Last updated March 2025

This Privacy Policy (“Policy”) describes how dYdX Operations Services Ltd., a Cayman Islands-exempted company and its affiliates (“DOS”, “we”, “us” or “our”) may collect, process, use, store and disclose personal information as data controller, and your rights and choices regarding this information. For the purposes of this Policy, “personal information” is any information related to an identified or identifiable natural person.

Please read this Policy carefully. You can contact us with questions using the details in the “Contact Us” section of this Policy.

Applicability of this Policy

This Privacy Policy applies to the website operated by us and located at https://dydx.forum/ (the ‘Site’), which facilitates discussions on DAO governance, including user-generated content, which is publicly accessible unless deleted by the user or removed under moderation policies.

What we collect

When you interact with the Site, we and/or our service providers may collect personal information about you from different sources listed below.

Personal information you provide to us or collected via automated means

• Contact Information, such as your name and email address.

• Profile Information, such as username, avatar, bio, personal description, links to personal websites.

• Forum Content, such as posts, replies, private messages, or uploaded attachments.

• Online identifiers, such as username, geo-location (country), browser fingerprint, operating system, browser name and version, and IP addresses.

• Information from cookies and other tracking technologies. We, and third parties we authorize, may use cookies, web beacons, and similar technologies to record your preferences, track the use of the Site, and collect information about the use of the Site, as well with other information we collect about you. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If you do so, please note that some parts of the Site may not function properly.

• Blockchain-Linked Data, such as on-chain actions performed as part of DAO governance discussions and which may be associated with your forum activity.

The personal information mentioned above is mandatory to allow us to perform the Site as set out in the Terms of Use.

In certain circumstances, we may anonymize your personal information so that it can no longer be associated with you.

How we use information

We will use your personal information as disclosed herein, if we have a contractual relationship or your consent or if it is in our legitimate business interest to use the personal information notably to ensure that the website can function properly, promote our services and realize statistics or if there is another lawful basis to do so. We can only rely on our legitimate business interest, if it is fair and reasonable to do so.

We may use your personal information to make the Site available in accordance with our Terms of Use and for:

• Providing the Site. We may use the personal information we collect to provide, maintain, and improve the Site, including as we described in the Terms of Use. This includes using your personal information to:

  • operate, maintain, customize, measure, and improve the Site, and manage our business;
  • enabling and maintaining DAO governance discussions by ensuring proper functionality, improving user experience, providing moderation actions, and upholding transparency and integrity in governance processes, including measures to mitigate manipulation and ensure fair participation; and
  • send information, including confirmations, notices, updates, security alerts, and support and administrative messages.

• Safety and security. We may use your personal information in our efforts to:

  • protect, investigate, and prevent against fraudulent, unauthorized, or illegal activity;
  • monitor and verify identity or service access, and combat spam, malware or security risks;
  • perform internal operations necessary to provide the Site, including to troubleshoot software bugs and operational problems;
  • enforce our agreements with third parties, and address violations of our Terms of Use or agreements; and
  • comply with applicable laws and regulations.

• Research and development. We may use your personal information for testing, research, analysis, product development, and to develop new features and products relating to the Site.

• Legal and regulatory compliance. We may use your personal information to enforce compliance with our terms and policies, including our Terms of Use, to defend ourselves against legal claims or disputes, for identity verification purposes, to investigate or address claims or disputes relating to use of the Services, as permitted by applicable law, and as requested by regulators, government entities, or official inquiries.

• Marketing. We and our service providers may use your personal information to market the Site and other products and services to you. This may include sending you communications about the Site, features, promotions, surveys, news, updates, and events, and managing your participation in these promotions and events. If you do not want us to send you marketing communications, please opt out by contacting us using the details in the “Contact Us” section of this Policy or by following instructions in any email communication you receive from us.

When we share and disclose information

We may share your information in the following circumstances, or for any other purpose:

• To Comply with our legal obligations. We may share your information: (a) to cooperate with government or regulatory enquiries or investigations; (b) when we are compelled to do so by a subpoena, court order, or similar legal procedure; (c) when we believe in good faith that the disclosure of personal information is necessary to prevent harm to you, us, or another person; (d) to report suspected illegal activity; or (e) to investigate violations of our Terms of Use, agreements for other products or services, or any other applicable policies.

• With Service Providers, vendors, partners or other third parties. We may share your personal information with service providers, vendors, partners or other third parties who need access to personal information to provide services to us.

• Affiliates. We may share your personal information with our subsidiaries and affiliates.

• During a change to our business. If we engage in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of our assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities, some or all of your personal information may be shared or transferred.

Transfer outside the EU or adequate country

We, our affiliates, subsidiaries, and third-party providers may process your personal information outside of your home country.

We will employ a suitable transfer mechanism as required by applicable data protection laws and ensure that your personal information receives an adequate level of protection (e.g. Standard Contractual Clauses adopted pursuant to applicable data protection laws of the EU).

For more information about how we transfer personal information internationally, please contact us using the details in the “Contact Us” section of this Policy.

Data retention

We retain your personal information as long as is necessary to fulfill the purposes for which it was collected and processed, in accordance with good practices in accordance with applicable laws, or until you withdraw your consent (where applicable). We reserve the right to remove or edit posts that violate our Terms of Use or applicable laws, including content that is defamatory, abusive, or violates privacy rights.

Users may request post-deletion of data such as posts and replies, but full erasure cannot always be guaranteed due to archival or regulatory obligations.

Personal information required to establish proof of a right or contract, or to comply with a legal obligation, will be kept for the period stipulated by the law in force.

Your rights and choices

You may submit requests relating to the personal information that we hold about you, including requests to access, correct/update, delete, restrict the processing of, or transfer such information. Please note that, in order for us to review and respond to such requests, we will require you to verify your identity.

You have certain data protection rights under the applicable data protection law, including the following:

1. You have the right to access personal information we hold about you and to ask that your personal information be corrected, or (in some limited circumstances) erased.
2. You also have the right to object to receiving direct marketing, or to request that we restrict processing.
3. You have the right to ask us to stop processing your personal information.
4. You have the right to be informed of a personal data breach (unless the breach is unlikely to be prejudicial to you).
5. You have the right to have your personal information transmitted directly to another party in a portable or machine-readable format (right to data portability).
6. You have the right to withdraw your consent for processing for which the consent is required, at any time.
7. You have the right to file a complaint regarding our data protection practices with your relevant data protection authority.

For EU individuals

Please note that the rights described above are not all absolute and may not apply in all circumstances. For more information about your rights please refer to Chapter III of GDPR.

We will review and respond to such requests without exceeding the maximum period of one month, or in the case of a complex request, we will notify you of the additional one-month period. We may have valid legal reasons to refuse your request, and will inform you if that is the case.

To submit such a request, contact us using the details in the “Contact Us” section of this Policy.

If you find necessary to file a complaint, you can find the relevant EU data protection authority here.

Security

We undertake to protect the security, confidentiality and integrity of your personal information provided on the website through the use of physical and logistical security measures.

No internet system can be completely secure. Therefore, although we take steps in an effort to secure your information, we cannot guarantee that your information, searches or other communication will always remain secure.

Third-party matters

Through the Site, we may provide links to websites, mobile applications or any other online assets that are not owned or controlled by us. This Policy does not apply to those websites. If you choose to use those websites, please check the legal and privacy statements posted on each website, mobile application or the online asset you access to understand their privacy practices. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Changes to this Policy

Please note that we may change this Policy from time to time. If we make any changes to this Policy, we will change the last updated date above and, in some cases, we will provide further notice (for example, by publishing a statement on our website home pages or by sending you an e-mail). We encourage you to review the Policy whenever you interact with us to stay informed about our privacy practices, and to stay informed about the methods you can use to control the use of your personal information and protect your privacy.

Cookies

Cookies are small text files of letters and numbers that are stored and accessed on your browser or the hard drive of your device. Like many companies online, we use services provided by Google (as defined herein) and other companies that use cookies and other tracking technology to collect directly from your device information about your browsing activities, your interactions with websites, and the device you are using to connect to the Internet.

We may use these technologies to improve your experience when you browse or use the Site, enhance the functionality of the Site, aid in our security efforts, and measure the use and effectiveness of the Site.

This Policy also governs:

• Pixels: A tracking pixel is a small amount of code on a web page or in an email notification that typically works in conjunction with cookies to identify users and track user behavior. We use pixels to learn whether you have interacted with certain web or email content.

• Local storage: Local storage is a technology that allows a website or application to store information locally on your computer or mobile device. We may use local storage, including HTML5, to customize what we show you based on your content consumption and other past interactions with the Site.

• Device identifiers: Device identifiers are distinctive numbers associated with a smartphone or similar handheld device. We may use mobile device identifiers for purposes set out in this Policy, for example to recognize your device when you return to the Site or otherwise use the Site.

We use the following types of cookies:

• Strictly necessary cookies: These cookies are necessary for the Site to function and cannot be switched off in our systems. They may allow us to enable security, prevent fraud and debug the Site and are usually only set in response to actions made by you which amount to a request for use of the Site, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but then some parts of the Site will not work.

• Analytical or performance cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of the Site. They help us to know which pages are the most and least popular and see how visitors move around the Site.

• Functional cookies: These are used to recognize you when you return to the Site. This may enable us to personalize our content for you and remember your preferences.

• Marketing cookies: These cookies are used by third-party advertisers or publishers to display personalized advertising. They do this by tracking your activity across websites.

We use both persistent cookies and session cookies. Persistent cookies stay on your device for a set period of time or until you delete them, while session cookies are deleted once you close your web browser. The cookies placed through your use of the Site are either set by us (first-party cookies) or by a third party at our request (third-party cookies). We do not control these third parties’ cookies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

You have a number of options to object, control or limit how we, our partners, and other third parties use cookies. You can block cookies through the mechanisms described below. However, note that cookies are important to many aspects of the Site. If you disable certain cookies, you may not be able to enjoy all features of the Site.

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.

• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

• Using privacy plug-ins or browsers. You may be able to block websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like PrivacyBadger, Ghostery or uBlock Origin, and configuring them to block third-party cookies or trackers. We do not endorse, control, or have any responsibility for such plug-ins.

• Advertising industry opt-out tools. You may also be able to use the opt-out options set forth below to limit use of your information for interest-based advertising by participating companies. Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

  • Digital Advertising Alliance: http://optout.aboutads.info
  • Network Advertising Initiative: http://optout.networkadvertising.org/
  • Google: https://adssettings.google.com

You can obtain a complete list of our analytic providers by contacting us by using the details in the “Contact Us” section of this Policy.

Do Not Track

Do Not Track (“DNT”) is a concept promoted by certain regulatory authorities and industry groups for development and implementation of a mechanism that would allow internet users to control the tracking of their online activities across websites. Currently, various browsers (including Internet Explorer, Firefox, and Safari) offer a DNT option that allows a user to set a preference in the browser to not have his/her activities on the internet tracked. You can usually access your browser’s DNT option in your browser’s preferences. When a user’s browser is set to DNT, some cookies and other tracking technologies may become inactive, depending on how the website visited responds to DNT browser settings. If that occurs, the website visited will not recognize you upon return to that website, save your passwords or user names, and some other features of a website may become unavailable or not function properly. Hence, if you enable Do Not Track (DNT) in your browser, we will respect this preference where technically feasible. However, essential tracking related to security, fraud prevention, and necessary functionality may still operate.

Contact Us

Please contact us if you have any questions about this Policy. You may contact us at info@dydxopsservices.com