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Privacy Policy

Version 1.0
Effective Date: August 20, 2026

This Privacy Policy explains how HDL LLC (“HDL,” “we,” “us,” or “our”) collects, uses, discloses, retains, and protects information when you visit or use HDL websites, applications, social and identity features, communications, support channels, and related services that link to this Policy (collectively, the “Services”).

HDL is designed around a simple principle: collect and use information that is reasonably necessary to operate, secure, improve, and provide the Services, comply with law, protect users, and support features the user chooses to use.

HDL may allow public pseudonymous identity. That does not mean HDL must treat every account as anonymous internally. We may collect or verify private information where reasonably necessary for eligibility, account integrity, security, compliance, recovery, or access to particular services.

1. Information We Collect

The information we collect depends on the Services you use and the choices you make.

1.1 Account and profile information

We may collect and process information such as:

  • email address;
  • public @handle;
  • password-derived authentication records rather than plaintext passwords;
  • account and verification status;
  • session and authentication information;
  • preferences and settings;
  • onboarding intent selections;
  • crypto asset interests and related preference ordering;
  • profile information you choose to add;
  • account creation, update, verification, login, and security timestamps.

Your public profile may be pseudonymous. HDL does not require your legal name to be publicly displayed merely because HDL may privately know or verify information about you.

1.2 Date of birth and age-eligibility information

HDL is an 18+ service at launch, subject to any higher age of majority or eligibility requirement that applies in a particular jurisdiction.

When necessary, HDL may collect your full date of birth to determine age eligibility accurately, including around birthday boundaries. HDL may retain full date of birth as sensitive, nonpublic account information for legitimate purposes such as age eligibility, identity and account integrity, fraud and security controls, recovery, compliance obligations, and eligibility for future features that lawfully require stronger identity assurance.

HDL does not display your date of birth publicly by default and does not use raw date of birth in general product analytics to infer wealth, crypto sophistication, investment behavior, creator status, community identity, or risk appetite.

Where an approved provider supplies an age-assurance signal that HDL may lawfully rely on, HDL may use that signal instead of asking you to provide the same information again.

1.3 Identity, verification, and compliance information

HDL may collect or verify additional information where reasonably necessary to establish who is using an account, protect the platform, investigate abuse, recover an account, comply with law, or enable a feature that requires a higher level of assurance.

Depending on the purpose and applicable law, such information may include a legal name, date of birth, contact details, verification result, provider identifier, official-domain or account proof, public-channel proof, or other evidence reasonably related to the request.

HDL does not publish private verification information merely because a user has an HDL account. If future wallet, payments, financial, regulated, or other higher-risk services require additional identity verification, those requirements will be disclosed before the applicable feature is used.

1.4 Content and social activity

We may process content and activity such as:

  • posts, comments, replies, reactions, follows, mentions, tags, and media;
  • public profile information;
  • links and other material you submit;
  • reports and moderation records;
  • messages or conversation metadata where messaging features are offered;
  • timestamps and metadata needed to provide, rank, secure, moderate, or troubleshoot social functionality.

Public content and public profile information may be visible to other users or visitors depending on the feature and your settings.

As described in the Terms of Service, HDL may use public User Content in ordinary promotion of HDL. This does not change your ownership of original content you own.

1.5 Asset interests, recommendations, and personalization

HDL may process user-selected interests, including ordered crypto asset interests, onboarding intent, and product behavior signals to personalize discovery, ranking, recommendations, and other product experiences where implemented.

Selecting an asset interest does not automatically declare that you own that asset, invest in it, belong to a public tribe or community, or endorse the associated project.

We do not use raw date of birth as a general personalization signal.

1.6 Wallet and blockchain-related information

If you choose a wallet-linked or blockchain-related feature, HDL may process information such as:

  • public wallet addresses;
  • network or wallet type;
  • signing challenges;
  • signatures or verification results;
  • timestamps;
  • user-selected public blockchain, token, NFT, or other on-chain information relevant to the feature.

Public blockchain information can be persistent and publicly observable. Associating a public address with an HDL handle may allow others to connect that handle with public on-chain activity.

HDL will not ask you to provide a seed phrase, recovery phrase, or private key for ordinary authentication or support.

1.7 Usage, device, security, and diagnostic information

We may collect information reasonably needed to operate, secure, debug, and improve the Services, such as:

  • IP address;
  • browser and device information;
  • operating system or application version;
  • locale and language;
  • session information;
  • pages and features accessed;
  • timestamps;
  • diagnostics and errors;
  • fraud, abuse, rate-limit, and security signals;
  • browser storage or similar technical state used for authentication, preferences, or product functionality.

HDL may use privacy-minimized engagement signals to understand product usage and improve onboarding or discovery. We do not treat an attempted email address as a general-purpose advertising identifier merely because it was entered in a signup flow.

1.8 Communications and support information

If you contact HDL, reply to a reply-enabled HDL email, report content, dispute a handle, request account assistance, exercise a privacy right, or submit a legal or intellectual-property complaint, we may process the information you provide and records reasonably necessary to investigate, verify, respond, enforce policy, or comply with law.

Transactional communications may include verification, password-reset, account, welcome, security, and similar required service messages.

2. How We Use Information

HDL may use information to:

  • create, authenticate, recover, and secure accounts;
  • determine and record age eligibility;
  • establish account integrity and, where appropriate, verify identity;
  • provide public profiles, handles, social features, content, and communications;
  • preserve user settings and preferences;
  • provide optional personalization, discovery, and recommendations;
  • provide wallet-linked or blockchain-related features you choose to use;
  • deliver transactional communications;
  • provide support and respond to requests;
  • prevent, detect, investigate, and respond to fraud, abuse, security incidents, spam, impersonation, and policy violations;
  • moderate content and enforce HDL policies;
  • maintain, troubleshoot, analyze, and improve the Services;
  • comply with legal, regulatory, tax, accounting, reporting, or law-enforcement obligations where applicable;
  • establish, exercise, or defend legal claims;
  • protect HDL, users, third parties, and the integrity of the Services.

HDL does not currently use personal information for general-purpose sale to data brokers or for cross-context behavioral advertising. HDL does not treat user content as automatically available for unrelated general-purpose AI model training merely because it appears on HDL. Material new uses require a separate review and, where required, notice or choice before launch.

3. How We Disclose Information

HDL does not publicly expose nonpublic personal information simply because you have an HDL account.

We may disclose information in the following circumstances:

3.1 At your direction or through public features

Information you deliberately make public may be visible to other users, visitors, search engines, or other recipients depending on the feature and settings.

3.2 Service providers and infrastructure partners

We may disclose information to vendors and service providers that help us operate the Services, such as hosting, database, storage, security, authentication, email delivery, analytics or diagnostics, customer support, content delivery, and similar infrastructure providers.

These providers receive information for defined service purposes and are expected to handle it under appropriate contractual and security obligations.

3.3 Integrations you choose

If you connect or use a third-party identity provider, wallet, blockchain service, application, or other integration, information may be exchanged as necessary to provide the feature you requested. The third party’s own terms and privacy practices also apply to its services.

3.4 Safety, legal, and compliance reasons

We may preserve or disclose information where we reasonably believe doing so is necessary to comply with law or valid legal process; protect rights, safety, or security; investigate fraud or abuse; respond to emergencies; enforce policies; or establish, exercise, or defend legal claims.

3.5 Business transactions

Information may be disclosed or transferred as part of a merger, acquisition, financing, restructuring, reorganization, sale of assets, or similar lawful business transaction, subject to applicable law and appropriate protections.

4. No Sale or Public Exposure of Private Identity Data

HDL does not sell your private identity information for money and does not make nonpublic identity information public simply because you use the Services.

This does not prevent disclosures that are necessary to operate the Services, comply with law, protect users, complete a user-requested integration, or carry out a lawful business transaction as described in this Policy.

Where a privacy law defines “sale,” “sharing,” or targeted advertising more broadly than an ordinary monetary sale, HDL will provide any notices, choices, or rights required by that law before engaging in covered activity.

5. Cookies, Local Storage, and Similar Technologies

HDL may use cookies, local storage, session storage, or similar technologies for authentication, security, preferences, session state, feature operation, diagnostics, and other product functions.

If HDL later enables non-essential analytics, advertising, attribution, or other technologies that require consent or additional choice under applicable law, the required notice and control mechanism must be implemented before those technologies are enabled for affected users.

6. Data Retention

We retain information for as long as reasonably necessary for the purpose for which it was collected, while your account is active where appropriate, and for additional periods reasonably necessary for security, fraud and abuse prevention, legal obligations, dispute resolution, evidence preservation, backup integrity, or enforcement.

Retention can vary by data type. For example:

  • account and profile information may remain while the account is active;
  • security and authentication records may be retained longer where necessary to protect accounts and investigate abuse;
  • date of birth and identity information may be retained while reasonably necessary for eligibility, identity, security, compliance, and supported account functions;
  • content may persist where it was shared, re-shared, quoted, retained by another user, preserved for legal or safety reasons, or temporarily remains in technical backups;
  • support, moderation, fraud, identity-claim, and legal records may be retained for investigation, enforcement, compliance, or defense of claims.

HDL will not retain information indefinitely merely because storage is available. Retention rules may become more specific as the Services and legal obligations mature.

7. Account Deletion and Data Deletion

You may request deletion of your HDL account using the product workflow or instructions HDL makes available.

Account deletion is intended to remove or de-identify information that HDL no longer has a legitimate reason to retain, subject to applicable law, technical backup cycles, fraud and security needs, evidence preservation, legal holds, disputes, and information that must reasonably remain because it was shared with or independently retained by others.

Deleting an HDL account cannot delete information independently maintained by third-party providers, blockchain networks, wallets, search engines, message recipients, or other external services.

8. Your Choices and Privacy Rights

Depending on your location and applicable law, you may have rights to:

  • access personal information HDL holds about you;
  • correct inaccurate personal information;
  • request deletion;
  • receive a portable copy of certain information where required or reasonably practical;
  • object to or restrict certain processing;
  • withdraw consent where processing is based on consent;
  • appeal or challenge certain privacy decisions where required by law;
  • obtain information about how your personal information is used or disclosed.

HDL may need to verify your identity before fulfilling a privacy request so that we do not disclose or delete another person’s information.

You may contact [email protected] to exercise a privacy right where no dedicated product workflow is available.

9. Profile Visibility and Communications

HDL is designed to let users control what personal information they choose to make public through their profile and content, subject to feature design and safety requirements.

Certain service communications, such as email verification, password reset, security, account, and other required transactional messages, are necessary to operate the account and are not treated as optional marketing communications.

If HDL later offers marketing or promotional subscriptions, unsubscribe or preference controls will be provided as required by law.

10. Security

HDL uses administrative, technical, and organizational safeguards intended to protect information appropriate to the nature of the Services and the information involved.

No system can guarantee absolute security. Users also have an important role in protecting credentials, devices, wallets, recovery methods, and accounts.

HDL will not represent that a feature is end-to-end encrypted, zero-knowledge, bank-grade, audited, or otherwise subject to a specific security assurance unless that claim is supported by the deployed implementation and current evidence.

11. Children and Minimum Age

HDL is intended for users who are at least 18 years old at launch, or a higher applicable age of majority or minimum eligibility age where required.

A person who does not satisfy the applicable eligibility rule must not complete durable account activation.

HDL may revisit its minimum-age policy in a future version if the Services, legal requirements, moderation capabilities, and operational safeguards support doing so.

12. International Users and Cross-Border Processing

HDL is intended to serve users across jurisdictions. Information may be processed in the United States and in other countries where HDL or its service providers operate.

Those countries may have data-protection laws that differ from the laws where you live. Where applicable law requires a particular mechanism or safeguard for international transfer, HDL will use an appropriate legal mechanism or take other steps required by law.

International processing does not change HDL’s commitment to handling information according to this Policy.

13. Third-Party Services

Third-party wallets, blockchains, identity providers, websites, applications, and other services that you choose to use with HDL may independently collect and process information under their own privacy policies.

HDL does not control a third party’s independent data practices merely because that service is linked to or interoperates with HDL.

14. Changes to This Policy

HDL may update this Policy as the Services, data practices, law, or operating model changes. Each version will identify an effective date and version number.

Where required by law or where a change materially affects how personal information is used, HDL will provide additional notice or choice before the revised practice applies.

15. Contact

HDL LLC
Privacy questions and rights requests: [email protected]
General support: [email protected]
Security reports: [email protected]
Legal inquiries: [email protected]

If applicable law requires an additional local representative, regulator contact, mailing address, or jurisdiction-specific notice, HDL will provide that information in the applicable regional notice or an updated version of this Policy.