This Policy explains what personal data Polarly processes, why, with whom we share it, and what rights you have. We collect the minimum necessary and have no access to your funds or exchange accounts. Processing is carried out in accordance with the Law of Ukraine “On Personal Data Protection” and, where applicable, the EU General Data Protection Regulation (GDPR).

1Who we are and scope

The controller of your personal data is Ihor Porada — the operator of the Polarly app (iOS, Android) and the website polarly.app (the “Service”). This Policy applies to the data we process when you use the Service.

2What data we collect

CategoryWhat exactlySource
Account dataEmailFrom Google Sign-In or Sign in with Apple when you log in
Usage dataYour Watchlist — the coins you choose to trackYour actions in the app
Portfolio dataTransactions you enter manually: coin, amount, price, fee, date, storage location, notes — and the positions calculated from themYour actions in the app
Reminder subscriptionsEvents (for example, a launchpool start or a token unlock) you asked to be reminded aboutYour actions in the app
Notification tokenDevice push token (Firebase Cloud Messaging)The device, when you allow notifications
Technical dataIP address, device type and model, OS, app version, date and time of requestsAutomatically, in server logs
Referral analyticsThe fact of following an affiliate link (not your activity on the exchange)Your tapping a link in the app

Your email is provided by the sign-in provider (Google or Apple) based on your permission. We do not store a password within the Service: sign-in relies on external authentication providers.

3What we do not collect

We have no access to your funds or accounts We do not request or store: private keys, seed phrases, exchange passwords or API keys, or access to your wallets. The Service does not connect to your exchange accounts and does not read balances automatically. Portfolio data appears in the Service only when you enter it manually yourself — you fully control these records and can change or delete them at any time. The Watchlist is merely a list of coins to track, without amounts.

4Why we process data and legal bases

PurposeLegal basis
Creating and maintaining your account; providing Service features (Watchlist, Portfolio, displaying products)Performance of a contract
Sending push notifications (Watchlist, event reminders, rate changes)Your consent
Security, abuse prevention, error diagnosticsLegitimate interest
Internal referral statistics and product improvementLegitimate interest
Compliance with the law and responding to lawful requestsLegal obligation

5Push notifications

Notifications are delivered via Firebase Cloud Messaging (a Google service). To do this, we store your device’s push token. You can withdraw consent at any time by disabling notifications in the app or device settings.

6Who we share data with

We do not sell personal data. We engage a limited set of providers and may disclose data in cases defined by law:

RecipientPurpose
Google (Firebase / Google Sign-In)Authentication and delivery of push notifications
Apple (Sign in with Apple)Authentication
Hosting provider (servers in the EU)Hosting and processing of Service data
Market data providersSource of coin prices and characteristics; technical requests are sent, not your personal data
Partner exchangesOnly when you follow a link yourself; the relevant exchange’s policy then applies
Government authoritiesOn the basis of a lawful request

7Affiliate links and referral analytics

When you follow a link to an exchange within the app, we record only the fact of the transition for internal statistics (how users engage with products). We do not track your subsequent activity on the exchange. When you delete your account, the link between these records and you is anonymised.

8Cookies and similar technologies

The mobile app makes virtually no use of cookies. The website polarly.app may use technical files necessary for its operation. You can control cookie settings in your browser.

9Retention periods

We retain account data for as long as your account is active. Technical logs are kept for a limited period necessary for security and diagnostics. After you delete your account, we delete or anonymise data related to you, except where retention is required by law (for example, to resolve disputes or comply with legal obligations).

10Security

We apply technical and organisational safeguards: authentication via opaque access tokens (rather than passwords stored in the app), encrypted connections (HTTPS/TLS), data hosting on servers in the EU, and restricted access. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

11Your rights

Subject to applicable law, you have the right to:

  • access your data and obtain a copy of it;
  • rectify inaccurate or incomplete data;
  • erase your data (the “right to be forgotten”);
  • restrict processing or object to it;
  • receive your data in a structured format (portability);
  • withdraw consent previously given;
  • lodge a complaint with the Ukrainian Parliament Commissioner for Human Rights or another competent authority.

To exercise your rights, email support@polarly.app.

12How to delete your account and data

You can delete your account directly in the app: Profile → Account → “Delete account”. The request marks your account for deletion with a 30-day recovery window. Immediately upon the request we delete your email, push token, and access tokens, and de-link referral analytics from you. Your Watchlist and portfolio data are retained during the 30-day window so you can restore the account by signing in again; once the window ends, all associated data is permanently deleted. Copies in system backups are permanently removed within approximately 35 days of rotation. You can also email support@polarly.app. See the Delete your account page for details.

13Children

The Service is intended for persons aged 18 and over. We do not knowingly collect personal data of anyone under that age. If you believe a child has provided us with their data, please tell us and we will delete it.

14International data transfers

Our servers and some of our providers are located in the European Union. Certain providers (including Google and Apple) may process data outside Ukraine or the EU under appropriate legal safeguards.

15Changes to this Policy

We may update this Policy from time to time. The current version is indicated by the date at the top of the page. Where possible, we will notify you of material changes within the Service.

16Contact

For privacy-related questions, contact the data controller: Ihor Porada, email: support@polarly.app.

See also the Terms of Use.

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