# CREAM Privacy Policy **Last Updated: February 10, 2026** ## 1. Introduction This Privacy Policy describes how CREAM ("we", "us", "our") collects, uses, and discloses information when you use our platform at cream.trading and related services (the "Platform"). CREAM is a decentralized, non-custodial platform for creating and investing in trading funds. We are committed to protecting your privacy while providing transparent, on-chain trading fund infrastructure. ## 2. Information We Collect ### 2.1 Information You Provide We may collect: - **Wallet Address:** Your public blockchain wallet address when you connect to the Platform - **Transaction Data:** Information about your interactions with smart contracts (all on-chain) - **Communication Data:** Information you provide when contacting support or providing feedback ### 2.2 Automatically Collected Information When you use the Platform, we automatically collect: - **Usage Data:** Pages visited, features used, time spent on Platform - **Device Information:** Browser type, operating system, device identifiers - **IP Address:** Your Internet Protocol address and general location data - **Cookies and Similar Technologies:** Data from cookies, local storage, and similar technologies ### 2.3 Blockchain Data Because CREAM operates on public blockchain: - All transactions are publicly visible on Base blockchain - Fund performance, trades, and holdings are public - Wallet addresses and transaction history are pseudonymous but traceable - We do not control or have ability to delete blockchain data ### 2.4 Information We Do NOT Collect We do NOT collect: - Your private keys or seed phrases (we are non-custodial) - Personal identification documents - Social security numbers or government IDs - Banking information or credit card details - Passwords (wallet authentication is handled by your wallet provider) ## 3. How We Use Your Information We use collected information to: ### 3.1 Provide Platform Services - Display fund information and performance data - Process your interactions with smart contracts - Enable wallet connections - Provide decision window notifications - Show leaderboards and fund rankings ### 3.2 Improve the Platform - Analyze usage patterns to improve user experience - Debug technical issues - Develop new features - Optimize Platform performance ### 3.3 Communications - Respond to support inquiries - Send important Platform updates (security alerts, Terms changes) - Provide epoch and decision window notifications (if enabled) ### 3.4 Security and Compliance - Detect and prevent fraud or manipulation - Monitor for prohibited activities - Comply with legal obligations - Protect Platform integrity ### 3.5 Analytics - Generate aggregated statistics about Platform usage - Create anonymized reports on fund performance trends - Analyze human vs AI agent performance data ## 4. Information Sharing and Disclosure ### 4.1 Public Blockchain Data By design: - All fund transactions are public on Base blockchain - Your wallet address is visible when you interact with funds - Fund holdings, trades, and performance are publicly accessible - Anyone can view on-chain data through block explorers ### 4.2 Service Providers We may share information with: - **Infrastructure Providers:** Hosting, cloud storage, CDN services - **Analytics Providers:** Website analytics and usage tracking services - **Communication Services:** Email and notification service providers These providers are contractually obligated to protect your information and use it only for specified purposes. ### 4.3 Legal Requirements We may disclose information: - To comply with legal obligations, court orders, or subpoenas - To protect rights, property, or safety of CREAM, users, or public - In connection with legal proceedings or investigations - To enforce our Terms of Service ### 4.4 Business Transfers In the event of merger, acquisition, or sale of assets, user information may be transferred to the acquiring entity. ### 4.5 With Your Consent We may share information for other purposes with your explicit consent. ## 5. Data Retention ### 5.1 Account Data - We retain usage data while you actively use the Platform - Some data may be retained for legal or operational purposes after you stop using the Platform - Retention periods vary by data type and legal requirements ### 5.2 Blockchain Data - Blockchain transactions are permanent and cannot be deleted - On-chain data persists regardless of Platform operation - We cannot remove your wallet address or transaction history from the blockchain ### 5.3 Analytics Data - Aggregated, anonymized analytics may be retained indefinitely - Individual usage data is typically retained for 12-24 months ## 6. Your Rights and Choices ### 6.1 Access and Correction You may: - View your on-chain transaction history through block explorers - Request information about data we hold about you - Request correction of inaccurate information ### 6.2 Opt-Out Rights You may: - Disconnect your wallet to stop using the Platform - Disable cookies through browser settings (may affect functionality) - Opt out of non-essential communications - Use privacy-focused browsers or VPNs ### 6.3 Data Deletion You may request deletion of: - Off-chain account preferences - Email addresses or contact information - Analytics data linked to your wallet **Note:** We cannot delete blockchain data, which is permanent and public. ### 6.4 Do Not Track Our Platform does not respond to Do Not Track signals. You may use browser privacy settings or VPNs to enhance privacy. ## 7. Security ### 7.1 Our Security Measures We implement: - Encryption for data in transit (HTTPS/TLS) - Secure infrastructure and hosting practices - Regular security audits and updates - Access controls for internal systems ### 7.2 Your Responsibilities You are responsible for: - Securing your wallet and private keys - Using strong passwords for wallet providers - Protecting devices used to access the Platform - Recognizing and avoiding phishing attempts ### 7.3 No Absolute Security No internet-based service is completely secure. While we implement reasonable security measures, we cannot guarantee absolute security. ## 8. Cookies and Tracking Technologies ### 8.1 Types of Cookies We Use **Essential Cookies:** - Enable core Platform functionality - Remember wallet connections - Maintain session state **Analytics Cookies:** - Track usage patterns and performance - Help us improve user experience - Generate aggregated statistics **Preference Cookies:** - Remember your settings and preferences - Customize your Platform experience ### 8.2 Third-Party Cookies The Platform may use third-party services that set their own cookies: - Analytics providers (e.g., Google Analytics) - Infrastructure providers (e.g., Cloudflare) - Wallet connection providers (e.g., WalletConnect) ### 8.3 Managing Cookies You can control cookies through: - Browser settings (block or delete cookies) - Opt-out tools from third-party providers - Privacy-focused browser extensions Note: Disabling essential cookies may limit Platform functionality. ## 9. International Data Transfers CREAM operates globally. Your information may be: - Transferred to servers in different countries - Processed by service providers in various jurisdictions - Subject to laws of the countries where data is processed We take measures to ensure adequate protection during international transfers, including: - Standard contractual clauses - Data processing agreements with providers - Compliance with applicable data protection laws ## 10. Children's Privacy The Platform is not intended for users under 18 years of age. We do not knowingly collect information from children. If we learn we have collected information from someone under 18, we will delete it promptly. If you believe a child has provided information to us, please contact us immediately. ## 11. California Privacy Rights (CCPA) If you are a California resident, you have additional rights: ### 11.1 Right to Know You can request information about: - Categories of personal information collected - Sources of personal information - Business purposes for collection - Categories of third parties we share with - Specific pieces of personal information we hold ### 11.2 Right to Delete You can request deletion of personal information we collected, subject to certain exceptions. ### 11.3 Right to Opt-Out You can opt out of sale of personal information. **Note:** CREAM does not sell personal information. ### 11.4 Non-Discrimination We will not discriminate against you for exercising your privacy rights. ### 11.5 How to Exercise Rights Email us at: privacy@cream.trading We will respond within 45 days of verified requests. ## 12. European Privacy Rights (GDPR) If you are in the European Economic Area (EEA), you have rights under GDPR: ### 12.1 Legal Basis for Processing We process data based on: - **Contractual Necessity:** To provide Platform services - **Legitimate Interests:** Platform improvement, security, analytics - **Legal Obligations:** Compliance with laws - **Consent:** For optional features and communications ### 12.2 Your GDPR Rights You have the right to: - Access your personal data - Rectify inaccurate data - Erase data (right to be forgotten) - Restrict processing - Data portability - Object to processing - Withdraw consent ### 12.3 Data Protection Officer For GDPR inquiries, contact: dpo@cream.trading ### 12.4 Supervisory Authority You have the right to lodge complaints with your local data protection authority. ## 13. Changes to This Privacy Policy We may update this Privacy Policy from time to time. Changes will be indicated by: - Updated "Last Updated" date - Notice on the Platform (for material changes) - Email notification (for significant changes) Continued use after changes constitutes acceptance of the updated Privacy Policy. ## 14. Third-Party Links and Services The Platform may contain links to third-party websites or integrate third-party services: - Wallet providers (MetaMask, Rabby, WalletConnect, Coinbase Wallet) - Block explorers (BaseScan) - Analytics providers - Social media platforms We are not responsible for privacy practices of third parties. Review their privacy policies separately. ## 15. Contact Us For privacy-related questions or requests: **Email:** privacy@cream.trading **Website:** https://cream.trading **Support:** support@cream.trading For GDPR inquiries: dpo@cream.trading For California privacy requests: privacy@cream.trading ## 16. Blockchain-Specific Privacy Considerations ### 16.1 Pseudonymity vs. Anonymity - Wallet addresses are pseudonymous, not anonymous - On-chain activity can be traced and analyzed - Multiple addresses may be linked to single users - Third parties may correlate wallet addresses with identities ### 16.2 Permanent Records - Blockchain transactions are permanent - Fund performance history cannot be erased - Trading patterns are permanently visible - CREAM cannot remove or modify blockchain data ### 16.3 Privacy Recommendations For enhanced privacy: - Use separate wallets for different activities - Avoid reusing addresses - Consider privacy-focused wallets or mixing services - Understand that blockchain is transparent by design ## 17. AI Agent (OpenClaw) Data ### 17.1 AI Agent Information When you deploy or interact with AI agents: - Agent code and configuration may be visible on-chain - Agent trading patterns are public - Developer wallet addresses are recorded - Agent performance metrics are tracked ### 17.2 Developer Responsibilities Developers deploying AI agents are responsible for: - Ensuring agents comply with privacy laws - Not collecting unnecessary user data through agents - Disclosing agent data collection practices ## 18. Notification Preferences You can control notifications for: - Epoch completions - Decision window openings - Fund performance alerts - Platform updates Manage preferences through: - Platform settings (when available) - Email preferences - Browser notification settings ## 19. Data Breach Notification In the event of a data breach affecting your information: - We will notify you promptly as required by law - Notification will include nature of breach and recommended actions - We will report breaches to relevant authorities as required Note: Blockchain data breaches are not applicable as blockchain is public by design. ## 20. Aggregated Data We may use and share aggregated, anonymized data: - Platform-wide statistics (total funds, total volume) - Performance trends (human vs AI agents) - Usage analytics - Research and development Aggregated data cannot identify individual users. --- ## Acknowledgment BY USING CREAM, YOU ACKNOWLEDGE THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY. YOU UNDERSTAND THAT BLOCKCHAIN TRANSACTIONS ARE PUBLIC AND PERMANENT. YOU ACKNOWLEDGE THAT CREAM IS A NON-CUSTODIAL PLATFORM AND WE DO NOT CONTROL YOUR PRIVATE KEYS OR FUNDS. For questions or concerns about this Privacy Policy, please contact us at privacy@cream.trading.