Draft, not yet reviewed by counsel. Published for review and comment.
This policy covers three groups of people: account holders on the exchange, people who click a stream link, and people who opt in on our funnels.
Account holders
We store your email address, a hashed password, an optional two-factor secret, your time zone and theme, your crypto payout addresses, your deposits, orders, streams, ledger postings and support tickets. We do not ask for your name or identity documents. Your public identity on the exchange is a random number ("Seller #4821") that is never linked to you for other members.
We use this data to run your account, to pay you and to meet legal duties. We send transactional email only (verification, password reset, payout sent, order delivered, weekly summary if you keep it on) and never marketing mail from the exchange domain. You can export your data and delete your account from Settings; ledger and audit records are kept as the law requires.
People who click a stream link
A click on a stream URL passes through a short interstitial page before it reaches the buyer's landing page. We record the time, the IP address, the user agent, country and region, device, browser, the result of local bot and proxy checks, a cookie and a browser fingerprint used to count the visitor as unique, and the outcome of the click (sold, skimmed, returned, filtered). After the click we score the IP address with a third-party IP quality service.
Retention: 12 months. Click records keep the full IP address for 12 months. After that the IP is removed and the row is kept for statistics only. Uniqueness records are kept for as long as the exchange operates so that a buyer is never charged twice for the same visitor.
This data is used to route the click, to charge the buyer, to pay the seller and to measure the seller's traffic quality. Buyers see the country, device and an anonymous seller id per delivered click. Sellers see the outcome and the reason per click, but never the buyer or the price of an individual click.
People who opt in on our funnels
About 5% of the clicks a stream sells are sent to funnels we operate under a separate brand. If you opt in there, we store your email address, the click that brought you, the stream it came from, your opens, clicks, replies and purchases, and we email you our own offers. You can unsubscribe at any time from any email; we delete your lead record 30 days after you unsubscribe. The aggregate results (opt-in rate, engagement, sales) are published as the quality numbers of the stream that sent you, never anything about you individually.
Processors
We use a crypto payment processor for deposits and payouts, a transactional email provider for account mail, an IP quality service and a URL safety service, an error monitoring service, and a hosting provider in the United States. Each receives only what it needs for its job.
Your rights
Depending on where you live you may have the right to access, correct, export or delete your data and to object to its use. Write to the support address on the help page. Account holders can do most of this from Settings. We respond within 30 days.
Changes
We will date changes here and notify account holders by email before a material change takes effect.