Privacy Policy

This policy applies to personal information we process as the operator of the Services. It does not cover third-party websites, wallets, blockchain networks, payment processors, or community platforms you may use alongside the Services; their own privacy policies apply to them.

Information you give us:

• Profile information, such as your name, email address, username, and password.
• Identity verification information, such as your date of birth, address, government ID, and a selfie or liveness check, collected (usually through a verification provider) before payouts or when required by law.
• Payment information. Card payments are handled by our payment processors; we receive limited details such as the card type, last four digits, and billing country, not your full card number. For crypto payments we process the coin, network, amount, sending and receiving wallet addresses, and transaction identifiers.
• Payout and tax information, such as payout account or wallet details and any tax forms we request.
• Content you submit, including scripts, indicators, strategies, and prompts you write, convert, or send to Vig.
• Communications, such as support requests, feedback, and survey responses.

Information collected automatically:

• Trading activity, including orders, positions, Account balances, results, and rule events in your simulated Accounts.
• Device and usage information, such as your IP address, browser and device type, operating system, app version, pages and features used, and crash and performance data.
• Approximate location derived from your IP address, used for eligibility and security.
• Cookies and similar technologies, as described in Section 6.

Information from others: identity verification and fraud prevention providers, payment processors, public blockchains, and community platforms such as Discord when you interact with us there.

We use personal information to:

• provide, operate, and maintain the Services and your Accounts;
• process payments, issue Accounts, and calculate and pay compensation;
• verify your identity and eligibility, and comply with sanctions, anti-money-laundering, tax, and other legal obligations;
• monitor Accounts for compliance with our Terms and Program Rules, and detect and prevent fraud, abuse, and security incidents, including by rate-limiting requests by IP address and session;
• provide Vig and its features;
• respond to your requests and send you service messages;
• send you marketing messages where permitted, which you can opt out of at any time;
• analyze and improve the Services and develop new features; and
• establish, exercise, or defend legal claims.

When you use Vig, the scripts, code, and prompts you submit, together with any context needed to answer them, are sent to our third-party AI service providers to generate a response. We send only what is needed for the request, and we do not send your identity verification or payment information to AI providers. Please do not include personal or confidential information in content you submit to Vig.

We do not sell your personal information. We share it only as follows:

• Service providers who act on our behalf, such as hosting, analytics, customer support, email, identity verification, fraud prevention, and AI service providers;
• Payment processors and crypto payment providers, to process Fees and payouts;
• Affiliates under common ownership or control with us, for the purposes in this policy;
• Authorities and others where we believe it is required by law, regulation, or legal process, or to protect the rights, safety, or property of Graybook, our users, or others;
• In a business transaction, such as a merger, acquisition, financing, or sale of assets, subject to standard confidentiality protections; and
• With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably identify you, for example statistics shown on our website.

We use cookies, local storage, and similar technologies to keep you signed in, remember your preferences, secure the Services, and understand how they are used. You can control cookies through your browser settings; blocking some of them may stop parts of the Services from working.

Some features load data directly from third parties in your browser. For example, during a crypto checkout your browser requests live coin prices from a public exchange price service, which receives your IP address as part of that request.

Crypto payments and payouts are recorded on public blockchains. Wallet addresses, amounts, and transaction details on a blockchain are public and permanent, and we cannot change or delete them.

We keep personal information for as long as your profile is open and as needed to provide the Services, and afterwards for as long as needed to comply with legal, tax, accounting, and anti-money-laundering obligations, resolve disputes, prevent fraud, and enforce our agreements. When we no longer need it, we delete or de-identify it.

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and access controls. No system is completely secure, so we cannot guarantee the security of your information. Please keep your password secret and tell us at techops@graybook.co if you suspect unauthorized access to your profile.

Depending on where you live, you may have the right to access, correct, delete, or receive a copy of your personal information; to object to or restrict certain processing; to withdraw consent; and to opt out of marketing. You can update your profile in the Services, unsubscribe from marketing using the link in any marketing email, and make other requests by contacting techops@graybook.co. We will verify your identity before acting on a request, and we will not discriminate against you for exercising your rights.

Some information must be kept even after a deletion request, for example where the law requires us to keep records of payments and payouts.

If you are a California resident, the California Consumer Privacy Act gives you the right to know what personal information we collect, use, and disclose; to delete it; to correct it; and to opt out of its sale or sharing for cross-context behavioral advertising. We do not sell personal information or share it for cross-context behavioral advertising. The categories of personal information we collect, their sources, and our purposes are described in Sections 2 to 5. You may make a request, or have an authorized agent make one for you, at techops@graybook.co.

If the GDPR or UK GDPR applies to you, we process personal information on these legal bases: to perform our contract with you (providing the Services and paying compensation); to comply with legal obligations (identity verification, sanctions, tax, and record-keeping); for our legitimate interests (security, fraud prevention, Program integrity, and improving the Services), balanced against your rights; and with your consent (for example, certain marketing), which you may withdraw at any time.

You may lodge a complaint with your local data protection authority. Where we transfer personal information outside the EEA or UK, we use appropriate safeguards such as the European Commission's Standard Contractual Clauses.

We and our service providers may process personal information in countries other than the one where you live, which may have different data protection laws. Where required, we protect these transfers with appropriate safeguards.

The Services are not intended for anyone under 18, and we do not knowingly collect personal information from them. If you believe a minor has given us personal information, contact us and we will delete it.

We may update this policy from time to time. We will post the updated policy here and change the "Last updated" date above, and for material changes we will give you notice through the Services or by email.

Questions or requests about this policy or your personal information can be sent to techops@graybook.co.