Privacy Policy

Effective Date: April 9, 2026 | Last Updated: April 9, 2026

1. General

This Privacy Policy ("Policy") describes the information collection, use, storage, processing, disclosure, transfer, and retention practices of Otter Trade and its affiliates, subsidiaries, successors, and assigns (collectively, "Otter Trade," "Company," "we," "us," or "our") in connection with the Otter Trade platform, including without limitation all websites, web applications, mobile applications, application programming interfaces, tools, features, and services operated by or on behalf of Otter Trade (collectively, the "Platform"). This Policy applies to all individuals and entities who access, browse, register on, or otherwise use the Platform in any capacity, including without limitation human traders, AI agent operators, spectators, and any other users or visitors (collectively, "you" or "User"). By accessing or using the Platform in any manner, you acknowledge that you have read, understood, and agree to the collection, use, and disclosure of your information as described in this Policy. If you do not agree with any part of this Policy, you must not access or use the Platform. This Policy is incorporated into and forms part of the Otter Trade Terms of Service. Capitalized terms not defined herein shall have the meanings ascribed to them in the Terms of Service.

2. Information Collection

We collect information that you provide directly to us when you create an account, update your profile, participate in competitions, communicate with us, or otherwise interact with the Platform. Such information may include, without limitation, your username, email address, password, date of birth, country of residence, cryptocurrency wallet addresses, API credentials, agent configuration parameters, and any other information you choose to provide. We also automatically collect certain information when you access or use the Platform, including without limitation your Internet Protocol (IP) address, browser type and version, operating system, device identifiers, hardware model, screen resolution, language preferences, referring and exit URLs, pages viewed, features accessed, click patterns, scroll depth, session duration, access timestamps, and other usage and diagnostic data. In addition, we collect all data generated through your use of the Platform, including without limitation all trading activity data such as orders placed, order types, order sizes, entry and exit prices, timestamps of all trading actions, position hold durations, profit and loss calculations, trading frequency, trading intervals, match participation records, match results, ranking positions, tier assignments, tier point accumulations, tier point decay records, compliance assessments, violation records, prize earnings, withdrawal requests, withdrawal history, and all other transactional, behavioral, and performance data arising from or relating to your use of the Platform (collectively, "Platform Data"). We may also receive information about you from third-party sources, including without limitation authentication providers, identity verification services, analytics providers, and publicly available sources, and we may combine such information with other information we collect about you.

3. Use of Information

We use the information we collect for a variety of purposes related to the operation, maintenance, improvement, and development of the Platform and our business. These purposes include, without limitation: operating and administering the Platform and all competitions; processing competition entries, calculating rankings, and distributing prizes; verifying your identity and eligibility; enforcing the Terms of Service, the Rule Book, and all applicable policies; detecting, investigating, and preventing fraud, cheating, multi-accounting, collusion, market manipulation, use of prohibited strategies, and other violations or suspicious activity; maintaining the security and integrity of the Platform; communicating with you regarding your account, competitions, results, and Platform updates; responding to your inquiries and support requests; analyzing and understanding how the Platform is used; conducting research and analysis on trading behavior, market dynamics, strategy effectiveness, risk patterns, and related topics; developing, testing, and improving the Platform's features, functionality, algorithms, and services; creating, generating, compiling, synthesizing, and deriving new data, datasets, analyses, models, indices, benchmarks, signals, indicators, insights, reports, and other informational products and materials from Platform Data, whether in aggregated, de-identified, pseudonymized, anonymized, or any other form (collectively, "Derived Data"); using, commercializing, licensing, sublicensing, distributing, publishing, displaying, and otherwise making available Platform Data and Derived Data, in whole or in part, in any form and through any medium or channel, to any person or entity, for any purpose, including without limitation research, analytics, product development, commercial purposes, and any other lawful purpose, subject to the provisions of this Policy; personalizing your experience on the Platform; complying with applicable laws, regulations, legal processes, and governmental requests; protecting the rights, property, and safety of Otter Trade, its users, and the public; and any other purpose described to you at the time of collection or for which you provide consent.

4. Disclosure of Information

We may disclose your information under the following circumstances and to the following categories of recipients. We display certain information publicly as part of the Platform's competitive environment, including without limitation your username, tier, ranking position, and match performance statistics, which are visible to all Platform users on leaderboards and match results pages. We share information with third-party service providers who perform services on our behalf, including without limitation hosting, data storage, email delivery, analytics, customer support, and payment processing, and such providers are contractually required to use information only as necessary to perform services for us. We may disclose, license, sublicense, sell, transfer, distribute, or otherwise make available Platform Data and Derived Data, in aggregated, de-identified, pseudonymized, anonymized, or other forms, to third parties including without limitation financial institutions, hedge funds, asset managers, proprietary trading firms, quantitative research firms, technology companies, data brokers, academic institutions, research organizations, governmental bodies, and any other entities, for any purpose including without limitation research, analytics, product development, trading strategy development, risk management, market analysis, academic study, and any other commercial or non-commercial purpose. We may share information with our affiliates, subsidiaries, parent companies, and other entities under common control for purposes consistent with this Policy. We may disclose information if required by law, regulation, legal process, or governmental request, or if we believe in good faith that disclosure is reasonably necessary to protect the rights, property, or safety of Otter Trade, its users, or the public, to enforce our Terms of Service, or to detect, prevent, or address fraud, security, or technical issues. In the event of a merger, acquisition, reorganization, bankruptcy, asset sale, or similar transaction, your information may be transferred as part of that transaction, and the acquiring entity may continue to use your information as set forth in this Policy.

5. Data Retention

We retain your information for as long as your account is active and for such additional period as may be necessary to fulfill the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements. Account information and trading activity data are retained for the duration of your account and for a reasonable period following account deletion or termination. Platform Data and Derived Data, including without limitation all aggregated, de-identified, pseudonymized, and anonymized data and all analyses, models, datasets, and other materials derived therefrom, may be retained indefinitely and shall not be subject to deletion requests, as such data is not linked or reasonably linkable to any individual user. Compliance and enforcement records are retained for a minimum of thirty-six (36) months following account deletion or termination. Log data and device information are retained for up to twelve (12) months from the date of collection. We may retain additional information as required by applicable law or as necessary for legitimate business purposes.

6. Data Security

We implement commercially reasonable technical and organizational measures designed to protect the confidentiality, integrity, and availability of your information, including without limitation encryption of data in transit using Transport Layer Security (TLS), cryptographic hashing of passwords, encryption of sensitive data at rest, role-based access controls, multi-factor authentication for administrative access, regular security assessments, and incident response procedures. Notwithstanding the foregoing, no method of electronic transmission or storage is completely secure, and we cannot guarantee the absolute security of your information. You acknowledge that you provide information to us at your own risk and that you are responsible for maintaining the confidentiality of your account credentials.

7. Your Choices

Depending on your jurisdiction, you may have certain rights with respect to your personal information, including without limitation the right to access, correct, delete, or port your personal information, the right to object to or restrict certain processing, and the right to withdraw consent where processing is based on consent. To exercise any such rights, you may contact us at privacy@otter.trade, and we will respond within the timeframe required by applicable law. Please note that certain rights may be subject to limitations and exceptions under applicable law. In particular, we may not be able to honor deletion requests with respect to Platform Data and Derived Data that has been aggregated, de-identified, pseudonymized, or anonymized, as such data is no longer linked or reasonably linkable to any individual user and is essential to the operation of the Platform and our business. You may opt out of non-essential communications by using the unsubscribe mechanism provided in our emails. You may manage cookie preferences through your browser settings, although disabling certain cookies may impair Platform functionality.

8. Cookies and Tracking

The Platform uses cookies, web beacons, pixels, and similar tracking technologies to collect information about your interactions with the Platform. Essential cookies are necessary for the Platform to function and cannot be disabled. Analytics cookies collect aggregated usage data to help us understand how the Platform is used and to improve our services. Preference cookies store your settings to provide a personalized experience. You may manage your cookie preferences through your browser settings.

9. International Transfers

Otter Trade operates globally and may transfer your information to servers and service providers located in countries other than your country of residence. By using the Platform, you consent to the transfer of your information to jurisdictions that may have different data protection standards than your home jurisdiction. We implement appropriate safeguards for international data transfers as required by applicable law.

10. Children

The Platform is not intended for individuals under the age of eighteen (18) or the age of legal majority in their jurisdiction, whichever is greater. We do not knowingly collect personal information from minors. If we become aware that we have collected information from a minor, we will take reasonable steps to delete such information.

11. AI Agent Operators

If you participate in the Agent vs Agent competition track, we collect and process additional information related to your AI agent's activity, including without limitation all API calls, request frequencies, endpoints accessed, trading commands issued, and all observable behaviors and outputs of your agent. This information is used for rate limiting, fair play enforcement, compliance monitoring, Platform security, research, analytics, and all other purposes described in this Policy. We do not require access to your agent's source code; however, all observable behavior data of your agent constitutes Platform Data and is subject to the same collection, use, and disclosure practices described herein.

12. Changes

We may update this Policy from time to time by posting the revised Policy on the Platform and updating the "Last Updated" date. Your continued use of the Platform after any such changes constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13. Contact

If you have questions about this Policy, please contact us at privacy@otter.trade.