Privacy Policy

Cozy ("Company," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, website, applications, and services (collectively, the "Platform"). By accessing or using the Platform, you consent to the practices described in this Privacy Policy. If you do not agree with this Policy, please discontinue use of the Platform immediately. This Policy applies to all users of the Platform regardless of location, though certain provisions may apply differently based on your jurisdiction's applicable data protection laws.

We may collect the following categories of information: ACCOUNT INFORMATION: When you create an account, we collect your email address, authentication method (e.g., email, Google, phone number), and associated identifiers. If an embedded wallet is created through our wallet provider (Privy), a public wallet address is generated and associated with your account. We also store your display name, avatar preference, and referral code. TRANSACTION DATA: We record transaction history including swap details, token amounts, wallet addresses, timestamps, and fees. This data is also publicly available on the Solana blockchain. For referral and creator earnings purposes, we track trade volume associated with referred users and tokens created through our Platform. TOKEN CREATION DATA: If you create a token through the Platform, we store the token metadata (name, symbol, description), your creator ID, wallet address, and earnings data. Token images and metadata are uploaded to IPFS and are publicly accessible. USAGE DATA: We automatically collect information about how you interact with the Platform, including pages visited, features used, click patterns, session duration, and navigation paths. DEVICE & TECHNICAL DATA: We collect device type, operating system, browser type and version, IP address, screen resolution, language settings, and timezone. ANALYTICS DATA: We may use cookies, pixels, and similar technologies to collect aggregated analytics about Platform usage and performance. COMMUNICATION DATA: If you contact us, we collect the contents of your messages, your contact information, and any attachments you provide.

We use collected information for the following purposes: SERVICE DELIVERY: To provide, operate, maintain, and improve the Platform and its features, including processing transactions, displaying portfolio data, and delivering market analytics. ACCOUNT MANAGEMENT: To create and manage your account, authenticate your identity, and maintain account security. COMMUNICATION: To respond to inquiries, send service-related notices (such as security alerts and transaction confirmations), and provide customer support. SECURITY & FRAUD PREVENTION: To detect, investigate, and prevent fraudulent transactions, unauthorized access, and other harmful activities. This includes monitoring for suspicious trading patterns and potential platform abuse. ANALYTICS & IMPROVEMENT: To understand how users interact with the Platform, identify usage trends, optimize performance, and develop new features. LEGAL COMPLIANCE: To comply with applicable laws, regulations, legal processes, or governmental requests, including anti-money laundering (AML) and know-your-customer (KYC) requirements where applicable. ENFORCEMENT: To enforce our Terms of Service and protect the rights, property, or safety of Cozy, our users, or the public.

You understand and acknowledge that blockchain transactions are inherently public. When you execute a transaction through the Platform, the following information is recorded on the Solana blockchain and is publicly accessible: • Your wallet address (public key) • Transaction amounts and token types • Transaction timestamps • Smart contract interactions We have no ability to delete, modify, or restrict access to data recorded on public blockchains. This data persists permanently on-chain regardless of whether you delete your account or cease using the Platform. Your wallet address is pseudonymous but may be linked to your identity through your account information or through third-party blockchain analysis services.

We do not sell your personal information. We may share your information in the following circumstances: SERVICE PROVIDERS: We engage trusted third-party companies to perform services on our behalf, including wallet infrastructure (Privy), payment processing (Coinbase), market data (Birdeye), database hosting (Firebase/Google Cloud), RPC infrastructure (Helius), token launch services (pump.fun), and customer support. These providers are contractually obligated to use your information only as necessary to provide services to us and in compliance with this Policy. LEGAL REQUIREMENTS: We may disclose information when we believe in good faith that disclosure is necessary to comply with applicable law, regulation, legal process, or governmental request; protect the rights, property, or safety of Cozy, our users, or the public; detect, prevent, or address fraud, security, or technical issues. BUSINESS TRANSFERS: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change in ownership or control. AGGREGATED DATA: We may share aggregated, anonymized, or de-identified information that cannot reasonably be used to identify you, for purposes such as analytics, research, or marketing. WITH YOUR CONSENT: We may share your information for other purposes with your explicit consent.

We use cookies and similar technologies to enhance your experience on the Platform: ESSENTIAL COOKIES: Required for basic Platform functionality, such as maintaining your session and security preferences. These cannot be disabled. ANALYTICS COOKIES: Help us understand how visitors interact with the Platform by collecting and reporting information anonymously. PREFERENCE COOKIES: Remember your settings and preferences, such as display preferences and language selection. You can manage cookie preferences through your browser settings. Disabling certain cookies may limit Platform functionality. We do not respond to "Do Not Track" signals, as there is no industry-standard interpretation of such signals for web-based cryptocurrency platforms. However, we limit our data collection to what is described in this Policy.

We implement commercially reasonable technical and organizational security measures to protect your information, including: • Encryption of data in transit (TLS/SSL) and at rest • Access controls and authentication requirements for internal systems • Regular security assessments and monitoring • Secure development practices However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to protect your information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and wallet security. In the event of a data breach affecting your personal information, we will notify you and relevant authorities in accordance with applicable law.

We retain your information for as long as your account is active or as needed to provide you with Services. We may also retain information as necessary to comply with legal obligations, resolve disputes, enforce agreements, and as permitted by applicable law. Upon account deletion, we will delete or anonymize your personal information within 90 days, except where retention is required by law or necessary for legitimate business purposes (such as fraud prevention or financial record-keeping). Transaction data recorded on the blockchain cannot be deleted as it is permanently stored on the distributed ledger.

Depending on your jurisdiction, you may have the following rights regarding your personal information: ACCESS: Request a copy of the personal information we hold about you. CORRECTION: Request correction of inaccurate or incomplete information. DELETION: Request deletion of your personal information, subject to legal retention requirements. PORTABILITY: Request a machine-readable copy of your data. OBJECTION: Object to certain processing of your personal information. RESTRICTION: Request that we limit how we use your data. WITHDRAWAL OF CONSENT: Withdraw consent where processing is based on consent, without affecting the lawfulness of prior processing. To exercise any of these rights, contact us at privacy@cozy.trade. We will respond within 30 days (or the timeframe required by your jurisdiction's applicable law). CALIFORNIA RESIDENTS: Under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA), you have additional rights including the right to know what personal information is collected, the right to opt-out of the sale of personal information (we do not sell personal information), and the right to non-discrimination for exercising your rights. EEA/UK RESIDENTS: If you are located in the European Economic Area or United Kingdom, we process your data under GDPR lawful bases including consent, contract performance, legitimate interests, and legal obligations. You may lodge a complaint with your local supervisory authority.

Your information may be transferred to and processed in countries other than your country of residence, including the United States. These countries may have data protection laws that differ from your jurisdiction. Where required by law, we implement appropriate safeguards for international transfers, such as Standard Contractual Clauses approved by relevant authorities, or rely on adequacy decisions. By using the Platform, you consent to the transfer of your information as described in this Policy.

The Platform is not intended for individuals under the age of 18 (or the age of legal majority in your jurisdiction). We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor without appropriate consent, we will take steps to delete such information promptly. If you believe a minor has provided us with personal information, please contact us at privacy@cozy.trade.

The Platform may contain links to or integrate with third-party websites, services, or protocols (including decentralized exchanges, wallet providers, and blockchain explorers). This Privacy Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you access through or in connection with the Platform. We are not responsible for the privacy practices of third parties. Key third-party services we integrate with include: • Privy — authentication and embedded wallet infrastructure • Jupiter Aggregator — decentralized swap routing • pump.fun / PumpPortal — token creation and bonding curve launch • Coinbase — fiat-to-crypto on-ramp (payment processing) • Birdeye Data Services — market data, token prices, and analytics • Firebase / Google Cloud Firestore — application database and user data storage • Helius — Solana RPC node infrastructure • IPFS — decentralized storage for token metadata • Solana blockchain — transaction settlement and on-chain data

When you create a token through the Platform, the following information is collected and stored: • Token metadata (name, symbol, description, image) — uploaded to IPFS and publicly accessible • Your user ID and wallet address — stored in our database to track creator earnings • Token mint address — stored to associate trades with creator earnings Creator earnings (0.3% of trade volume on your token) and referral earnings (0.1% of referred user trade volume) are tracked in our database. This data is used solely for calculating and displaying your earnings within the Platform. Token metadata uploaded to IPFS is permanent and publicly accessible. Cozy cannot delete or modify data stored on IPFS or the Solana blockchain.

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. Material changes will be communicated through the Platform or via email. The "Last updated" date at the top of this page indicates when this Policy was last revised. Your continued use of the Platform after any changes constitutes acceptance of the updated Policy. We encourage you to review this Policy periodically.

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: Email: privacy@cozy.trade Data Protection Inquiries: dpo@cozy.trade We will respond to your inquiry within 30 days.