Privacy Policy
Last Updated:
Sep 27, 2025
1. Introduction
ChainSpark Foundation (“Foundation”, “us”, “we” or “our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy. This policy describes the types of information we may collect from you or that you may provide when you use the Trojan interface (the “WebApp”), our website located at https://trojan.com (the “Website”), and any mobile applications to which this policy is posted (collectively, the “Functionality”), and our data collection and handling practices.
This Privacy Policy is part of the Terms of Use applicable to the use of our Functionality. Please review this policy together with the Terms of Use to understand all of your rights and obligations and how we operate our Functionality.
2. Global Applicability
This Privacy Policy applies to all users of the Functionality worldwide. We have adopted a privacy approach that is designed to reflect widely recognized principles of data protection, including transparency, user control, data minimization, and security.
3. Data Controller
The data controller is: ChainSpark Foundation
Email: privacy@chainspark.foundation
4. Basis for Processing Personal Information
We may process your personal information based on a variety of grounds, including:
Your consent
Our need to perform a contract with you
Compliance with a legal obligation
Our legitimate business interests, where these are not overridden by your rights and interests
The specific legal basis we rely on may vary depending on the type of data and purpose of processing.
5. Prohibited Users and Jurisdictions
Our Functionality is not available to individuals or entities located in, resident in, or otherwise subject to the sanctions laws of the United States or any other jurisdiction subject to comprehensive trade restrictions (“Restricted Jurisdiction”). A “Restricted Person” includes any individual or entity that (i) is organized, based, or ordinarily resident in a Restricted Jurisdiction; (ii) appears on any sanctions list maintained by the U.S. government (including the U.S. Treasury Department’s Specially Designated Nationals List), the United Nations, the European Union, the United Kingdom, or any other relevant authority; or (iii) is owned or controlled by, or acting on behalf of, such a person or entity.
If you are a Restricted Person, or acting on behalf of one, you may not access or use our Functionality. We do not knowingly collect or process data from such users.
6. Information We Collect and How
We may collect personal and non-personal information directly from you, automatically, and from third parties. This includes:
Identifiers (e.g., IP address, device ID, wallet address)
Advertising identifiers such as Identifier for Advertisers (IDFA), Google Advertising ID
International Mobile Equipment Identity (IMEI)
Device and browser characteristics
Browser fingerprint data (e.g., fonts, plugins, screen resolution)
Transaction data
Geolocation and usage data
Communication records and search queries
We do not collect or process personal data on behalf of users for regulated financial purposes. Our Functionality are intended as a conduit to third-party blockchain networks and infrastructure. We are not a broker, custodian, or financial service provider.
7. Third-Party Technologies and Disclaimer
Certain features of the Functionality are provided via or integrate with third-party technologies third-party wallet SDKs, decentralized exchanges (DEXs), and other blockchain infrastructure. Third-party partners may also use cookies, pixels, or similar technologies to collect information about your activities across websites or Functionality for purposes of analytics or advertising. We do not control these technologies and are not responsible for their data practices. Your interaction with these Functionality is governed by their respective terms and privacy policies.
8. Your Privacy Rights
Depending on your location and applicable law, you may have certain rights in relation to your personal information. These may include the rights to:
Access your personal data
Request correction or deletion
Object to or restrict certain processing
Withdraw consent where applicable
Request a copy of your data in a portable format
To exercise your rights, email privacy@chainspark.foundation. We will respond to such requests in accordance with applicable laws.
9. Data Retention
We retain personal data only as long as necessary to fulfill the purposes we collected it for, including legal and reporting obligations. For example:
Transaction records: up to 6 years
Account data: as long as your account is active
Marketing data: until consent is withdrawn
10. Cookie and Tracking Technologies
We use cookies and similar technologies to collect information. Our use of cookies includes:
Essential cookies for service functionality (no consent needed)
Non-essential cookies for analytics and advertising (used only with your consent)
Additional technologies may include:
Web beacons and pixel tags to track page views or email opens
ETags, embedded scripts, and device fingerprinting to enhance recognition and prevent fraud
Flash cookies or local storage to retain preferences
Log files to record device activity and connection details
We provide a cookie consent tool that lets you manage your preferences.
Do Not Track: We currently do not respond to "Do Not Track" signals sent by your browser due to a lack of standardized interpretation across the industry.
11. Do Not Sell or Share My Personal Information
We do not sell your personal information. If in the future we begin to share personal data for targeted advertising or similar purposes, we will implement appropriate controls and notifications.
12. International Data Transfers
We may transfer your data outside your home country. Where we do, we implement appropriate safeguards to ensure that your personal data continues to be protected in a manner consistent with applicable data protection principles.
13. Data Security
We implement technical and organizational safeguards to protect your data. While we strive for security, no system is impenetrable. We urge you to use strong, unique passwords and maintain good security hygiene. In certain cases, with your authorization, we may store encrypted credentials, such as wallet keys or seed phrases, solely for transaction signing purposes. We make no guarantees as to the security of third-party storage providers and disclaim all liability for any breach affecting stored credentials.
14. How We Use Your Information
We may use your information for the following purposes:
To present our Functionality and their content to you
To provide customer support, if applicable
To enable you to engage in transactions
To personalize your experience
To process referrals or promotions
To detect and prevent fraud
To conduct analytics and performance measurement
To improve the functionality and content of the Functionality
To comply with legal obligations
To communicate with you about our or third-party offerings (with consent)
To conduct user profiling and deliver personalized content and advertisements
15. Disclosure of Your Information
We may share your data:
With affiliates and service providers (under appropriate contracts)
In connection with business transfers
To comply with legal requirements
With your consent
To administer marketing and referral programs
We will never sell your personal data.
16. Children’s Privacy
Our Functionality is not intended for children under 18. We do not knowingly collect personal data from minors. In jurisdictions with different age thresholds for consent, we aim to comply with local requirements.
17. Changes to This Policy
We may update this policy from time to time. Material changes will be notified via email or on the Functionality. Please check this page periodically.
18. Contact Us
To exercise your rights or ask questions about our privacy practices:
© 2026 Trojan Trading. All rights reserved.
Systems Operational