Privacy Policy

This Privacy Policy is part of the Mina Terms of Service. All terms, conditions, and terminology are consistent with the Terms of Service, and the Terms of Service are incorporated into this document by reference.

This policy governs the use of the Mina mobile application and the associated tools and services. Collectively, the application and the associated tools and services are referred to as the "Services" in these terms.

The Services do not include outside websites, protocols, or platforms which may be linked or interconnected to the Services. Such outside platforms may have their own terms of service, which control for all transactions on such platforms. These outside platforms may include, but are not limited to:

• The Hyperliquid protocol and interface at app.hyperliquid.xyz
• Privy authentication services at privy.io
• Third-party wallet providers
• Blockchain networks and protocols

Area21 Labs LLC, a limited liability company, operates the Services. It and its affiliates are referred to in this document as the "operator," "we," or "us."

Mina is a non-custodial interface. We do not operate databases, store user data, custody funds, or control private keys. The Services function as a software interface connecting you directly to:

• Privy - Handles all authentication, login, and account management
• Hyperliquid Protocol - A decentralized exchange where you execute trades directly from your wallet
• Public blockchains - Where all transaction data is permanently and publicly recorded

We never have access to your funds, private keys, or the ability to execute transactions on your behalf. All trading activity occurs directly between your self-custodial wallet and the Hyperliquid protocol.

Blockchain technology, also known as distributed ledger technology (or simply 'DLT'), is at the core of the Services. Blockchains are decentralized and made up of digitally recorded data in a chain of packages called 'blocks'. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded.

This means that by design, a blockchain's records cannot be changed or deleted and is said to be 'immutable'. This may affect your ability to exercise your rights such as your right to erasure ('right to be forgotten'), or your rights to object or restrict processing, of your personal data. Data on the blockchain can't be erased or changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.

Mina does not custody, control, or have access to your funds or private keys. You maintain full control of your self-custodial wallet at all times. All transactions occur directly between your wallet and the Hyperliquid protocol. We are a non-custodial software interface only.

In certain circumstances, in order to facilitate your use of the Services (such as connecting to blockchain protocols), your wallet address may be written to the blockchain. This requires you to execute such transactions using your wallet's private key, which neither we nor Privy ever access or control.

If you want to ensure your privacy rights are not affected in any way, you should not transact on blockchains as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the blockchain. The blockchain is available to the public and any personal data shared on the blockchain will become publicly available.

As per our Terms of Service, individuals under the age of 18 are not permitted to use the Services. As such, we do not knowingly collect, solicit or maintain personal data from anyone under the age of 18 or knowingly allow such persons to register for the Services.

In the event that we learn that we have collected personal data from an individual under age 18, we will use commercially reasonable efforts to delete that information. Please contact us if you have any concerns. If you are a parent or guardian and become aware that your child has used our Services, please contact us immediately. Note that we cannot delete information stored on public cryptographic blockchains, and authentication data is managed by Privy according to their policies.

Mina does not operate any databases or data storage systems. We do not collect, store, or have access to:

• Names, addresses, or contact information
• Email addresses or phone numbers
• Social Security Numbers or tax identification
• Government-issued identification documents
• Financial account information (bank accounts, credit cards)
• Date of birth or citizenship information
• Payment information
• Private keys or seed phrases
• Passwords or authentication credentials
• User analytics, tracking data, or usage statistics
• Device identifiers for advertising purposes

To operate the Services, we may temporarily process certain technical data that is not stored in databases:

• API requests: When you use Mina to view data from Hyperliquid, your device makes direct API calls to Hyperliquid's infrastructure
• Connection data: Your device communicates with Privy's authentication services to verify your login session
• Session tokens: Temporary authentication tokens from Privy are cached locally on your device

This data is processed in-memory to make the application function and is not permanently stored by Mina.

The Services may use minimal local storage on your device to:

• Cache your login session (managed by Privy)
• Store your user preferences and settings
• Improve application performance

You may clear this data at any time through your device settings or by deleting the application.

We do not use cookies or tracking technologies for advertising, analytics, or cross-site tracking.

To operate the mobile application, your device may provide:

• Operating system type and version (for compatibility)
• Device type (for responsive design)
• App version (for update management)

This information is used only to ensure the application functions correctly on your device.

We partner with third-party services to operate Mina. These partners may collect information independently:

Because Mina does not collect or store user data, our use of information is limited to:

• Facilitating authentication: Connecting you to Privy's authentication services
• Enabling protocol access: Allowing your wallet to interact with Hyperliquid
• Providing the interface: Displaying information retrieved from public blockchains and Hyperliquid APIs

We do not:

• Track user behavior or analytics
• Build user profiles
• Serve advertisements
• Share data with third parties (because we don't have data to share)
• Use information for marketing purposes

To delete your Mina account:

• Navigate to Settings → Account → Delete Account within the application, or
• Contact us at support@mina.gg

Mina does not retain user data because we do not store it.

• Authentication data: Managed and retained by Privy per their policies
• Blockchain data: Permanent and public
• Local cache: Cleared when you delete the app or clear app data

Because Mina does not collect or store user information, we have no user data to share.

The Services facilitate your direct interactions with:

• Privy (for authentication)
• Hyperliquid (for trading)
• Public blockchains (for transaction execution)

These third parties operate under their own privacy policies and terms of service.

In the event of a valid legal request (subpoena, court order, warrant), we would:

• Comply with all applicable laws
• Notify you to the extent legally permitted
• Refer law enforcement to Privy (for authentication data) and public blockchain explorers (for transaction data)

We may transfer our business, intellectual property, or assets to a third party as a result of a business combination, merger, asset sale, or reorganization. In such an event, this privacy policy would continue to govern any data processed through the Services.

We do not sell user data. We do not have user data to sell.

Because Mina does not collect or store your personal information, most data rights requests must be directed to our partners:

Depending on your jurisdiction, you may have rights including:

• Access to information about you
• Correction of inaccurate information
• Deletion of your information (where technically possible)
• Data portability
• Objection to certain processing

Please understand that blockchain data cannot be deleted or modified due to the technological design of distributed ledgers.

We have put in place procedures to deal with any suspected security issues and will notify you and any applicable regulator of a breach where we are legally required to do so.

The Services connect you to third-party providers that may operate internationally:

• Privy: Operates infrastructure in the United States and potentially other jurisdictions
• Hyperliquid: Operates as a decentralized protocol across a global network of nodes
• Blockchains: Distributed globally across thousands of nodes

By using the Services, you consent to your information being processed in countries outside your country of residence, which may have different data protection rules.

Individuals under the age of 18 are prohibited from using the Services. We do not knowingly collect information from minors. If we become aware that a minor has used the Services, we will:

• Terminate their access
• Request that Privy delete any associated account data
• Take reasonable steps to prevent future access

Parents or guardians who believe their child has used the Services should contact us immediately at support@mina.gg.

We may update this privacy policy from time to time. Changes will be posted within the application and will include the "Last updated" date at the top of this policy.

Material changes will be communicated through:

• In-app notifications
• Email (if you've provided one to Privy)
• Posted notice on mina.gg

Continued use of the Services after changes constitutes acceptance of the updated policy.

Because we do not track users or collect analytics, Do Not Track signals are not applicable to the Services. We do not track you regardless of your browser settings.

If you are a California resident, you have specific rights under the California Consumer Privacy Act (CCPA):

• Right to Know: You can request information about data collected about you
• Right to Delete: You can request deletion of your data
• Right to Opt-Out: You can opt out of the "sale" of your information

However: Mina does not collect, store, or sell personal information. All data collection is performed by Privy and public blockchains.

For CCPA requests related to authentication data, contact Privy directly.

If you are located in the European Economic Area (EEA), UK, or Switzerland, you have rights under GDPR:

• Legal basis for processing: We facilitate your use of third-party services (Privy and Hyperliquid) based on your consent and contractual necessity
• Data controller: For authentication data, Privy is the data controller. For blockchain data, there is no single controller due to the decentralized nature of the technology
• Data transfers: Privy may transfer data outside the EEA. Review their privacy policy for details on transfer mechanisms
• Your rights: Access, rectification, erasure (where technically possible), data portability, and objection

To exercise GDPR rights related to authentication data, contact Privy at support@privy.io.

If you have questions about this privacy policy or how the Services handle information: