clusterz.fun
Privacy Policy
1. Who is responsible
Cluster Inc. ("we", "us") is the controller of the personal data processed through clusterz.fun (the "Service"). Contact for privacy questions and requests: privacy@clusterfuk.fun.
We have not yet appointed a representative in the European Union under Article 27 of the GDPR; until we do, contact us directly at that address, and we will add our representative's details here. We have not appointed a data protection officer.
2. What we collect about users
| Data | Where it comes from |
|---|---|
| Account: your account ID and, if you sign in with email, Google or Apple, your email address. If you sign in with X, Discord or a wallet, the profile details stay with our sign-in provider Privy; we receive your account ID and wallet address. | You, through Privy |
| Wallets: the public addresses of your main wallet, your Auto wallets, your rewards wallet and any wallet you link or follow. | You and the Service |
| Trading and settings: your Practice and real trades, positions, balances, profit and loss, Auto and exit settings, follows, lists, filters and preferences. | Your use of the Service and the blockchain |
| Social: your display name, handle, profile picture, posts, reactions, reports you make, who you follow, and share links. | You |
| Rewards and referrals: invite codes, who invited whom, fees paid and rewards and referral earnings. | The Service |
| Technical: IP address, browser and device details, and connection and security logs. | Your device |
| Error reports: errors and start-up problems your browser reports to our servers, with your IP address, browser and screen details, your account ID if you are signed in, and your last actions in the app. Email addresses and secrets are removed first. | Your device |
| Analytics: the screens and buttons you use and, if you are signed in, each Practice or real trade you make (token, size, price, fees, profit or loss, how long you held it, why it closed), failed trades, deposits, withdrawals and rewards you claim. Linked to your account ID. | Your device and our servers, through Mixpanel |
| GIF search: the words you search for in the feed's GIF picker, with an identifier derived from your account (not your email or account ID itself). | You, through KLIPY |
| Messages: what you send us when you contact us. | You |
Public blockchain data. Solana is a public ledger. Wallet addresses, balances and transactions are public and permanent, and anyone with an address can see its whole history. We cannot delete anything from the blockchain.
We do not collect your main wallet's private key. We do hold the keys of your Auto wallets, encrypted, to trade for you (see our Terms, section 4). We do not knowingly collect special categories of data, and we do not sell personal data.
You need an email address, a social login or a wallet to create an account; without one you can browse but not trade. We do not make decisions about you based solely on automated processing that have legal or similarly significant effects on you; Auto trades only under rules you choose.
3. Wallets we track and people we name
The Service tracks public Solana wallets, including those of traders who do not use the Service. For some of them we show a public name, picture, X or Telegram handle and public posts, taken from public sources such as kolscan.io, X, FomoScan, Nansen and GMGN. We also score their trading, and AI models may summarize it. We do this in our legitimate interest in showing users public market activity. If a wallet is yours, you can object at privacy@clusterfuk.fun and we will remove your name, handle and picture unless we have compelling grounds to keep them.
4. Why we use it
- To provide the Service: your account, wallets, trading, Auto, rewards, referrals and social features (to perform our contract with you).
- To keep it safe and lawful: sign-in, fraud and abuse prevention, rate limiting, enforcing our Terms, and, where we do so, checking locations, wallets and transactions against sanctions rules (our legitimate interests in protecting users and the Service and in complying with laws that apply to us; legal obligation where EU or UK law requires it).
- To understand and improve it: analytics and error reports (our legitimate interest in understanding use and fixing faults; where the law requires your consent for storing data in your browser, your consent).
- To comply with law: record keeping and responding to lawful requests (legal obligation where EU or UK law requires it; otherwise our legitimate interest in complying with laws that apply to us).
- To talk to you: answering your messages and telling you about changes to the Service or these documents (contract and legitimate interests).
5. Who we share it with
Service providers that process data for us, under contract and only for these purposes:
| Provider | What for |
|---|---|
| Privy | Sign-in and embedded wallets. Privy's software includes WalletConnect (Reown) and Coinbase Wallet components for connecting external wallets, and Cloudflare Turnstile for bot protection at sign-in. |
| Vercel | Hosting the website and app |
| Infomaniak (Switzerland) | Hosting our servers, databases and logs |
| Mixpanel | Analytics (stored in the European Union) |
| Google Fonts | Serving a font to your browser (receives your IP address) |
| KLIPY | GIF search in the feed |
| wsrv.nl | Resizing token logos and public profile pictures (receives image addresses only) |
| Carbium, Jupiter, Helius, Birdeye, DexScreener, GeckoTerminal, Jito | Blockchain data, quotes, trade routing and sending transactions (they receive wallet and token addresses and transactions, not your account details) |
| X, kolscan.io, FomoScan, Nansen, GMGN | Public profiles, posts, labels and market data about tracked wallets (we send wallet and token addresses, not your account details) |
| Anthropic, xAI | AI analysis of tokens, wallets and market activity, including public names and posts of tracked traders (we do not send them your account details) |
Our staff can look up accounts by email, handle or wallet in our back office, to support users, keep the Service safe and meet legal duties.
What others can see. Your posts, public profile and share links are visible to other users and the public. When you share, sites such as X, Telegram and Discord fetch the shared page to show a preview. Your realized profit and loss, in Practice and with real money, appears on leaderboards under your handle or an anonymous alias. If you post under a handle, other users can follow you without asking you; while you trade with real money, your followers see your trading wallet's address and your trades, labeled with your handle.
We may also disclose data where the law requires it, to protect rights and safety, or to a buyer or successor of our business, who will be bound by this policy.
6. International transfers
Our servers are in Switzerland and our analytics are stored in the European Union. Some providers, including Privy, Vercel, Google, Anthropic and xAI, process data in the United States. For data from the European Union, the United Kingdom or Switzerland, we rely on adequacy decisions (including the EU-US Data Privacy Framework for certified providers) or standard contractual clauses. Ask us at privacy@clusterfuk.fun for a copy.
7. How long we keep it
- Account, wallet, settings and social data: while your account is open. When you ask us to delete your account, we delete or anonymize it within 30 days, except the records below. Deleted data can remain in backups for up to 14 days.
- Trade, fee, reward and referral records: up to 5 years after the trade, for accounting, tax, legal or dispute purposes, and longer where the law requires it or a dispute or investigation is open.
- Share links and leaderboard entries: until you ask us to delete them or your account.
- Server logs and error reports: up to 30 days, longer only while we investigate an incident.
- Analytics: up to 24 months. When you delete your account, we ask Mixpanel to delete your data.
- Privy keeps sign-in data under its own policy; when you delete your account we ask Privy to delete your user.
- Public blockchain data cannot be deleted by anyone.
8. Your rights
Depending on where you live, you may have the right to access your data, correct it, delete it, receive a copy in a portable format, restrict its use, and withdraw consent at any time (without affecting earlier processing). To use these rights, email privacy@clusterfuk.fun from the address or account you use with us. We will answer within the time the law requires, usually one month. You can also complain to your data protection authority.
Your right to object. Where we rely on legitimate interests (analytics, security, and showing wallets and public profiles), you can object at any time at privacy@clusterfuk.fun. We will stop unless we have compelling legitimate grounds or need the data for legal claims.
9. Cookies, local storage and Do Not Track
We store your sign-in session and settings in your browser (local storage and similar); the Service needs these to work. Our analytics provider, Mixpanel, also stores a random identifier in your browser's local storage, which the Service does not need. If your browser sends Do Not Track or Global Privacy Control, we do not load Mixpanel in your browser, but our servers still send the trade events described in section 2 for signed-in users; email us to stop this. The page loads a font from Google Fonts, which gives Google your IP address. We do not use advertising cookies, we do not let third parties track you across other websites through the Service, and we do not sell personal data or share it for cross-context behavioral advertising.
10. Security
We use encryption in transit, encryption at rest for Auto wallet keys, access controls and monitoring. No system is perfectly secure. If a breach is likely to put you at risk, we will tell you and the authorities as the law requires. Tell us at privacy@clusterfuk.fun if you believe your account is at risk.
11. Children
The Service is not for anyone under 18, and we do not knowingly collect their data. If we learn that someone under 18 has an account, we will close it and delete their data.
12. Users in the United States and the United Kingdom
The Service is not intended for anyone located in or resident in the United States or the United Kingdom (see our Terms, section 2).
13. Changes
We may update this policy. We will show the new date at the top and, for material changes, tell you in the Service, and by email if we have your address, before they take effect.