Cipher Privacy Policy
Effective Date: June 1st, 2025
This Policy outlines how Cipher gathers, uses, and discloses information for visitors to the website (the "Site") and users of its features and Services. By using the Site or Services, you agree to the data handling practices described below.
Governing Terms: Your use is subject to this Policy and the relevant Terms of Use (including dispute resolution and damage limitations).
1. Privacy Commitment & Data Collection
Privacy Commitment: Cipher is committed to privacy and transparency.
No Required Personal Information: Cipher does not require personally identifiable information (like name, email, or tax ID) to access the Site or Services.
Automatic Logging: When you engage with the Site or the Services, Cipher may automatically log your IP address.
Information We Collect
| Source | Type of Information Collected | Purpose |
|---|---|---|
| Directly From You | Public digital asset wallet address and public blockchain data. | To provide and enhance Services, and ensure legal compliance. |
| Automatically | IP address, browser type, device information, and usage data. | To improve the platform, maintain security, and analyze usage trends. |
2. How We Use Your Information
We use collected information for the following purposes:
- Service Delivery: To communicate with you, respond to inquiries, fulfill orders, and provide customer support.
- Personalization: To tailor content, offer location customization, provide personalized assistance, and enhance your user experience.
- Improvement and Development: To ensure proper functioning of the Site and Services, understand usage patterns (aggregated and individual), and develop new features.
- Legal & Compliance: To enforce the Terms of Use, comply with legal/regulatory obligations (including those from overseas authorities), exercise or defend legal claims, prevent fraud, and safeguard our rights and property.
3. Data Protection
Warning:
Cipher will never solicit your password, bank account details, or credit card information. Disregard and report any such communication to hello@cipher.gg.
Security Measures: Cipher employs industry-standard measures (internal reviews and standard security protocols) to guard against unauthorized access, alteration, or disclosure of data.
User Responsibility: No data security is 100% guaranteed. You must take steps to protect your password and devices. Cipher is not responsible for lost, stolen, or compromised passwords or unauthorized account activity.
4. How We Share Your Information
Your information may be shared in the following ways:
- Transaction Data Sharing (Order Flow): We may share certain transaction-related data (e.g., token pairs, order size, wallet address) with partners. This is done to improve execution quality, reduce failed transactions, and optimize routing across decentralized exchanges. Cipher may sell order flow to these third parties for efficiency. Personally identifying information is NOT shared unless required for compliance, fraud prevention, or legal obligations.
- Business Transfers: Information may be transferred to counterparties during a merger, acquisition, asset transfer, or bankruptcy proceeding.
- Legal Requirements and Protection: Disclosure may occur to investigate illegal activities, suspected fraud, threats to safety, violations of the Terms or Policy, or as evidence in regulatory investigations or litigation.
- Aggregate and De-Identified Information: We may share aggregate or de-identified information publicly for marketing, advertising, research, or similar purposes.
Consent Required: Except as listed above, Cipher will not sell or share your personal information with any third party for their direct marketing purposes without your consent.
5. Third-Party Services and Tracking
Third-Party Service Providers: We use third-party providers (data processors) who may collect information like your IP address and usage behavior.
Google Analytics: Used to understand user interactions.
Third-Party Links: Links to external websites are not governed by this Policy but by the policies of those third-party sites. Cipher is not responsible for their practices.
Cookies and Tracking: We and our service providers may use cookies (alphanumeric identifiers) and tracking mechanisms.
Purpose: To monitor usage, facilitate navigation, enable faster log-in, and track activities.
Do-Not-Track (DNT): Our systems do not currently recognize DNT requests.
Disabling Cookies: Most browsers accept cookies automatically, but you can disable them. However, disabling cookies will impair use of the Site and Services.
6. Your Rights and Data Retention
Your Rights and Choices
General Rights: You may request access, copies, modification, or deletion of personal information you submitted by contacting hello@cipher.gg.
GDPR Rights (EEA Users): If you are in the EEA, you have rights including access, correction, deletion (subject to limitations), restriction of processing, data portability, and the right to lodge a complaint.
Important Limitations: The right to deletion is limited for data needed for legal compliance, financial regulations, or legitimate business interests. This includes public blockchain data (which is immutable) and transaction data retained for regulatory compliance.
California Privacy Rights: California residents can request a disclosure of personal information shared with third parties for direct marketing by contacting hello@cipher.gg.
Data Retention and Storage
Retention Period: We retain personal information only for as long as necessary to fulfill the purposes of this Policy (services, security, fraud prevention, legal compliance).
Specific Retention:
- Public Blockchain Data: Retained indefinitely (as it is immutable).
- Transaction Data: Retained for 7 years (for financial regulations, reporting, and fraud prevention).
- IP Addresses & Session Data: Retained for up to 7 years (for security, tax compliance, and abuse prevention).
Extended Retention: Data may be retained longer if subject to active legal proceedings, regulatory mandates, or ongoing investigations.
Location of Information: The Site and Services are offered from the British Virgin Islands. By accessing them from, you agree to the transfer of your information to the British Virgin Islands as well as the European Union, which may offer fewer privacy protections than your home jurisdiction.
7. Special Considerations
Children: Our Site and Services are not designed for children under 13. If we discover a child under 13 has provided personal information, we will delete it.
Policy Changes: This Policy may be modified periodically. Your continued use after a modification indicates your acceptance of the updated terms.