Privacy Policy

This policy explains what Clubhouse.Fund(“we”, “us”, “our”) does with personal data when you use the website at clubhouse.fundand its interface (the “Interface”). For data-protection purposes, Clubhouse.Fund is the controller of that data.

It covers the Interface and nothing else. It does not cover the blockchain, the smart contracts deployed to it, your wallet, the RPC providers and explorers you route through, the decentralised exchanges your swaps execute against, or any other front-end built on the same open-source contracts. We do not control those, we are not the controller for them, and sections 6, 7 and 9 explain what that means for you in practice.

Read this alongside our Terms of Service, which governs your use of the Interface.

Connecting a wallet requires no email address, no name and no account. In that mode the only thing we hold about you is your public wallet address and whatever that address has already done on-chain — which was public before you arrived, and which we read rather than collect.

We collect personal data only when you choose to create an account. The features that need one — Clubs, saved collections, creator tools — are the reason to do so. If you would rather we held nothing, use a wallet alone: the protocol does not care either way, because it has no idea who you are.

We ask for the minimum the feature needs, and we would rather not hold data we have no use for. Every field in section 3 that is marked “if you add it” is genuinely optional and the account works without it.

Device and log data means the ordinary technical record a web service keeps: IP address, browser and operating system, referring page, pages viewed, timestamps, and errors thrown. We use it for security, abuse prevention and debugging, and we do not use it to build a profile of you or to target advertising.

A wallet signature is not a transaction. When you sign in with a wallet, you sign a message proving you control the address. It moves nothing, approves nothing and costs no gas. If a Clubhouse prompt ever asks you to sign something that would transfer an asset or grant an approval in order to log in, it is not us.

To be explicit, we do not collect or ask for:

• Private keys or seed phrases. We never have them, no part of the Interface will ever request them, and anyone who does is trying to rob you.
• Government identity documents. There is no KYC step to use the Interface.
• Payment card or bank details. All payment happens on-chain, from your wallet, directly to a contract. Nothing passes through us.
• Precise geolocation, biometrics, or device fingerprinting for tracking.
• Special category data — health, religion, political opinions, sexual orientation, trade union membership and the like. Please do not put any of it in a profile or a Club post.

We do not use your data to train machine-learning models, and we make no automated decisions producing legal or similarly significant effects about you.

• to operate the Interface, authenticate you and keep you signed in;
• to show your profile, collections and Club activity to other members;
• to send service messages — verification, password resets, security and policy notices;
• to review creator whitelist applications and record the outcome;
• to attribute referrals and invites where you used one;
• to detect, investigate and prevent fraud, abuse, market manipulation and security incidents;
• to debug, measure and improve the service;
• to comply with legal obligations, respond to lawful requests, and establish or defend legal claims.

Where the law requires a legal basis, we rely on: contract — operating the account you asked us for; legitimate interests — security, abuse prevention, and improving the service, balanced against your rights; consent — where we ask for it, which you can withdraw at any time; and legal obligation — where we must.

We do not sell personal data, we do not share it for advertising, and we do not engage in cross-context behavioural advertising. We have no advertising business, and there is nothing in our model that would be improved by building a profile of you.

A deletion request can only ever reach our database. It cannot reach the chain. If you ask us to erase your data we will erase our copy — but your wallet address, its balances and its entire transaction history will remain public, and every block explorer, indexer, analytics firm and archival node that already copied it will still have it.

Linking a wallet to an account creates a connection between your email identity and that permanent public history. Under our Terms that link is also permanent on our side and cannot be undone by you. We can delete our record of the association; we cannot delete the chain, and we cannot retrieve it from anyone who observed the association while it was visible.

Consider this carefully before linking a wallet whose history you would rather not tie to your identity. Using Clubhouse with a wallet alone, as described in section 2, avoids creating the connection in the first place. This is a property of public blockchains and a consequence you accept when you use one — not something we can engineer around.

The Clubhouse protocol is a set of open-source smart contracts, published under the MIT licence and deployed to a public blockchain. Contracts have no analytics, no logs, no accounts, no cookies and no servers. They cannot see your IP address, your email or your browser, and they hold no personal data of any kind — only addresses, balances and token ids, which the chain already publishes.

Everything this policy describes therefore concerns the front-end alone. Three consequences follow, and they are worth stating plainly:

• You are not obliged to use our front-end. The contracts are permissionless: you can interact with them from a block explorer, your own interface, or a script, and we will then have no record of you at all.
• Blocking or deleting you here changes nothing on-chain. If we suspend an account or geofence a region, that restricts our Interface only. The protocol keeps running, for you and for everyone.
• We cannot act on the chain on your behalf. We hold no key that can move, freeze, censor or redact anything. Where a privacy right would require doing so, we cannot satisfy it — not as a matter of policy, but because the capability does not exist.

We disclose personal data only in these situations:

• Service providers acting on our instructions and under contract — hosting (HOST / REGION), email delivery, and error monitoring. They may process data only as we direct.
• Other users, for anything you choose to make public: your profile, your collections, your Club posts, your username against on-chain activity.
• Analytics — aggregate traffic measurement, as described in section 10.
• Legal and safety — where we must comply with law, respond to a lawful request, enforce our Terms, or protect the rights and safety of users or the public. Where we are permitted to tell you about such a request, we will.
• Corporate transactions — if we are involved in a merger, acquisition or sale of assets, data may transfer as part of it, remaining subject to this policy.

We do not disclose personal data to data brokers, advertisers or ad networks, and we do not publish your email address.

Using a decentralised application necessarily involves third parties, and they see things we do not:

• Wallets and connection services see your address, the network you are on, and what you are asked to sign.
• RPC and node providers serve the chain data the Interface renders, and may log your IP address alongside the addresses you query.
• Block explorers and indexers republish on-chain activity, often with their own labelling and analytics.
• Decentralised exchanges execute swaps against public contracts, where nothing is “shared” so much as published to everyone at once.
• The public mempool exposes your pending transaction before it is confirmed, to anyone watching.

These parties are independent of us and handle your data under their own policies, not this one. We do not choose them for you, do not audit them, and are not responsible for what they do. The same applies to any site you reach through a link on the Interface.

We keep a session token in your browser’s local storage so you stay signed in, and the launch tool keeps a draft of an in-progress deployment there so it survives a refresh. Both stay until you sign out or clear site data. They are stored by your browser, on your device.

We use Google Analytics to measure aggregate page traffic. It sets its own identifiers and Google processes that data under its own policy as an independent controller for some purposes. You can block it with any standard browser control, content blocker or Do Not Track extension, and the Interface will work exactly as before.

We use no advertising cookies, no retargeting pixels and no cross-site tracking networks.

Depending on where you live, you may have rights to access, correct, export, delete or restrict the personal data we hold, to object to processing based on legitimate interests, and to withdraw consent. We honour these regardless of where you live, so far as we are able.

• Access and correction — most profile fields are editable directly in your account settings.
• Deletion — you can delete your account, which removes the data in section 3. We cannot delete on-chain records, for the reasons in sections 6 and 7, and we may retain the minimum needed to meet a legal obligation or to prevent a banned user returning.
• Export — request a machine-readable copy of your account data at privacy@clubhouse.fund.
• Objection and restriction — tell us at the same address and we will consider it against the basis we rely on in section 5.
• Consent — where we rely on it, you may withdraw it at any time, without affecting processing already carried out.
• Marketing — we send service messages, not marketing. Any future marketing email will carry an unsubscribe link and will be optional.

We respond within 30 days, and will tell you if we need longer where the law allows an extension. We may need to verify that a request comes from you — usually by confirming control of the account email or the linked wallet — and we will not act on a request we cannot verify. We will never discriminate against you for exercising these rights, and using them will not degrade your access to the Interface.

We keep account data for as long as your account exists, and afterwards only as long as needed for the purposes in section 5 or to meet a legal obligation. Our working periods:

• Account data — until you delete the account, then removed from live systems.
• Backups — a deleted record may persist in backups for up to 30 days before being overwritten in the ordinary rotation.
• Device and log data — up to 12 months, then deleted or aggregated.
• Support correspondence — up to 24 months.
• Records kept for legal reasons — for as long as the relevant limitation period or obligation requires.
• On-chain data — forever, by the network, outside our control entirely.

We use access controls, encryption in transit, hashed password storage and short-lived verification tokens, and we limit who on our side can reach production data. No service is perfectly secure, and we cannot guarantee absolute security.

Your wallet’s security is yours to maintain. It is the single most important control over your assets, and it is the one we cannot help you recover. A compromised seed phrase loses everything, permanently, and nothing in our security posture changes that.

If a breach affects your personal data, we will notify you and any regulator as the law requires. Our liability arising from your use of the Interface is limited as set out in the Terms of Service, to the extent the law permits — nothing in that limitation restricts the statutory data-protection rights described in section 11, which we do not ask you to waive.

The Interface is not intended for anyone under 18, and we do not knowingly collect their personal data. If you believe a child has created an account, contact us at privacy@clubhouse.fund and we will remove it.

The Interface is available internationally and our infrastructure is in HOST / REGION. Using it may involve transferring your data across borders, including to countries whose data-protection laws differ from your own. Where required, we rely on an approved transfer mechanism such as the European Commission’s standard contractual clauses, and you may request details of the safeguards in place.

Blockchain data is inherently global: once written, it is replicated to nodes everywhere, by everyone, with no transfer mechanism available to anyone.

If you are in these regions, the controller of your personal data is Clubhouse.Fund, REGISTERED ADDRESS. You have the rights in section 11 and the right to lodge a complaint with your local supervisory authority — we would appreciate the chance to address it first. Our legal bases are set out in section 5, and our retention periods in section 12.

Residents of California and of other states with comparable laws have the rights in section 11, including the right to know what we collect, the right to correct it, the right to request deletion, and the right to be free from discrimination for exercising them. You may use an authorised agent, and we will verify the authorisation.

We do not sell or share personal information as those terms are defined in the CCPA/CPRA, we have not done so in the preceding twelve months, and we do not use personal information for cross-context behavioural advertising. We do not knowingly sell the personal information of minors.

We may update this policy. We will change the date at the top and, for material changes, give notice through the Interface before they take effect. Continuing to use the Interface afterwards means you accept the updated policy.

Clubhouse.Fund, REGISTERED ADDRESS.

Privacy enquiries and rights requests: privacy@clubhouse.fund. General support: support@clubhouse.fund. See also our Terms of Service.