> For the complete documentation index, see [llms.txt](https://docs.atoma.fi/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://docs.atoma.fi/legal/privacy.md).

# Privacy Policy

Last updated: October 20, 2026

This Privacy Policy explains what personal data Atoma ("we", "us") collects when you use atoma.fi, app.atoma.fi, this documentation site and related services (the "Services"), how we use it, and your rights.

The data controller is Atoma Labs, a company incorporated in the Republic of Panama that operates the Services. Contact: <support@atoma.fi>.

## 1. What we collect

**Data you give us**

* Your wallet address and the signed sign-in message, when you sign in to the app.
* Your referral code, the referral code you entered, and the wallets linked to you through the referral program.
* Anything you send to <support@atoma.fi> or to our Discord or X accounts, such as your name, email, handle and the content of your messages.
* Identity documents, only if we are required by law or sanctions rules to ask for them.

**Data collected automatically**

* Server logs: IP address, approximate location derived from it, browser and device type, pages and API endpoints requested, time stamps and error reports.
* Settings stored in your browser (local storage), such as your session token, referral code and interface preferences. We do not set advertising cookies and do not use third-party analytics.

**Blockchain data**

* Your deposits, withdrawals, share balance, transfers and claims are recorded on the Arbitrum blockchain, which is public and permanent. We read and index this data to calculate share balances, points, tiers and referral credit. We cannot change or delete blockchain data.

## 2. How we use it

| Purpose                                                           | Data                                                               | Legal basis                              |
| ----------------------------------------------------------------- | ------------------------------------------------------------------ | ---------------------------------------- |
| Signing you in and keeping your session                           | Wallet address, signature, session token                           | Performance of a contract                |
| Calculating and showing points, tiers, referrals and leaderboards | Wallet address, blockchain data, referral data                     | Performance of a contract                |
| Operating, securing and debugging the Services                    | Server logs                                                        | Legitimate interest                      |
| Enforcing the Restricted Persons rules                            | IP address, location, wallet screening results, identity documents | Legal obligation and legitimate interest |
| Answering your messages                                           | Contact data and message content                                   | Legitimate interest                      |
| Announcements about the Services                                  | Discord or X account, if you follow us                             | Consent, through the platform you use    |

We do not sell personal data and do not use it for advertising.

## 3. Who we share it with

* **Service providers** that host and run the Services: cloud hosting, database, RPC and node providers, WalletConnect and Reown for wallet connections, and email. They process data only on our instructions.
* **Wallet screening providers**, to check addresses against sanctions lists.
* **Venues** on which the vaults trade do not receive your personal data; the vaults trade from Atoma's own accounts.
* **Authorities**, when required by law, a court order or a sanctions obligation.
* **A successor**, if Atoma is sold or merged, under this policy.

## 4. Public data

Your wallet address, share balance, points, tier and rank may be shown publicly in the app, for example on the leaderboard, in shortened form. Your blockchain transactions are public by nature of the network.

## 5. International transfers

Our service providers may process data outside the country you are in. Where the law requires it, such transfers are covered by appropriate safeguards.

## 6. Retention

* Sign-in, referral and points records: for as long as your wallet is registered with the Services and for 5 years after, to meet accounting and legal obligations.
* Server logs: up to 90 days, unless needed for a security investigation.
* Identity documents: for as long as required by law, and otherwise deleted after the verification is complete.
* Blockchain data: permanent, outside our control.

## 7. Your rights

Depending on where you live, you may have the right to access, correct, delete or receive a copy of your personal data, to object to or restrict its processing, to withdraw consent, and to complain to a supervisory authority. To exercise a right, email <support@atoma.fi> from an address we can link to your request, or sign a message from the wallet concerned. We may not be able to delete data that we are legally required to keep or that is recorded on the blockchain.

## 8. Security

We protect data with access controls, encryption in transit, encrypted storage of sensitive fields and logging of administrative access. No system is fully secure, and you are responsible for your own wallet and device.

## 9. Children

The Services are not for anyone under 18. We do not knowingly collect data from children.

## 10. Changes

We may update this policy at any time by publishing a new version with a new "Last updated" date.