Probly — Privacy Policy
Last Updated: April 2026
1. Introduction
This Privacy Policy (“Policy”) governs the manner and provides the basis in which your Personal Information is collected on probly.com (“Website”, “Company”, “we”, “our”, or “us”), web applications, mobile applications and all associated websites linked to us or by us or our affiliates. We recognize the importance of your right to privacy and the protection of your information. This Policy further applies to all information we collect through our Website and otherwise obtain in connection with products and Services, content, features, technologies, functions and all related websites we may provide to you or to which we may provide access (collectively, the “Services”).
By using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Policy. Specifically, by (i) using, visiting, or accessing the Services, (ii) using, accessing, establishing an account through or purchasing any of the Services, and/or (iii) clicking “accept”, “agree”, or “OK” (or a similar term) with respect to any of our Terms or similar policies, you consent and agree to be legally bound by each of the terms and conditions contained in this Policy. If you do not agree to this Policy, do not use, access, connect to or interact with us, or otherwise provide your information to us.
In operating the Website and providing the Services, we may collect (and/or receive) certain information about you and your activities. You hereby authorize us to collect and/or receive such information to operate the Website and provide the Services.
2. Applicability
This Policy applies to all information we collect from you in connection with the Website and offering the Services. This Policy does not apply to information collected by us offline or through any other means, including on any other website made available by us or by any third party (including our affiliates and subsidiaries). Throughout this Policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been aggregated and/or anonymized so that it does not identify a specific user. Personal Information may also include the personal information of third parties that may be contained in information you provide to us through your use of the Website.
Personal Information you provide us
Personal information you provide us may include, but is not limited to, the following:
- Any digital-asset;
- Wallet information;
- Protocol Address information;
- Geolocation data;
- Transaction data or history; and
- Any information associated with a linked address or Wallet and token holdings.
Your Personal Information will be provided to us when you connect your Wallet or have any communications with us.
We collect information:
- Directly from you when you provide it to us;
- Automatically as you navigate through the Website. Personal Information collected automatically may include usage details, IP addresses, and information collected through Cookies and other tracking technologies; and
- In certain instances, from third parties, such as our business partners, third-party providers or other networks where you have connected your account and authorized us to access this information.
We may collect additional information from or about you in other ways not specifically described here. For example, we may collect information related to your contact with our customer support team.
We will access, use, and share your information as required to fulfill our contractual obligations to you, provide you with support, and to address your questions or requests regarding our Services.
3.Protection for Minors’ Personal Information
Upon discovering inadvertent collection from individuals below age of eighteen (18), we will exert reasonable measures to purge such Personal Information from our systems.
4. Policy on Cookies
A cookie is a small file placed on the hard drive of your computer. When you visit our Website, use our Services, we and certain business partners and vendors may use cookies and other tracking technologies (collectively, “Cookies”). We use Cookies to recognize you as a customer, to customize the Services, other content and advertising, to measure the effectiveness of our promotions, to perform a wide range of analytics, to mitigate risk and prevent potential fraud, and to promote trust and safety across our Services.
Most browsers are set to accept cookies by default. You can remove or reject cookies. However, certain Services are only available through the use of Cookies. Therefore, if you choose to disable or decline Cookies, your use of the Services may be limited or not possible.
5. Justification for Handling Personal Information
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. We may use information collected about you via the Website for the following purposes, including but not limited to:
- Administer sweepstakes, promotions, and contests;
- Compare information for accuracy and verify it with third parties;
- Compile anonymous statistical data and analysis for our use internally or with third parties;
- Customize, personalize, measure, and improve our Services and the content and layout of our Services;
- Deliver the Services and provide customer support to you;
Enhance the efficiency and operation of the Website and the Services we deliver to you for our legitimate interests including for the following purposes:
- Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
- Measuring interest and engagement in our Services and short-term, transient use, such as contextual customization of ads;
- Undertaking research for technological development and demonstration;
- Researching and developing products, Services, marketing or security procedures to improve their performance, resilience, reliability or efficiency;
- Improving, upgrading or enhancing our Services;
- Developing new products and Services;
- Ensuring internal quality control;
- Debugging to identify and repair errors that impair existing intended functionality;
- Enforcing our terms and policies; and
- Complying with our legal obligations, protecting your vital interest, or as may be required for the public good.
- Fulfill any other purpose for which you may provide us with your information;
- Improve the security of the Website and, if you share geolocation Information, provide you with location-specific options, functionality, offers, advertising, search results, or other location-specific content;
- Monitor and analyze usage and trends to improve your experience with the Services;
- Notify you of updates to the Services;
- Perform such other duties as may be required by law;
- Prevent potentially fraudulent, prohibited or illegal activities, and enforce our Terms of Use through the use of our risk and fraud tools;
- Process transactions (including payments and refunds) and send notices about your transactions or your network activity;
- Provide and improve the Services;
- Provide targeted advertising, coupons, newsletters, and other promotional information regarding the Services;
- Request feedback, resolve disputes, collect fees, and troubleshoot problems; and
- Respond to your inquiries or fulfill requests and provide customer Services.
Without limiting the foregoing, you also authorize us to use and/or share information as described below:
- We may, from time to time, share your information with other companies, who may provide you information about the products and Services they or their partners offer.
- We will access, use, and share your information as required to fulfill our contractual obligations to you, provide you with support, and to address your questions or requests regarding our Services;
- We may employ other companies and individuals to perform functions on our behalf. Examples may include providing technical, customer service and marketing assistance;
- In an ongoing effort to better understand our customers and our Services, we may analyze your information in anonymized and/or aggregate form in order to operate, maintain, manage, and improve the Services. This anonymous information does not identify you personally. We may use this anonymous information and share it with our affiliates, agents, business and promotional partners, and other third parties. We may also disclose anonymous user statistics in order to describe our Services and business to current and prospective business partners and to other third parties for other lawful purposes.
- We may share some or all of your information with any of our parent companies, affiliates, subsidiaries, joint ventures, or other companies under common control with us.
- As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, liquidation, or bankruptcy or similar event, your information may be part of the transferred assets; and
- To the extent permitted by law, we may also disclose your information: (i) in response to lawful requests by public authorities, including for the purpose of meeting national security or law enforcement requirements, (ii) when required by law, court order, or other government or law enforcement authority or regulatory agency; or (iii) whenever we believe that disclosing such information is necessary or advisable, for example, to protect the rights, property, or safety of us or others.
6. How We Protect and Store Your Information
The security of your Personal Information is important to us but remember that no method of transmission over the Internet or method of electronic storage is absolutely secure. We strive to ensure security on our systems and use administrative, technical, and other physical security measures to help protect your personal information. We also use computer safeguards such as firewalls and data encryption, we enforce access controls to our office and files, and we authorize access to personal information only for those employees who require it to fulfill their job responsibilities. Despite our efforts, we cannot guarantee that personal information may not be accessed, disclosed, altered or destroyed by breach of our administrative, managerial and technical safeguards. Therefore, we urge you to take adequate precautions to protect your personal information as well. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
7. How We Share Personal Information with Other Parties
We may share your information with our business partners to offer you certain products, Services, and promotions. We may also use third-party advertising companies to serve ads when you visit the Website. These companies may use information about your visits to the Website and other Websites that are contained in web cookies in order to provide advertisements about goods and Services of interest to you.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Some personal information is public information (this may include your web3-enabled wallet’s public address, username, profile photo, profile first and last name, month, and year of account creation, and public transactions in which you've been involved), and may be seen by anyone on the Internet due to the nature of the blockchain, whether or not they have an account with us. Public information may also be seen, accessed, reshared or downloaded through APIs, SDKs, or third-party Services that integrate with our products.
We may share your personal information with:
- Law enforcement, government officials, or other third parties if we are compelled to do so by a subpoena, court order or similar legal procedure, when it is necessary to do so to comply with law, or where the disclosure of personal information is reasonably necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of the Terms of Services, or as otherwise required by law.
- Third-party services providers who assist us in providing the Services to you or who provide fraud detection or similar Services on our or any vendor’s behalf.
- Our affiliate entities, including but not limited to subsidiaries.
Other third parties with your consent or at your direction to do so, including if you authorize an account connection with a third-party account or platform:
- For the purposes of this Policy, an “account connection” with such a third party is a connection you authorize or enable between your account and a payment instrument, or platform that you lawfully control or own. When you authorize such a connection, we may exchange your personal information and other information directly with such third-parties. Examples of account connections include, without limitation: linking your account to a social media account or social messaging services; connecting your account to a third-party Personal Information aggregation or financial services company, if you provide such company with your account log-in credentials; or using your account to make payments to a merchant or allowing a merchant to charge your account.
- If you connect your account to other financial accounts, directly or through a third-party services provider, we may have access to your account balance and account and transactional information, such as purchases and funds transfers. If you choose to create an account connection, we may receive information from the third party about you and your use of the third-party’s services. For example, if you connect your account to a social media account, we will receive personal information from the social media provider via the account connection. We will use all such information that we receive from a third-party via an account connection in a manner consistent with this Policy.
- Information that we share with a third-party based on an account connection will be used and disclosed in accordance with the third-party’s privacy practices. Before authorizing an account connection, you should review the privacy notice of any third party that will gain access to your personal information as part of the account connection.
We do not send your personal information to third-party social networks unless you have specifically requested or authorized us to do so. When you broadcast information to such third-party social networks, such information is no longer under our control and is subject to the terms of use and privacy policies maintained by such third parties.
8. Third-Party Links
The Services may contain links to (or allow you to link to) unaffiliated third-party services, applications, or websites. We do not control information collection of any third-party services, applications, or websites that can be reached through such links. We encourage our users to be aware when they are linking to a third-party service or website and to read the privacy statements of any third-party services or website that collects personal information. Any information you provide to any third party is not covered by this Policy and we cannot guarantee the safety and privacy of your information.
Note also that third parties may use Cookies (either alone or in conjunction with web beacons or other tracking technologies) to collect information about you when you use our Services. Information third parties collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and online services. Third parties may use this information to provide you with interest-based advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, we encourage you to contact the responsible provider directly. If you no longer wish to receive correspondence, e-mails, or other communications from third parties, you are responsible for contacting the third party directly.
9. Connections to External Wallets and Liability Waiver
Some aspects of the Services might necessitate linking a supported external cryptocurrency wallet. In doing so, you acknowledge that your engagement with these wallets falls under their respective guidelines, and you confirm adherence to the provider’s stipulations or terms and conditions.
These wallets operate independently of the Company, without any endorsement or affiliation. We fully disclaim responsibility for any issues stemming from your wallet usage, encompassing but not limited to the handling or exposure of sensitive details by those providers.
10. Transfer of Personal Information
Your personal information may be transferred to, and maintained on computers located outside of your state, province, country or other governmental jurisdiction where the Personal Information protection laws may differ from those of your jurisdiction. By using the Services, you consent to the transfer of your information outside of your country of residence, which may have Personal Information protection rules that are different from those of your country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
We will take all the steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy and no transfer of your personal information will take place to an organization or a country unless there are adequate controls in place including the security of your Personal Information and other personal information.
11. Your Rights
Depending on applicable law where you reside, you may be able to assert certain rights related to your personal information identified below. If any of the rights listed below are not provided under law for your operating entity or jurisdiction, we have absolute discretion in providing you with those rights.
Your rights to personal information are not absolute. Depending upon the applicable law, access to your rights under the applicable law may be denied. Depending on applicable protection laws, you may possess certain rights regarding your Personal Information, potentially including:
- Viewing your held Personal Information, its usage details, and sharing recipients;
- Seeking fixes for erroneous or partial Personal Information, subject to our checks;
- Demanding Personal Information erasure under specific conditions;
- Contesting Personal Information handling in select cases;
- Limiting handling to mere storage in certain situations;
- Revoking permission for consent-based handling, without impacting prior or alternate-basis activities.
Note that the above rights apply only in certain circumstances and all these rights may be limited by law. These rights are also contextual and may face legal constraints, e.g., if they harm other users, our proprietary info, public welfare, or retention mandates. Identity confirmation will precede responses, and we have the sole and absolute discretion to deny requests under lawful grounds.
12. Disclaimer
Be aware that despite our efforts to protect your Personal Information and other information, we cannot guarantee perfect security of your information transmitted through the Website. In addition, note that any information you send us may not be secure while in transit. Any transmission is at your own risk.
13. Retention
We keep your Personal Information for the time necessary for the purposes for which it is processed. The length of time for which we retain Personal Information depends on the purposes for which we collected and use it and your choices, after which time we may delete and/or aggregate it. We may also retain and use Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
14. Policy Updates
We may update this Policy at any time. When we do, we will revise the updated date at the top of this page. We encourage users to frequently check this page for any changes to stay informed about our information practices. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Website following the posting of changes to this Privacy Policy will be deemed your acceptance of those changes. If you do not agree to this Privacy Policy, please do not use our Website.
15. Jurisdiction
The Services, including the Website, is made available by us from Panama and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of Panama.
16. How to Reach Us
For inquiries or concerns on our Personal Information practices, your information, or this Policy, contact [email protected].