Working draft. Not legal advice and not a contractual guarantee. Luca must have counsel review it before it is treated as final.
Privacy Policy
Last updated: 12 September 2026 · Condy
1. Controller and purpose
This notice describes how Condy handles data for people who create an account or use the site. It is a working draft and must be reviewed by Luca’s counsel before it is a final GDPR notice. For this draft, the controller is the Condy team operating the app at condyapp.com.
2. Data we collect
On Condy we keep, in short:
- Account: email, name, password handled by Supabase Auth.
- Onboarding profile: name, date of birth, address, mobile phone, and optional Telegram. The team uses this to start access on a supported firm. This is not the firm’s KYC file.
- Product use: requested tasks, status, USDC balance, withdrawals, invites.
- Technical: session cookies, security logs, notification preferences.
3. What we do not collect (the firm’s KYC)
The actual KYC: document scan, selfie, AML checks: happens on the supported firm’s platform (today FuturesElite; BlueGuardian and LucidTrading only if unlocked for you). Those files stay encrypted on their systems. They do not come to Condy. We do not receive or store the partner KYC documents. We only send your personal link when it is ready. The firm has its own privacy notice, separate from this one.
4. Why we use the data
To create and protect the account, prepare tasks, credit USDC rewards, handle withdrawals, attribute invites, prevent abuse, and reply to you. Draft legal bases: performing the service you ask for (account, task, withdrawal), legitimate interest (security, anti-fraud), and consent where needed (non-operational messages). Counsel must confirm the bases before a legal go-live.
5. Sharing
The Condy team (and, if needed, an appointed operator) can see the pre-onboarding profile in order to create the KYC link in the firm’s back office. We do not sell lists. Current processors: Supabase (database and auth) and Vercel (hosting). USDC payouts go to the wallet you name; the reward does not pass through a traditional bank.
6. Retention and rights
We keep account, ledger, and audit data while the account is active and for as long as disputes or the law require. You can ask for access, correction, deletion, restriction, or objection by writing to the team from the app. Deleting the account may block a task already in flight. You also have the right to complain to your data-protection authority.
7. Cookies
We use technical session cookies to keep you signed in, and a locale cookie so the language you pick stays selected. This draft does not use third-party advertising cookies on the web app. If we later add analytics that are not strictly necessary, we will say so here.
8. Related documents
The rules for using the service are in the Terms of service. If this draft and the Terms disagree on a product point, the latest description in the app applies until legal review.
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