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Privacy Policy

Last updated: 23/05/2026

1. Introduction

This Privacy Policy describes how ContriX Limited, a company incorporated in Hong Kong ("whale.dance," "we," "us," or "our"), collects, uses, and shares information when you use the whale.dance mobile application, website, and related services (the "Services"). By using the Services, you agree to this Policy.

We handle personal data in accordance with the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong ("PDPO") and, where applicable, other data-protection laws.

2. Information We Collect

Because whale.dance is a non-custodial application, we collect as little personal data as practical. We do not collect your private keys, seed phrases, or take custody of your assets.

Information you provide:

  • Contact information (such as an email address or phone number) if you join a waitlist, claim a promotional item, or contact support.
  • Communications you send to us.

Information collected automatically:

  • Public wallet address(es) you connect to the Services.
  • Device and usage data (device type, operating system, app interactions, approximate location derived from IP address) collected via analytics tools.
  • On-chain transaction data associated with a connected wallet, which is publicly available on the blockchain.

Information from third parties:

  • We use third-party providers for fiat on-ramp, analytics, sanctions/AML screening, and infrastructure. When you use a third-party on-ramp provider, that provider collects and processes your payment and identity-verification (KYC) information directly under its own privacy policy; we do not receive or store your full payment or KYC details.

3. How We Use Information

We use information to:

  • provide, operate, and improve the Services;
  • communicate with you, including about waitlists, promotions, and support;
  • monitor, detect, and prevent fraud, abuse, and prohibited activity;
  • screen connected wallet addresses against sanctions and AML risk lists;
  • enforce our Terms and comply with applicable law;
  • apply geographic restrictions on access to the Services.

We use personal data only for the purposes for which it was collected, or a directly related purpose, consistent with the PDPO.

4. How We Share Information

We do not sell your personal data. We share information only:

  • with service providers who perform functions on our behalf (analytics, on-ramp, screening, hosting), under appropriate confidentiality obligations;
  • to comply with law, legal process, or lawful requests by public authorities;
  • to protect the rights, safety, and property of ContriX Limited, our users, or others;
  • in connection with a merger, acquisition, or sale of assets.

Any transaction you make on a public blockchain is, by the nature of the technology, publicly visible and outside our control.

5. Third-Party Services

The Services rely on and may link to third parties, including on-ramp providers, wallet providers, blockchain networks, and analytics tools. Their handling of your information is governed by their own privacy policies. We are not responsible for the privacy practices of any third party.

6. Data Retention

We retain personal data only as long as necessary for the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our agreements.

7. Your Rights

Under the PDPO, you have the right to request access to and correction of your personal data held by us, and to ascertain our policies and practices in relation to personal data. Depending on your location, you may also have rights under other laws (for example, the EU/UK GDPR or the California CCPA/CPRA), including rights to access, correct, delete, or restrict processing, and to object to certain processing.

To exercise any of these rights, contact us at yo@whale.dance. We will respond as required by applicable law.

8. Children's Privacy

The Services are not directed to anyone under 18, and we do not knowingly collect personal data from anyone under 18. If we learn we have collected such data, we will delete it.

9. International Transfers

We may process and store information in locations outside your own jurisdiction, where data-protection laws may differ. Where required, we apply appropriate safeguards for such transfers.

10. Security

We implement reasonable technical and organizational measures to protect personal data. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are solely responsible for safeguarding your own wallet, keys, and credentials.

11. Changes to This Policy

We may update this Policy from time to time. Changes are indicated by the "Last updated" date, and material changes may be communicated through the Services.

12. Contact

Questions about this Policy, or requests to exercise your data rights, may be directed to ContriX Limited at yo@whale.dance, Room D07, 8/F, Phase 2, Kai Tak Factory Building, 99 King Fuk Street, San Po Kong, Kowloon, Hong Kong.