguards:
      • Service Providers and Third-Parties: Third-party service providers engaged by the Company to perform services on its behalf, including cloud hosting and infrastructure providers, identity verification and KYC/AML service providers and blockchain analytics providers, customer support platforms, analytics providers, email and communication service providers, and security and fraud detection services. 
      • Affiliates: The Company may share Personal Data with its corporate affiliates, subsidiaries, and related entities for the purposes described in this Policy, subject to data processing agreements.
      • Professional Advisors: Attorneys, auditors, accountants, and other professional advisors retained by the Company, to the extent necessary for the provision of professional services.
      • Law Enforcement and Regulatory Authorities: Where disclosure is required by Applicable Law, regulation, legal process (such as court order, subpoena), or governmental request, or where the Company reasonably believes disclosure is necessary to: (i) comply with a legal obligation; (ii) protect the safety, rights, or property of the Company, its Users, or the public; (iii) detect, prevent, or address fraud, security, or technical issues; or (iv) respond to an emergency.
      • Business Transfer Recipients: In connection with any merger, acquisition, reorganization, asset sale, financing, or similar corporate transaction involving the Company, Personal Data may be disclosed to the acquiring or surviving entity, subject to the acquirer's assumption of the obligations set forth in this Policy.
      • Public Blockchain Disclosure: Users acknowledge that certain data associated with on-chain transactions — including wallet addresses, transaction amounts, timestamps, and Smart Contract interactions — is inherently public and permanently recorded on blockchain networks. This disclosure is a structural feature of blockchain technology and is not within the Company's control. The Company does not publicly associate User identity information with wallet addresses, except as may be required by Applicable Law or valid legal process.
      • Aggregated and De-Identified Data: The Company may share aggregated, anonymized, or de-identified data that cannot reasonably be used to identify any individual, for any purpose including research, analytics, benchmarking, and business development. Such data is not subject to the restrictions of this Policy.
      • No Sale of Personal Data: The Company does not sell Personal Data to third parties within the meaning of Applicable Data Protection Law. If the Company's data practices change in this respect, this Policy will be updated accordingly and Users will be notified.
  • INTERNATIONAL DATA TRANSFERS
    • Transfer Jurisdictions: The Company is incorporated in the Republic of Panama. Personal Data collected through the Platform may be transferred to, stored in, and processed in jurisdictions outside the User's country of residence, including jurisdictions that may not provide the same level of data protection as the User's home jurisdiction. By using the Platform, each User acknowledges and consents to such transfers.
    • Transfer Safeguards: Where Personal Data is transferred to a jurisdiction that has not been recognized as providing an adequate level of data protection under Applicable Data Protection Law, the Company may implement appropriate safeguards.
    • Adequacy Requests: Users may request information regarding the specific transfer mechanisms applied to their Personal Data by contacting the Company at team@legend.trade.
  • DATA SECURITY
    • Security Measures: The Company implements appropriate technical and organizational measures designed to protect Personal Data against unauthorized access, accidental loss, destruction, alteration, disclosure, or misuse. These measures include, as applicable:
      • Encryption of Personal Data in transit (TLS/SSL) and at rest;
      • Access controls, authentication mechanisms, and role-based permissions;
      • Regular security assessments, vulnerability testing, and penetration testing.
      • Logging, monitoring, and anomaly detection systems;
      • Incident response and breach notification procedures;
      • Employee and contractor security awareness training; and
      • Contractual security obligations imposed on third parties and service providers.
    • No Absolute Guarantee: While the Company endeavors to implement industry-appropriate security measures, no method of transmission over the internet or method of electronic storage is completely secure. The Company cannot guarantee the absolute security of Personal Data. Users transmit data to the Platform at their own risk.
    • Breach Notification: In the event of a Personal Data breach that is likely to result in a risk to the rights and freedoms of affected Users, the Company shall notify the competent supervisory authority and, where required by Applicable Data Protection Law, the affected Users, in accordance with the timelines and procedures mandated by Applicable Data Protection Law.
  • THIRD-PARTY COOKIES LINKS AND SERVICES
  • The Platform may contain links to, or integrations with, third-party websites, services, Decentralized Protocols, and applications. This Policy does not apply to the data practices of such third parties. The Company is not responsible for the privacy practices, content, or security of any third-party service. Users are encouraged to review the privacy policies of any third-party service before providing Personal Data or interacting with such service.
  • Some content or applications on the the Platforms may be served by third parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about the User when they access or use the Platform. The information they collect may be associated with the User’s personal information or they may collect information, including personal information, about their online activities over time and across different websites and services. They may use this information to provide the User with behavioral advertising or other targeted content. 
  • The Company does not control the technology of these third parties or how they may be used. If the User have any queries or concerns about an advertisement or other targeted content, they should contact the responsible provider directly.
  • COOKIES AND TRACKING TECHNOLOGIES

The Company uses cookies and similar tracking technologies in connection with the Platform. Detailed information regarding the types of cookies used, their purposes, and User choices is set forth in the Company's Cookie Policy, available at /privacy/cookies and incorporated herein by reference. To the extent cookies collect or process Personal Data, such processing is governed by this Policy.

  • DO NOT TRACK AND OPT-OUT SIGNALS

“Do Not Track” is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Various browsers offer a Do Not Track option that allows a user to set a preference in the browser to not have their online activities tracked. When a user’s browser is set to Do Not Track, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to Do Not Track browser settings. If that occurs, the website visited will not recognize the User upon return to that website or save the User’s passwords or usernames, and some other features of that website may become unavailable or not function correctly.

Given the lack of a standard in the industry or any clear regulatory guidance, the Company may not comply with Do Not Track signals from the User’s browser at this time.

  • AUTOMATED DECISION-MAKING AND PROFILING

The Company may use automated systems in connection with fraud detection, risk scoring, sanctions screening, and jurisdictional compliance. Where automated processing produces legal effects or similarly significantly affects a User, the Company shall, upon request: (a) provide meaningful information about the logic involved; (b) explain the significance and envisaged consequences of such processing; and (c) provide the opportunity for human review of any adverse automated decision, to the extent required by Applicable Data Protection Law.

  • DATA DELETION REQUESTS

The User may request the deletion of personal information by contacting us at team@legend.trade. The Company will consider each request and may comply with such requests at its discretion. 

Please note that the Company reserve the right to retain personal information as permitted or required by law.

  • CHANGES TO THIS POLICY
    • Right to Update: The Company reserves the right to modify or update this Policy at any time, in its sole discretion, to reflect changes in data processing practices, legal requirements, or business operations. Any material changes will be communicated by posting the revised Policy on the Platform with an updated "Last Updated" date
    • Material Changes: Where a material change affects the purposes or lawful bases of processing, expands the categories of Personal Data collected, or introduces new categories of recipients, the Company shall endeavor to provide notice through the Platform, by email, or through other appropriate channels prior to the change taking effect. Where required by Applicable Data Protection Law, the Company shall obtain fresh consent before implementing such changes.
    • Continued Use: Continued access to or use of the Platform following the posting of a revised Policy constitutes acceptance of the revised Policy. Users who do not agree to the revised Policy must immediately discontinue use of the Platform.
  • HOW TO COMPLAIN
    • The User may exercise their rights of access, rectification, cancellation, or opposition concerning their personal data, as well as request the revocation of their consent, by sending a request to us via email at team@legend.trade, providing their full name and address or any other data or document that allows their identification, including a legal document proving ownership, as well as the purpose of their request and/or procedure to be carried out. If the person submitting the request is the parent, mother, or guardian of the personal data owner, they must be accompanied by the minor's birth certificate and/or a legal document proving guardianship. The official identifications accepted by us are; valid Passport, Personal Identity Card, Driver's License, valid immigration document issued by the competent authority. The response time is twenty (20) working days.
    • If the User has any questions or wish to exercise any right related to this privacy statement, please contact team@legend.trade. If the User believes that their right to personal data protection has been violated, as well as ARCO rights, they can also go to the National Authority for Transparency and Access to Information "ANTAI" from the Republic of Panama, whose website is https://www.antai.gob.pa/. 
    • This privacy notice has been created based on the rules issued under Law 81 of 2019 on "Personal Data Protection" and Executive Decree No. 285 of May 28, 2021, which regulates Law 81 of 2019 on Personal Data Protection.
  • GOVERNING LAW

This Policy is governed by and construed in accordance with the substantive laws of the Republic of Panama, without regard to conflict of laws principles. The dispute resolution provisions set forth in the Terms of Service apply to any dispute arising out of or in connection with this Policy.

  • CONTACT INFORMATION

For all inquiries relating to this Policy, the processing of Personal Data, or any other relevant queries, Users may contact the Company as follows:

Many Labs Inc.

Attn: Data Protection

Address: Panama City, Republic of Panama

Email: team@legend.trade

The Company is committed to processing Personal Data lawfully, fairly, and transparently, and to respecting the data protection rights of all Users.

— END OF PRIVACY POLICY —