Privacy Policy

Last updated: 15 September 2026 · Version 1.0

This Privacy Policy explains how Freddy Made another one LLC, 1209 Mountain Road Pl NE, Ste R, Albuquerque, NM 87110, United States ("Beaver", "we", "us") collects, uses, shares and protects personal data when you use the TryBeaver web application and iOS application (the "App").

It forms part of, and is incorporated into, the TryBeaver Terms of Service. Capitalised terms not defined here have the meanings given there.

Controller. Freddy Made another one LLC is the controller of the personal data described in this policy, except where stated otherwise (notably for Privy and the Data Aggregator, which act as controllers in their own right for parts of the processing).

1. Summary

• We collect what we need to run the App: your sign-in identity, your handle, your wallet address, the transaction data you authorise us to read from the Data Aggregator, your App activity, and technical/device data.
• We never receive or hold your private keys, seed phrase or wallet recovery factors. We cannot access your wallet.
• We never receive your open banking credentials, those go to a licensed Data Aggregator, not to us.
• We use data to calculate roundups, execute the features you turn on, screen for sanctions and fraud, send you notifications, fix bugs and comply with law.
• We do not sell your personal data, and we do not share it for cross-context behavioural advertising.
• Blockchain data is public and permanent. Anything on-chain cannot be deleted by us or by you.

2. What we collect

2.1 Information you give us

2.2 Information from your Connected Accounts

When you link a bank, card or neobank account, a licensed third-party account-information provider (a "Data Aggregator") obtains your authorisation and provides us with read-only data, typically: institution name, masked account identifier, account type, transaction date, amount, currency, merchant name or description, merchant category, and pending/posted status. We may also receive a balance indicator where you authorise it.

We do not receive your online banking username, password, PIN or one-time codes. Those are handled by the Data Aggregator and your institution, under their terms. We do not have, and do not ask for, the ability to move money from your Connected Account.

2.3 Wallet and blockchain data

We record your wallet address and read publicly available on-chain data associated with it : balances, token holdings, transaction hashes and history, to display your portfolio and activity.

We never collect, receive, store or have access to your private key, seed phrase, key shares or wallet recovery factors. The Wallet is provisioned by Privy and is self-custodial.

2.4 Usage, device and technical data

Screens viewed, features used, taps and flows, session timing, crash and error logs, performance metrics, device model and OS version, app version, language and time zone, IP address and coarse geolocation derived from it, and push notification tokens. On the web app, we and our service providers use cookies and similar technologies (see Section 9).

2.5 Compliance data

Results of sanctions and wallet-risk screening, geolocation and VPN/proxy signals used to enforce the eligibility restrictions in the Terms, and records of your acceptance of the Terms, Risk Disclosure and this policy (including timestamp and version).

2.6 What we do not collect

We do not knowingly collect data from anyone under 18. We do not collect government identity documents, national identifiers or biometric data in the App. We do not collect special-category data (health, race, religion, political opinions, sexual orientation, union membership) and ask that you do not send it to us.

3. Why we use it, and our legal bases

Where the GDPR, UK GDPR or a similar law applies to you, our legal bases are noted in brackets.

• Provide the App : create your Account, provision the Wallet, calculate round-ups and matches, construct transaction messages you sign, display your portfolio and activity. (Performance of a contract.)
• Notifications and service messages : transaction and funding alerts, security notices, changes to these documents. (Contract; legitimate interests.)
• Eligibility, sanctions and fraud : screen users, wallets and jurisdictions; detect multi-accounting, reward abuse, circumvention and market abuse; enforce the Terms. (Legal obligation; legitimate interests in preventing crime and protecting the service.)
• Security and reliability : authentication, abuse prevention, rate limiting, debugging, crash analysis. (Legitimate interests.)
• Improve the product : aggregated and de-identified analytics on how features are used. (Legitimate interests; consent where required for analytics cookies.)
• Rewards and referrals : operate the reward ledger, verify qualifying events, prevent abuse. (Contract; legitimate interests.)
• Marketing : product updates and promotions, where you have opted in or where permitted. (Consent; legitimate interests.) You can opt out at any time.
• Legal and regulatory : respond to lawful requests, establish or defend legal claims, maintain records. (Legal obligation; legitimate interests.)

3.1 Automated decision-making

We use automated rules to calculate round-ups, trigger notifications, and screen for sanctions, fraud and reward abuse. Screening may result in your access being restricted or terminated. Where such a decision produces legal or similarly significant effects for you and applicable law gives you the right, you may request human review by contacting privacy@trybeaver.app. We do not use your data for profiling to sell you third-party products.

4. Who we share it with

We share personal data only as described here. We do not sell personal data and we do not share it for cross-context behavioural advertising.

We require processors to act only on our instructions and to apply appropriate security. Providers change; a current list is available on request from helo@trybeaver.app.

4.1 Disclosure to authorities

We may disclose data where we believe in good faith it is required to comply with a law, regulation, sanctions obligation, subpoena, court order or lawful request from a governmental, regulatory or law-enforcement authority; to enforce the Terms; or to protect the rights, property or safety of any person.

4.2 Public blockchain data

Transactions from your Wallet are recorded on-chain. Blockchain data is public, permanent and outside our control. Anyone can inspect your wallet address and its full history, and third parties may be able to link that address to you through information you or others publish. We cannot delete, amend or restrict on-chain data. Consider this before funding your Wallet from an address associated with your identity.

5. International transfers

We are established in the United States and our providers operate in the United States and elsewhere. If you are in the European Economic Area, the United Kingdom, Switzerland or another region with transfer restrictions, your data will be transferred outside that region. Where required, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (with the UK Addendum where applicable) together with supplementary measures, or on a recognised adequacy decision. You may request details of the safeguards used by writing to hello@trybeaver.app.

6. How long we keep it

• Account and profile data : for as long as your Account is open, and up to twelve (12) months after closure where needed for legal, tax, sanctions-compliance or dispute purposes.
• Connected Account transaction data : while the connection is active and for up to twelve (12) months afterwards, to support activity history, reconciliation and dispute handling. You may disconnect at any time, which stops new data being received.
• Compliance and screening records : as required by applicable law, typically at least twelve (12) months.
• Logs, analytics and crash data : typically 12 months, or less where aggregated.
• On-chain data : permanent, and outside our control.

We may retain de-identified or aggregated data indefinitely; such data is not used to re-identify you.

7. Your rights

Depending on where you live, you may have the right to: access the personal data we hold about you; correct it; delete it; restrict or object to processing (including profiling); receive a portable copy; withdraw consent at any time without affecting prior processing; and opt out of marketing.

If you are a California resident, you may additionally have the right to know the categories and specific pieces of personal information collected, the categories of sources, the business purposes, and the categories of third parties to whom it was disclosed; to delete or correct it; to limit the use of sensitive personal information; to opt out of sale or sharing (we do not sell or share personal information as those terms are defined under the CCPA/CPRA); and not to be discriminated against for exercising any right. Note, however, that the App is not available to U.S. Persons under Section 4 of the Terms.

To exercise a right, contact hello@trybeaver.app. We will verify your request through your registered Account and respond within the period required by applicable law (generally 30 days, extendable where permitted). An authorised agent may act for you with proof of authorisation.

Two limits you should understand. First, we cannot delete blockchain data. Second, we must retain certain records for legal and sanctions-compliance purposes even after you ask for deletion; in that case we will restrict processing rather than erase.

You may also complain to your local data protection authority (in the EEA, your national supervisory authority; in the UK, the Information Commissioner's Office). We would appreciate the chance to address your concern first.

8. Security

We apply administrative, technical and organisational measures appropriate to the risk, including encryption in transit and at rest, access controls and least privilege, audit logging, vendor due diligence, and secure development practices. We hold no private keys, so a compromise of our systems cannot by itself move your assets.

No system is perfectly secure, and we cannot guarantee absolute security. The most significant risk to your assets is on your side: your device, your email or identity-provider account, your wallet authentication factors, and any transaction you sign. Use a strong, unique password and two-factor authentication on the account you sign in with, keep your device updated, and never share recovery details. We will never ask you for your seed phrase, private key or recovery factors.

If a personal data breach occurs that is likely to result in a risk to your rights, we will notify you and the relevant authorities as required by applicable law.

9. Cookies and similar technologies

The web app uses cookies, local storage and similar technologies for: strictly necessary purposes (session, authentication, security, load balancing); preference storage; and analytics and performance measurement. Where required by law, we request your consent for non-essential cookies and provide a means to withdraw it. You can also control cookies through your browser, though blocking strictly necessary cookies will break the App.

The iOS app does not use cookies but uses equivalent local storage and SDK identifiers. We do not use the App Tracking Transparency identifier (IDFA) for cross-app tracking and do not engage in third-party behavioural advertising.

10. Push notifications and Live Activities

If you enable them, we send push notifications and, on iOS, Live Activities for bounded events such as a detected purchase, a funding prompt, an order submitted or confirmed, or a reward unlock. To do this we process your device push token and the relevant transaction record. You can disable notifications at any time in the App or in your device settings; service-critical notices may still be sent by email while your Account is open.

11. Children

The App is for adults. It is not directed at, and must not be used by, anyone under 18. We do not knowingly collect personal data from a minor. If we learn that we have, we will delete it and close the Account. If you believe a minor has provided us data, contact hello@trybeaver.app.

12. Third-party services

Privy, Data Aggregators, on-ramp providers, exchanges, token issuers, the Apple App Store and any site you reach from a link in the App each operate under their own privacy policies. Those policies, not this one, govern what they do with your data. Read them. We are not responsible for their practices.

13. Changes

We may update this policy. We will change the "Last updated" date and, for material changes, notify you in the App or by email before the change takes effect. Continued use after the effective date constitutes acceptance.

14. Contact

Freddy Made another one LLC

1209 Mountain Road Pl NE, Ste R

Albuquerque, NM 87110

United States

Privacy: hello@trybeaver.app

Support: hello@trybeaver.app

Representative: freddy@made-another.one