We at ParlayX Inc. (“ParlayX”) are committed to protecting your privacy. This Privacy Policy applies to the personal information and data collected by ParlayX when you interact with our website, the ParlayX Platform, or any other services provided by ParlayX.
This Privacy Policy describes how we collect, receive, use, store, share, transfer, and process your Personal Data. This Privacy Policy also describes your choices and rights with respect to your Personal Data, including your rights of access and correction of your Personal Data. For the purposes of this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable individual. If you do not agree with this Privacy Policy, you should not use our website or services.
We update this Privacy Policy from time to time, and we encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email notification. Terms not otherwise defined in this Privacy Policy will have the meanings set forth in the ParlayX Terms of Service.
If you have any questions about this Privacy Policy or wish to exercise the privacy rights and choices we offer, please contact us at support@parlayx.com.
Information We Collect About You
Information You Provide to ParlayX
We collect your email address, name, organization or role information, and wallet address (including your Dynamic-managed wallet and any external withdrawal addresses you provide) when you access and use the ParlayX Platform. If you connect a third-party trading venue account, we also collect the credentials for that account, such as API keys. We may also collect other Personal Data you provide when using our website or contacting us, for example, when requesting customer support or communicating with our team.
b. Information We Collect When You Use our Services
Log and Connection Data. When you visit our website or use the ParlayX Platform, we automatically collect certain technical information. This may include your IP address, browser type, domain names, internet service provider, operating system, referring website addresses, access times, and streaming gateway connection identifiers. This information is used for security, debugging, and operational purposes.
Usage and Trading Data. When you interact with the ParlayX Platform through your account or API key, we collect usage and trading data. This includes API usage and metering data (such as request volume and token consumption tied to your API key), as well as trading activity data (such as orders, fills, transfers, and positions). We may engage service providers to assist with collecting and analyzing usage data, and we share such data with those providers only as necessary to operate and improve the Platform. Usage data helps us understand how the Platform is being used, monitor system performance, and support billing and accounting.
How We Use Personal Data
To Provide Access to the ParlayX Platform
We use your account information and Personal Data to provide the ParlayX Platform and services to you. For example, we use your email address to deliver one-time passcode authentication, account identification, and transactional notices. We use your wallet address to route and execute trades and on-chain transfers on your behalf. Your API key and associated usage data are used for authentication, usage metering, and billing. Trade, order, and transfer data are used to provide the service, including position and P&L views, accounting, and record-keeping.
b. To Improve and Develop Our Products and Services
We collect usage data about how you interact with our Platform and services. We use this data to develop and improve our products and services, monitor system performance, and support service-level obligations. For example, we use aggregate operational metrics and usage patterns to assess trends, detect anomalies, and determine what features or improvements may benefit our users.
We may publish data about how our Platform and services are being used across our customer base. When we share statistical information externally in this way, the data will be aggregated and we will not identify individual users.
c. To Secure and Protect Our ParlayX Platform Users
We use your account information to investigate and help prevent security incidents. We may also use this information to meet legal requirements. We use your information to verify user accounts and API key provisioning, and to detect and prevent platform abuse.
We use log and connection data to provide general statistics regarding use of our website and Platform, including how you access our services and to help improve your experience. IP addresses are collected and logged for security and session audit purposes, for example to track access patterns and investigate security events. For these purposes we may link automatically-collected data to other Personal Data provided by you.
d. Legal Bases for Processing (EEA, Switzerland, and United Kingdom Users)
If you are in the European Economic Area (EEA), Switzerland, or the United Kingdom, we rely on the following legal bases under applicable data protection law to process your Personal Data:
Performance of a contract: We process your account information (including email address and wallet address), authentication credentials, and trading and transaction data as necessary to enter into and perform our contract with you to provide the Platform.
Legitimate interests: We process usage and API data, log and connection data, and security information on the basis of our legitimate interests in operating, improving, and securing the Platform, preventing fraud and abuse, and supporting our business operations.
Compliance with legal obligations: We may process and retain Personal Data where necessary to comply with applicable laws and regulations or to respond to lawful requests from competent authorities.
Consent: Where we rely on consent as a legal basis — for example, for non-essential cookies — you may withdraw your consent at any time by contacting us at support@parlayx.com or adjusting your browser settings. Withdrawal of consent does not affect the lawfulness of processing conducted before withdrawal.
How We Share Personal Data
Service Providers
We may share Personal Data with our third-party service providers to support our website and services. These providers assist us with functions such as cloud hosting and storage, email delivery, CDN and network infrastructure, monitoring and alerting, sports data, non-custodial wallet management and signing, on-chain trade routing and bridge aggregation for asset transfers, and related operational services. We share only the information necessary for each provider to perform its function, and these providers are prohibited from using your Personal Data for purposes other than those for which it was disclosed. They are required to maintain the confidentiality and security of your information. As ParlayX grows, we may engage additional or different service providers; however, any such providers will be held to the same standards described here.
b. Trading Venues
When you place an order, we transmit order, fill, and position data to the trading venue or exchange you selected, under your account with that venue. Each venue processes that data under its own privacy policy.
c. Compelled Disclosure
We reserve the right to use or disclose your Personal Data if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
How We Transfer Personal Data Internationally
Our Platform infrastructure is hosted on servers located primarily in the United States. If you are in the EEA, Switzerland, or the United Kingdom, your Personal Data is transferred to the United States. When we share or transfer Personal Data of individuals in the EEA, Switzerland, or the UK with third parties or across borders, we use a variety of legal mechanisms to safeguard the transfer, including the European Commission-approved Data Privacy Framework or Standard Contractual Clauses where applicable. Please contact us if you need more information about the legal mechanisms we rely on to transfer Personal Data internationally.
How We Store and Secure Personal Data
Data Storage and Security
We use a variety of security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Our Platform is hosted in a controlled, secure cloud environment. We employ measures including encryption of data in transit (via TLS), hashed and encrypted storage of sensitive credentials, short-lived authentication sessions, role-based access controls, and least-privilege database credentials. ParlayX operates a non-custodial model and does not take custody of funds in your wallet or your venue accounts.
b. Retention of Personal Data
We retain Personal Data for as long as your account remains active and for a period that varies by data category: (i) account and authentication data (such as email address and wallet address) is retained for the duration of your account plus three (3) years following account closure; (ii) trading and transaction records are retained for seven (7) years to support financial record-keeping, regulatory compliance, and dispute resolution; (iii) usage and API data is retained for up to twenty-four (24) months; and (iv) log and connection data is retained for up to twelve (12) months for security and audit purposes. After the applicable retention period, we will delete or anonymize your Personal Data. If immediate deletion is not technically feasible, we will securely store your information and isolate it from further use until deletion is possible.
We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes, and enforce our agreements).
Data Privacy On-Chain
The nature of trading and transacting in digital assets through the ParlayX Platform inherently means that some of your information may be recorded on the blockchain and available for the public to see. This includes your wallet address, transaction history, token balances, and other metadata associated with on-chain activity. By using our website or the ParlayX Platform, you acknowledge that on-chain activity is inherently public and outside the scope of this Privacy Policy.
Cookies
Technologies such as cookies may be used by ParlayX and our analytics and service providers.
What are cookies?
A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information.
Cookies provide a convenience feature to save you time or tell the web server that you have returned to a specific page.
Cookies set by the website owner (in this case, ParlayX) are called “first-party cookies”. Cookies set by parties other than the website owner are called “third-party cookies”. Third-party cookies enable third-party features or functionality to be provided on or through the website (e.g. interactive content and analytics). The parties that set these third-party cookies can recognize your computer both when it visits the website in question and also when it visits certain other websites.
b. Why do we use cookies?
We use first-party and third-party cookies for several reasons. Some cookies are required for technical reasons in order for our website to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our website. For example, ParlayX keeps track of the pages you visit to determine what portion of the website or services is the most popular or most used. This data is used to analyze trends, administer the website, monitor how visitors navigate around the website, and to gather demographic information about our user base as a whole.
c. What types of cookies do we use and how do we use them?
The specific types of first- and third-party cookies served through our website include:
Essential website cookies: These cookies are strictly necessary to provide you with services available through our website.
Performance and functionality cookies: These cookies are used to enhance the performance and functionality of our website but are non-essential to their use.
Analytics and customization cookies: These cookies collect information that is used either in aggregate form to help us understand how our website is being used or to help us customize our website for you.
d. How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by adjusting your web browser settings, as described below, or by contacting us at support@parlayx.com.
You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website, though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser to browser, you should visit your browser’s help menu for more information.
In addition, most advertising networks offer you a way to opt out of targeted advertising. To learn more, please visit http://www.aboutads.info/choices/. You may opt out by clicking here: http://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
Your Privacy Rights and Choices
You have the following data protection rights:
Access, Correction or Deletion. You can request access, correction, updates or deletion of your Personal Data.
Objection. You can object to our processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
Withdraw Consent. If we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
Complaint. You have the right to complain to a competent data protection supervisory authority about our collection and use of your Personal Data. If you are located in the EEA or Switzerland, contact details for supervisory authorities are available at https://edpb.europa.eu/about-edpb/about-edpb/members_en. If you are located in the United Kingdom, you may contact the Information Commissioner’s Office at https://ico.org.uk/make-a-complaint/.
We do not sell personal information.
To exercise any of these rights, please email support@parlayx.com.
Please note that to protect personal information, we may verify your identity by a method appropriate to the type of request you are making. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws.
We will respond to your request to change, correct, or delete your data within a reasonable timeframe and notify you of the action we have taken. In some instances, your rights may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights.
California Privacy Rights
Applicability
This section is provided for informational purposes regarding California consumer privacy rights. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act (“CCPA”). ParlayX does not currently meet the revenue, data volume, or other thresholds that would require compliance with the CCPA as a “business” subject to that law. Nevertheless, ParlayX does not sell Personal Information to any third party, and we only share Personal Information with authorized service providers who have agreed to contractual limitations on their retention, use, and disclosure of such Personal Information. If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format.
b. How We Collect, Use, and Share Your Personal Information
In the process of providing our website, the ParlayX Platform, or any other services, ParlayX may collect the following categories of Personal Information:
Identifiers, such as name, email address, and blockchain wallet address (including Dynamic-managed wallets and external withdrawal addresses), and credentials for third-party trading venue accounts you connect. We collect this information directly from you.
Commercial information, such as account and subscription records. We collect this information directly from you.
Internet or network activity information, such as API usage and metering data, connection logs, and Platform interaction data. We collect this information from your device and through your use of the Platform.
Geolocation data, such as general location inferred from IP address. We collect this information from your device.
Financial information, such as trading activity, positions, and transaction records generated through use of the Platform. We collect this information through your use of the service.
Inferences, such as predictions about your usage preferences and trading behavior, derived from usage and trading activity data collected through the Platform.
Other Personal Information, in instances when you interact with us online, by phone, or by email in the context of receiving support or other assistance.
The business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy. The categories of third parties to whom we disclose this information for a business purpose are described in Section 3 of this Privacy Policy. The period of time for which we retain this information is described in Section 5 of this Privacy Policy.
c. Your California Rights
You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law.
The right of access means that you have the right to request that we disclose what Personal Information we have collected, used and disclosed about you in the past 12 months.
The right of deletion means that you have the right to request that we delete Personal Information collected or maintained by us, subject to certain exceptions.
The right of correction means that you have the right to request that we correct any inaccurate personal information that we maintain about you.
The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.
ParlayX does not sell or share Personal Information with third parties (pursuant to California Civil Code §§ 1798.100–1798.199, also known as the California Consumer Privacy Act of 2018).
d. How to Exercise Your California Rights
You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Information, we will verify your identity by a method appropriate to the type of request you are making. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent’s identity to protect your Personal Information.
Please use the contact details below, or see Section 8 “Your Privacy Rights and Choices” above, if you would like to:
Access this policy in an alternative format;
Exercise your rights;
Learn more about your rights or our privacy practices; or
Designate an authorized agent to make a request on your behalf.
Other Important Privacy Information
We Never Sell Personal Data
We will never sell your Personal Data to any third party.
b. Information About Children
The website, Platform, and services are not intended for or targeted at children under 18, and we do not knowingly or intentionally collect Personal Data about children under 18. If you believe that we have collected Personal Data about a child under 18, please contact us at support@parlayx.com so that we may delete the information.