Privacy Policy Launchpad

EFFECTIVE DATE: June 2, 2026

Launchpad Investments Ltd., a British Virgin Islands business company ("Launchpad," "we," "us," or "our"), provides cryptocurrency-related services, including consumer mobile and desktop applications, non-custodial wallet services, software connectivity services, and command-line and agentic interfaces (collectively, our "Services"). This Privacy Notice (this "Notice") describes how we collect, use, share, and protect your personal data in connection with your access to, or use of, the Services. 

By using the Services, you acknowledge that you have read and understood this Notice. If you do not agree with our processing of your personal data as described in this Notice, please do not use the Services. 

Who We Are

Launchpad Investments Ltd. is a British Virgin Islands business company and a wholly owned subsidiary of MoonPay Inc., a Delaware corporation. Launchpad is the data controller for personal data processed through the Services as described in this Notice. 

If you have questions about this Notice, please contact our Data Protection Officer at [email protected]. 

Scope of This Notice

This Notice applies to personal data we process in connection with the following Services: 

• App Services: The MoonPay.com website and any other consumer mobile or desktop applications offered by Launchpad or the MoonPay Group. 
• Wallet Services: The use of a MoonPay Account, including the creation and management of non-custodial wallets. 
• Software Services: The ability to connect your MoonPay Account to other wallets you may hold at cryptocurrency exchanges or self-custody wallets, in order to access those wallets from the MoonPay platform. 
• MoonPay CLI (including when accessed via the MoonAgents App): The command-line software interface that enables you to access, initiate, or transmit requests to certain connected services from a local computing environment. 
• MoonAgents App: The desktop application that provides users with access to the MoonPay CLI, including related binaries, scripts, software development kits, documentation, updates, and associated endpoints. 
• Dawn CLI: The command-line software interface that enables you to research prediction markets, build and deploy trading strategies, and interact with third-party prediction market platforms from a local computing environment. 

This Notice does not apply to other MoonPay Group services that are governed by separate privacy policies. For information about those services, please see the MoonPay Global Privacy Policy at moonpay.com/legal/privacy_policy. 

This Notice also does not apply to personal data processed by third-party services you may access through our Services, including third-party AI agents, large language models, prediction market platforms, or blockchain networks. Those third parties maintain their own privacy policies governing their processing of your data. 

Our Role as Data Controller

Launchpad acts as a data controller in respect of personal data processed through the Services. This means that Launchpad determines the purposes and means of such processing. 

Where you use our Services to interact with third-party services (such as blockchain networks, prediction market platforms, or wallet providers), those third parties are separate data controllers for the data they collect from you directly. For information about how those third parties collect and use your data, please refer to their respective privacy policies. 

Personal Data We Collect

We collect personal data in a variety of ways depending on how you interact with us and our Services. The categories of personal data we collect include: 

Information You Provide to Us

• Account Information: Email address, phone number, one-time passwords, login credentials, and other information required to create and manage your MoonPay Account. 
• Wallet Information: Blockchain wallet addresses and information about wallets you connect to the Services. 
• Transaction Information: Information about transactions made through our Services, such as transaction amounts, currency preferences, token types, destination addresses, timestamps, and other parameters required to facilitate transactions. 
• Preferences: Settings and preferences you select within the Services. 
• Communications and Support Data: Correspondence with our team, survey responses, and information provided to our customer support team. 

Information We Collect Automatically

• App, Browser, and Device Information: Information about the device, operating system, and browser you use, and other device characteristics or identifiers. 
• IP Address: Your Internet Protocol address collected when you access the Services. 
• Product Usage Information: Activity information about what you view or interact with while using the Services, including how you use our Services and which features you access. 
• Diagnostic and Troubleshooting Information: Service-related diagnostic and performance information, including timestamps, crash data, performance logs, and error messages. 
• Cookies and Similar Technologies: Information collected through cookies and similar tracking technologies. Please refer to our Cookie Policy for more information. 

Information Specific to CLI and Agent Products

When you use the MoonPay CLI, MoonAgents App, or Dawn CLI, we may additionally collect: 

• Authentication Data: Session tokens, access tokens, or similar authentication credentials issued following successful authentication through the MoonPay CLI Portal or MoonAgents App login. 
• Command Telemetry Data: Anonymous usage metrics, such as command names, timestamps, success/failure status, and CLI version, collected for product improvement purposes. 
• Strategy Deployment Metadata: Where you deploy trading strategies through Dawn CLI, we may collect metadata relating to strategy deployment and execution. 

We do not collect through the CLI and Agent products: private keys, strategy source code, or full command input text. 

Information Collected from Other Sources

• Blockchain Data: We may analyze public blockchain data, including transaction IDs, digital signatures, transaction amounts, timestamps, and wallet addresses. 
• MoonPay Group Affiliates: We may obtain information about you from our affiliates as a normal part of conducting business. 

What We Do Not Collect

Launchpad does not collect, store, or have access to private keys, seed phrases, signing credentials, or recovery material, and cannot initiate transactions on your behalf. Where you use third-party AI agents or large language models in connection with MoonPay CLI, MoonAgents App, or Dawn CLI, we do not collect or have visibility into the prompts, instructions, or outputs you exchange with those third-party tools. Chat sessions associated with the MoonAgents Desktop App are stored locally on your device and are not transmitted to or stored by Launchpad. 

How We Use Personal Data

We use your personal data for the following purposes: 

• Service Operation and Delivery: Operating, maintaining, and providing the Services to you, including enabling wallet creation, processing transactions, facilitating connections to third-party services, and executing user-initiated requests through the CLI and Agent products. 
• Account Management: Creating and maintaining your MoonPay Account, authenticating your identity, and managing your relationship with us. 
• Customer Support: Addressing your requests for support and responding to inquiries. 
• Service Communications: Sending you administrative or account-related communications about the Services, including security updates or transaction-related information. 
• Safety, Security, and Integrity: Verifying accounts and related activity, detecting and preventing fraud, unauthorized use, and other harmful or unlawful behavior, and maintaining the security and integrity of the Services. 
• Product Improvement: Operating, maintaining, debugging, and improving the Services, including analyzing anonymized usage data from CLI telemetry to inform product development, identify reliability issues, and improve documentation. 
• Compliance and Legal Obligations: Complying with applicable laws, screening wallet addresses and conducting compliance-related checks, and responding to lawful requests from governmental authorities. 
• Marketing Communications: With your consent where required, sending you promotional communications about our Services. You may opt out of marketing communications at any time. 

Legal Basis for Processing

We process personal data in accordance with the British Virgin Islands Data Protection Act, 2021 (the "DPA") and only where a lawful basis for processing exists. Our lawful bases for processing include: 

• Express Consent: You have consented to the processing of your personal data for specified purposes.
• Contractual Necessity: Processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. 
• Legal Obligations: Processing is necessary for compliance with a legal obligation to which Launchpad is subject. 
• Vital Interests: Processing is necessary to protect your vital interests or those of another person. 
• Administration of Justice: Processing is necessary for the administration of justice or the exercise of functions conferred by law. 

How We Share Personal Data

We disclose personal data to third parties only where necessary for the purposes described above and only to the extent required to operate and support the Services. Such third parties may include:

• Blockchain networks, protocols, and platforms with which the Services interoperate, including third-party wallet providers, prediction market platforms (such as Polymarket), and decentralized exchanges acting as independent controllers. 
• Service providers that support the operation of the Services, such as providers of technical infrastructure, hosting, data analytics, security, communications, payment processing, and customer support. 
• Professional advisers, including legal, accounting, and audit advisers. 
• Entities affiliated with Launchpad, including other entities within the MoonPay Group, where relevant for internal administration, compliance, or reporting purposes. 
• Regulators, law enforcement, and government authorities, where required to comply with applicable laws or regulations, court orders, or lawful requests, or to detect, investigate, prevent, or address fraud and other illegal activity. 
• Third parties in connection with a corporate transaction, such as a merger, reorganization, sale of assets, or similar event, including in the context of insolvency or liquidation. 

We do not sell personal data and do not share personal data for targeted or behavioral advertising purposes. 

International Data Transfers

Launchpad and its service providers may process personal data in jurisdictions outside the British Virgin Islands where this is necessary to operate and support the Services. 

Where we transfer personal data internationally, we implement appropriate safeguards to ensure that such transfers are protected to a level consistent with applicable legal requirements, which may include standard contractual clauses, adequacy assessments, or other approved transfer mechanisms. 

Data Retention

We retain personal data only for as long as necessary to fulfill the purposes described in this Notice, unless a longer retention period is required or permitted by law. 

When determining retention periods, we consider the nature of the data, the purposes for which it was collected, our legal obligations, and the potential risk of harm from unauthorized use or disclosure. When personal data is no longer required, we delete or anonymize it in accordance with our data retention schedules. 

Due to the nature of cryptocurrency transactions, information associated with our Services may be recorded on public, decentralized blockchain ledgers which Launchpad does not control. This data, including wallet addresses, transaction hashes, amounts, and timestamps, is immutable and cannot be modified or deleted by Launchpad. 

Data Security

We implement technical and organizational measures designed to protect personal data against unauthorized access, alteration, disclosure, or destruction. 

These measures include, where appropriate:

• Encryption of data in transit and at rest;
• Access controls and authentication mechanisms;
• Regular review of our security practices;
• Measures for ensuring the reliability, integrity, and competence of personnel having access to personal data; and
• Internal policies and procedures for handling personal data in accordance with generally accepted industry standards. 

Where a data processor carries out processing on our behalf, we ensure that the processor provides sufficient guarantees in respect of technical and organizational security measures and take reasonable steps to ensure compliance with those measures. 

Your Privacy Rights

Subject to applicable law, you have certain rights regarding your personal data. These rights include: 

• Right of Access: You may request access to your personal data and a description of the data and purposes for processing. 
• Right of Rectification: You may request that we rectify any personal data which is incomplete, incorrect, misleading, excessive, or which is not relevant to the purpose for which it is held. 
• Right to Prevent Processing for Direct Marketing: You may require us to stop or not begin processing your personal data for direct marketing purposes. 
• Right to Withdraw Consent: Where our processing is based on your consent, you may withdraw your consent at any time. Please note that withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. 

Given the pseudonymous nature of wallet data, we may require additional information to verify your identity before responding to certain requests. Please note that transaction data recorded on public blockchains cannot be deleted or modified by Launchpad. 

To exercise your rights, or if you have any questions about our processing of personal data, please contact us at [email protected]. 

Depending on your location, you may also have the right to lodge a complaint with the BVI Information Commissioner (once appointed) or your local data protection authority. 

Children's Personal Data

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you are under the age of 18, please do not use the Services or provide any personal data to us. If we become aware that a user is under the age of 18, we will take steps to close their account and delete the associated personal data as soon as possible.

Third-Party Services

Our Services may interact with third-party services, including blockchain networks, wallet providers, prediction market platforms (such as Polymarket), decentralized exchanges, AI agents, and large language models. These third-party services are not operated by Launchpad and this Notice does not apply to the processing of personal data by those third parties. 

In particular, where you use a third-party AI agent or large language model (such as Claude Code or OpenAI Codex) in connection with MoonPay CLI, MoonAgents App, or Dawn CLI, those tools are third-party software that you independently source, configure, and direct. The collection and processing of data by those tools is governed by their own privacy policies. 

We encourage you to review the privacy policies of any third-party service you access through or in connection with the Services. 

Cookies

Our websites and applications may use cookies and similar technologies to collect information about your browsing activities. For detailed information about the cookies we use and how to manage your preferences, please refer to our Cookie Policy available at https://www.moonpay.com/legal/cookie_policy.

Changes to This Notice

We may update this Privacy Notice from time to time to reflect changes in our processing activities or changes in applicable data protection law. If we make material changes, we will update the effective date at the top of this Notice and, where practicable, notify you by email or through the Services. 

Your continued access to or use of our Services after any changes constitutes acceptance of the updated Notice. We encourage you to review this Notice periodically. 

How to Contact Us

If you have questions or concerns regarding this Privacy Notice, wish to exercise your privacy rights, or have a complaint, please contact our DPO at [email protected].