Cohven Privacy Policy

Effective date: August 25, 2026

Controller: cohven ("cohven", "we", "us", "our")

Contact: help@cohven.com

This Privacy Policy describes how we collect, use, share and delete information when you use cohven.com, app.cohven.com and related services (the "Service"). By using the Service you acknowledge this Policy. Terms not defined here have the meaning given in the Terms of Service.

1. Information We Collect

1.1. Information you provide.

(a) Email address, used as your account identifier and for one-time sign-in codes and service emails.

(b) Blockchain addresses you submit for tracking, including your own address and the addresses in your cohort. These are public blockchain identifiers; we treat the fact that you submitted them as your account data.

(c) Communications you send to us (for example, support requests to help@cohven.com).

(d) Referral data, if you participate in the referral program: your referral code, referred payments, and the payout address you provide.

1.2. Payment information. When you pay, we record the paying wallet address, transaction hash, amount, asset, network, plan and period. We never receive or store private keys or seed phrases. Payment transactions occur on the public Polygon blockchain and are publicly visible by their nature.

1.3. Information collected automatically. Log and usage data: IP address, approximate location derived from IP, browser and device type, pages viewed, interface events, timestamps, and error diagnostics. We use cookies and localStorage for strictly necessary purposes (session, language preference) and for first-party analytics of Service usage.

1.4. Public blockchain and Polymarket data. The Service continuously processes publicly available data from the Polymarket public API and public blockchains (trades, positions, order book, price history) relating to addresses tracked by our users. This data is public by design and may relate to third parties who are not our users. We do not attempt to identify the natural persons behind blockchain addresses.

1.5. What we do not collect. We do not request or store private keys, seed phrases or passwords (sign-in uses one-time email codes). We do not perform identity verification (KYC) and do not collect government identifiers, and we hold no custody of funds.

2. How We Use Information

We use the information described above to: (a) provide, operate and secure the Service, including authentication by one-time codes; (b) process payments and activate access; (c) send transactional emails: sign-in codes, period expiry reminders and service notices; (d) provide support and handle refund reviews; (e) operate the referral program and pay rewards; (f) detect, prevent and investigate fraud, abuse and security incidents; (g) analyze aggregated usage to improve the Service; (h) comply with legal obligations. We do not send third-party advertising and we do not sell personal data.

3. Legal Bases

Where the GDPR or similar data protection laws apply to you, we process data on the following bases: performance of a contract (account, access, payments, transactional emails); legitimate interests (security, fraud prevention, service analytics, defense of legal claims); consent, where required (non-essential cookies, if any); legal obligation (accounting and lawful requests).

4. Sharing of Information

We share information only with: (a) infrastructure providers acting on our behalf (hosting, email delivery, blockchain RPC providers, analytics), bound by confidentiality and data-processing obligations; (b) authorities, where required by applicable law or a valid legal request; (c) a successor entity in the event of a merger, acquisition or sale of assets, under this Policy. We do not sell or rent personal data and we do not share it for third-party marketing.

5. Public Nature of Blockchain Data

Blockchain data is public, replicated and generally immutable. Your payment transactions are visible to anyone on the Polygon network independently of us. Deleting your cohven account removes data from our systems but cannot and does not remove anything from any blockchain.

6. Data Retention and Deletion

6.1. Account data is retained while your account is active. When a prepaid period ends without renewal, data is retained for 60 hours; after that, the account and all associated personal data (email, cohort composition, settings, computation history) are deleted automatically and irreversibly.

6.2. Accounts that have never activated a paid period are deleted automatically 60 hours (2.5 days) after registration.

6.3. Addresses no longer tracked by any account are removed from the Service together with their processed history.

6.4. Notwithstanding the above, we retain payment records (transaction hashes, amounts, dates, plan) and support correspondence for as long as required by applicable accounting, tax and anti-fraud laws, and we may retain minimal records needed to establish, exercise or defend legal claims.

6.5. Residual copies may persist in encrypted backups for up to 30 days after deletion and are then purged.

7. Security

We apply technical and organizational measures appropriate to the risk: encryption in transit (TLS), access controls, principle of least privilege, passwordless authentication, and data minimization. No method of transmission or storage is completely secure; we cannot guarantee absolute security. Protect access to your email account, since it controls sign-in to the Service.

8. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, receive a copy of, delete, or restrict and object to the processing of your personal data, and the right to withdraw consent where processing is based on consent. You may exercise these rights by writing to help@cohven.com from your account email. You may also delete your account as described in Section 6. If you believe our processing violates applicable law, you may lodge a complaint with your local supervisory authority.

9. International Transfers

We may process data on servers located outside your country. Where required, we use appropriate safeguards for cross-border transfers, such as standard contractual clauses.

10. Children

The Service is intended for persons 18 years of age or older. We do not knowingly collect data from anyone under 18. If you believe a minor has provided us data, contact help@cohven.com and we will delete it.

11. Changes to this Policy

We may update this Policy by posting a new version with a new effective date; for material changes we will additionally notify you by email. Continued use of the Service after the effective date constitutes acknowledgment of the updated Policy.

12. Contact

Privacy questions and requests: help@cohven.com.

This Policy is drawn up in English. Translations may be provided for convenience; in case of any discrepancy, the English version prevails.