This Privacy Policy describes how Bullpen collects, uses, and shares information when you visit our website, use the Bullpen App, or otherwise interact with the Bullpen Trading Platform.
Personal Information We Collect
When you use Bullpen, we may collect certain information, including:
— Account and contact information, such as your email address, if you create an account or contact support.
— Wallet and usage data, such as public wallet addresses, transaction history visible onchain, and app interaction data necessary to provide trading services.
— Technical information, such as your IP address, browser type, device information, operating system, and referral URLs.
— Analytics and cookie data, as described in our Cookie Policy.
Bullpen is a non-custodial platform. We do not take custody of your digital assets. Private keys are managed through secure infrastructure partners such as Turnkey — we do not store your private keys on our servers.
Why We Need Your Information and How We Use It
We rely on a number of legal bases to collect, use, and share your information, including:
as needed to provide our services, such as enabling trades, wallet connectivity, customer support, and platform functionality;
when you have provided your affirmative consent, which you may revoke at any time, such as by signing up for marketing communications;
if necessary to comply with a legal obligation, court order, or regulatory requirement; and
as necessary for our legitimate interests, where those interests are not overridden by your rights, such as improving the Bullpen App, maintaining security, preventing fraud, and analyzing platform performance.
Information Sharing and Disclosure
Information about our users is important to our business. We share personal information only in limited circumstances:
Service providers. We engage trusted third parties to perform functions on our behalf, such as analytics, hosting, key management (e.g., Turnkey), payment processing, and customer support. We share information only to the extent necessary for these services.
Blockchain networks. When you execute trades, transaction data is recorded on public blockchains (e.g., Solana, Hyperliquid, Polymarket-related networks) and is visible to anyone.
Business transfers. If we sell or merge our business, we may disclose your information as part of that transaction, only to the extent permitted by law.
Compliance with laws. We may collect, use, retain, and share your information if we have a good faith belief that it is reasonably necessary to respond to legal process, enforce our agreements, prevent fraud, address security issues, or protect the rights and safety of Bullpen, our users, or others.
Data Retention
We retain your personal information only for as long as necessary to provide you with our services and as described in this Privacy Policy. We may also retain information to comply with legal and regulatory obligations, resolve disputes, and enforce our agreements.
Transfers of Personal Information
We may store and process your information through third-party hosting services in the United States and other jurisdictions. As a result, your information may be transferred to jurisdictions with different data protection laws than your own. Where required, we implement appropriate safeguards for such transfers.
Your Rights
Depending on your location, you may have rights in relation to your personal information, including:
Access. You may have the right to access and receive a copy of the personal information we hold about you.
Change, restrict, delete. You may have rights to correct, restrict our use of, or delete your personal information, subject to legal exceptions.
Object. You can object to certain processing based on our legitimate interests, or opt out of marketing communications.
Complain. If you reside in the EU or UK, you may raise a concern with your local data protection authority.
Cookies
We use cookies and similar technologies to improve your experience, analyze usage, and support website functionality. For more details, see our Cookie Policy. You can accept or decline cookies through your browser settings or our cookie banner.
Children's Privacy
Bullpen is not intended for users under the age of 18. We do not knowingly collect personal information from children.
Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our practices or for operational, legal, or regulatory reasons. We encourage you to review this page periodically.
For more information about our privacy practices, or if you have questions or would like to make a complaint, please contact us through our support channels.
Data collected: IP address, browser type, device information, wallet addresses, analytics data, and cookies
Purpose: platform functionality, trading services, analytics, security, and performance improvement
Third-party services: analytics providers, Turnkey (key management), and integrated protocols (Jupiter, Hyperliquid, Polymarket)
User rights: access, correction, deletion, and opt-out options where applicable
Contact: See Bullpen documentation for support inquiries