Privacy policy

Acepyr Legal

Version v2.1 · Effective August 18, 2026

Acepyr, Inc. ("Acepyr," "we," "us," or "our") operates the Acepyr platform (acepyr.com), the Acepyr Discord community, and related services (the "Platform"). This Privacy Policy explains what information we collect during the testnet phase, why we collect it, how we use it, who we share it with, and what rights you have over it. It consolidates and replaces all prior Acepyr privacy policies, and it includes our full vendor (subprocessor) list in §11.

1. Who we are

Acepyr, Inc., a Delaware C-Corporation. EIN 41-5028866. Principal office: 90 John Street #1807, New York, NY 10038-3202.

For data protection purposes, Acepyr is the controller of the personal information described here.

Privacy contact: [email protected]

2. Scope

This Policy covers the Acepyr platform (acepyr.com), the Acepyr Discord community, and related services (the "Platform"), during the testnet phase.

The Platform is open to international users, subject only to the sanctions exclusions in the Terms of Service (§3.2). Where GDPR, UK data protection law, CCPA/CPRA, or other data protection law applies to you, it applies, and we honor the rights it gives you (§9).

3. What we collect

3.1 You give us

3.2 We observe

3.3 We do not collect

• Payment card numbers or bank details. (Testnet $ACEPYR cannot be purchased; see the Terms of Service §2.4.)
• Government ID, biometrics, or precise geolocation.
• Private keys or seed phrases. We will never ask.
• Discord direct messages.
• Special-category data (health, biometrics, political opinions, religious beliefs, sex life, or sexual orientation), except where you volunteer it in a demographic field; see §4.3.

4. Demographic information

4.1 What we ask, and when. If you choose to link a blockchain wallet, we ask a short set of questions about your background first: preferred language, age bracket, country of residence, years in crypto, and which chains you use. You can also answer, change, or delete them at any time in account settings.

We do not ask these at signup. You can create an account and use the Platform without ever seeing them.

4.2 The wallet link is optional, and answering is how you complete it.

You do not need a wallet to use Acepyr. Markets, predictions, scoring, and your testnet $ACEPYR balance all work without one (Wallet Consent §1). If you never link a wallet, we never ask.

Answering is how you complete the wallet link, so declining costs you nothing except that optional flow. If you begin a wallet link and do not answer, the link does not complete; nothing else about your account changes.

Declining does not block account creation, does not reduce your testnet $ACEPYR earning rate, and does not affect tournament eligibility or your ability to be paid a prize. Tournament prizes can be delivered to a mailing address or a wallet (Official rules §7); a wallet is never required to win or be paid.

You may change or delete your answers at any time in account settings.

4.3 Sensitive fields. Some demographic categories are treated as sensitive under some laws. Where we ask anything in that class, the field is separately optional, marked as such, and never required. If you'd rather not say, don't.

4.4 Why we ask. Demographics let us understand how different kinds of people reason and forecast (the core research question of the Platform) and let us tell whether our trait models behave fairly across groups. This is Acepyr's own research, for Acepyr's own product.

4.5 Lawful basis: your consent (GDPR Art. 6(1)(a)). You give it by answering; you withdraw it by clearing your answers in settings or emailing [email protected]. Because linking a wallet is optional and declining costs you nothing you need, this consent is freely given, and withdrawal costs you nothing.

4.6 What we never do with it. We do not sell it. We do not license it. We do not share it with third parties for their own purposes. We do not use it for advertising, and we do not build advertising profiles.

5. How we use your information

We use personal information to:

1. Operate the Platform: your account, markets, balances, scoring, notifications.
2. Compute trait scores from your behavioral signals.
3. Conduct Acepyr's own research: understanding how people reason, forecast, and decide; developing and evaluating our models. In-house, for our own product.
4. Secure the Platform: fraud, abuse, multi-accounting, and sanctions enforcement.
5. Communicate: service notices, security alerts, and (if you opt in) product updates.
6. Comply with law.

We do not use your information for advertising, and we do not build advertising profiles.

5.1 Automated processing and profiling

The Platform computes trait scores from your behavior automatically. These scores affect your Platform experience: rankings, features, and standing.

They do not produce legal or similarly significant effects about you, and they are not used to make decisions about your employment, credit, insurance, housing, or access to essential services. You may request an explanation of the logic and purpose (§9), and you may opt out of profiling for purposes beyond operating the Platform.

6. What we do not do: the commitment

This section states the change from every prior version of this Policy.

• We do not sell your personal information. Not now, not in any tier, not to anyone.
• We do not license, rent, or otherwise make your data available to third parties for their own purposes.
• We do not run an enterprise data-licensing program. Any prior document describing one, including a Data Use Agreement, is withdrawn and does not apply to you.
• Your earning rate is not coupled to any data permission. There is no opt-out that costs you points, because there is nothing to opt out of.
• We do not share your wallet address with buyers, marketers, ad networks, or data brokers. See Wallet Consent.

Your data is used by Acepyr, for Acepyr. Full stop.

If that ever changes, it would require a new version of this Policy, advance notice, and (for any use requiring it) your separate, freely-given, opt-in consent. It would never be applied retroactively to data collected under this Policy.

7. Cookies

Your session: acepyr_session. Signing in sets it. It holds a session token and nothing else, it is scoped to acepyr.com with SameSite=Lax, and it is deleted when you log out. Your browser writes and clears it as part of signing in and out; our servers read it to recognize you, and clear it on logout. It is strictly necessary to provide a service you asked for.

Analytics and error monitoring. Our product-analytics and error-monitoring tools, PostHog and Sentry (both listed in §11), record how the Platform is used and set their own first-party cookies (PostHog's are named ph_*) to recognize a returning browser.

We do not use advertising cookies, tracking pixels, ad networks, or cross-site trackers. We do not sell or share what these tools collect, and we do not build advertising profiles.

8. Who we share with

We share personal information only with:

1. Vendors who process it for us, under contract, on our instructions, for no purpose of their own (§11).
2. Legal: where required by law, subpoena, or court order, or to protect rights, safety, or property.
3. Corporate transaction: in a merger, acquisition, or asset sale, a successor may receive it, bound by commitments no weaker than this Policy. We will notify you before it becomes subject to a different policy.

That's the whole list. No buyers. No brokers. No advertisers.

9. Your rights

These rights apply to you, wherever you are. Where a law gives you more, that law wins.

How. Use Data Privacy in account settings, or email [email protected] with enough detail to verify your identity (account email, Discord ID, or wallet address).

When. We acknowledge within 10 days and respond within 30 days (45 under CCPA, extendable by a further 45 with notice).

Complaints. If you're in the EU/EEA or UK, you may lodge a complaint with your supervisory authority. We'd rather you told us first: [email protected].

No fee, unless a request is manifestly unfounded or excessive.

10. Retention

De-identification is not deletion. Where we say de-identified, we mean direct identifiers are severed and we do not attempt re-identification.

11. Vendors (subprocessors)

These vendors process personal information on our behalf, under contract, for no purpose of their own. This section replaces the standalone Subprocessors page.

Public blockchain nodes. Checking a linked wallet's public on-chain history or balances means asking a blockchain node for public data about that address. Those requests carry the wallet address and nothing else about you, and the data they return is already public on the chain.

Platforms you separately use are not our processors; your relationship with them is governed by their terms:

12. International transfers

Acepyr is based in the United States and our vendors process data there. If you are outside the US, your personal information is transferred to and processed in the US, which may not offer equivalent protection to your home jurisdiction.

Where required, we rely on appropriate safeguards, including Standard Contractual Clauses with vendors, and you may request a copy of the relevant safeguard from [email protected].

13. Security

We protect personal information with encryption in transit and at rest, row-level access controls, hashed passwords, audited access, and least-privilege internal access.

No system is perfectly secure. The Platform is a testnet and is provided "AS IS" (see the Terms of Service §2.2). Do not put anything on it you could not bear to lose or see exposed.

If a breach affects your personal information, we will notify you and the relevant authority as required by law.

14. Children

The Platform is for 18 and over. We do not knowingly collect information from anyone under 18. If we learn we have, we delete it. If you believe a minor has given us information, email [email protected].

15. Changes

We may update this Policy. Material changes will be notified by email and/or in-Platform notice at least 15 days before taking effect.

We will never apply a materially different data use retroactively to information collected under this Policy. If we ever wanted to use your data in a way §6 rules out, that would require a new Policy version, advance notice, and (where required) your fresh opt-in consent.

Each version is published with its own effective date. We do not edit a published version in place.

16. Contact

Acepyr, Inc. 90 John Street #1807, New York, NY 10038-3202