> For the complete documentation index, see [llms.txt](https://chomp-1.gitbook.io/chomp-docs/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://chomp-1.gitbook.io/chomp-docs/policy/privacy-policy.md). # Privacy Policy Version 5.0 \[Effective Date: September 28, 2026] This Privacy Policy describes how Gator Labs, Inc. (“Chomp,” “we,” “our,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies to information we collect when you access or use our website, mobile application, services, products, and any other online services we provide, as well as any other interaction you may have with Chomp (collectively, the “Services”). Please read this Privacy Policy carefully so you understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to interact with the Services. By accessing or using the Services you agree to this Privacy Policy. We encourage you to check this Privacy Policy regularly so you stay informed about our practices and the choices available to you. This Privacy Policy includes the following sections: 1. Information We Collect 2. How We Use Your Information 3. Sharing Information 4. The Chomp Data Product (Commissioned Questions) 5. Sensitive Information 6. Cookies and Similar Technologies 7. Analytics and Advertising 8. Your Choices 9. Your U.S. State Privacy Rights 10. International Transfers 11. What Is Our Legal Basis? 12. How We Protect Your Information 13. Information Storage and Retention 14. Age Restrictions 15. Changes to This Privacy Policy 16. Third-Party Links and Features 17. Contact Us ## 1. Information We Collect Depending on how you use the Services, we may collect information about you in the following ways: ### 1.1 Information You Provide You provide us with information when you create an account, update your profile, participate in Activities (such as structured prompts, nowcasting questions, or challenges), communicate with us by email, or otherwise interact with the Services. ### 1.2 Information Collected Automatically We automatically collect information about your interactions with the Services, including when you view or click content, navigate between pages, or engage with features. ### 1.3 Information from Third Parties We may receive information about you from third parties. Our advertising and business partners may also share information about you with us. ### 1.4 Categories of Information In connection with using the Services, we may collect the following categories of information: Profile Content. Your name, username, profile picture, email address, preferences, and phone number. Self-Reported Demographic Information. Information you choose to provide about yourself, such as your age range and gender. We collect this information in ranges or brackets rather than as exact values, and we do not require you to provide it. Where you decline to provide demographic information, we treat it as absent and do not infer or reconstruct it. Device Data. Device type, software and hardware details, browser type and version, operating system, IP address, approximate location (such as city or general region derived from your IP address), unique device identifiers, and mobile device ID. We do not request access to your device’s precise location, and we do not use precise geolocation (such as GPS-level location) in the Services or in the data product described in Section 4. Log and Usage Data. Information about your activity on the Services, such as content viewed, pages visited, links clicked, usage patterns, and ranking information relative to other users. Response and Contribution Data. Your first-order responses, second-order beliefs about peer responses, calibration and reputation signals, contribution quality scores, and other data generated through your participation in Activities within the Services. This data is used by the platform’s deterministic aggregation mechanism to resolve outcomes endogenously and to calculate informational contribution quality. Some responses may touch on topics that could reveal sensitive characteristics; we describe how we handle that possibility in the Sensitive Information section below. Communication Information. Information about your communications with us and messages sent through the Services. Third-Party Connections and Integrations. If you access the Services through a third-party connection or login, you allow us to access and store certain information from that third party, depending on your settings with that service. Please see the privacy policies and terms for these third parties for more information. Information Collected Through Tracking Technologies. Like many online services, we may use cookies and similar technologies to collect additional usage data and to operate our business. For more information, see the Cookies and Similar Technologies section below. Transaction, Credit, and Rewards Data. Information relating to your participation in Activities, credits earned and staked, account-level accrual balances, rewards redistributed under the platform’s deterministic rules, wallet addresses, and transaction history within the Services. Other Information. Any other information that you choose to provide or that we request. Sometimes we aggregate or de-identify information so that it can no longer reasonably be used to identify you. We do not disclose information through the data product described in Section 4 unless it has first been aggregated and de-identified in accordance with this standard. When we de-identify information, we maintain technical safeguards and processes designed to prevent re-identification, we publicly commit not to attempt to re-identify the information except as permitted by law to test the de-identification, and we contractually require any recipient of de-identified information to honor the same restrictions. We use and disclose aggregated and de-identified information for purposes that may include measuring ad performance, building advertising interest-based segments, and compiling aggregated results. ## 2. How We Use Your Information We use the information we collect in connection with what we consider our Everyday Business Activities, which may include using your information to: Operate and Provide the Services. We may use the information we collect to provide and operate the Services, including maintaining your account and profile, processing credits and Rewards, resolving Activity outcomes through the platform’s deterministic aggregation mechanism, calculating informational contribution quality and reputation signals, contacting you about technical notices or security alerts, and personalizing your user experience. Monitor and Improve the Services. We may use the information we collect to analyze the effectiveness of the Services, review usage patterns, evaluate calibration and scoring accuracy, and improve the Services. Research. We may use information you share with us, or that we collect, to conduct research, product testing, and troubleshooting to help us operate and improve the Services. This may include analysis of aggregated participant responses and contribution quality metrics to evaluate mechanism performance and to demonstrate that informational contribution quality, rather than chance, drives outcomes on the platform. Operate the Data Product. We may use aggregated and de-identified Response and Contribution Data, together with self-reported demographic brackets, to operate the commissioned-question data product described in Section 4. Communicate with You. We may use information we collect to communicate with you about the Services, including offers, promotions, and other news and information we think will be of interest to you. Facilitate a Corporate Transaction. We may use the information we collect during negotiations or in connection with a sale, acquisition, financing, bankruptcy, or similar corporate transaction. Foster Safety and Security. We use the information we collect to provide for the safety and security of our users and the Services. This includes detecting and preventing malicious, deceptive, fraudulent, or illegal activities, monitoring for platform integrity violations including strategic misreporting and exogenous outcome manipulation, improving our security, exercising our legal rights, and complying with applicable law. Content Moderation. We use information we collect to review user-generated prompts and content to ensure that all Activities remain endogenous and do not anchor outcomes on external events, scores, results, award announcements, elections, financial instruments, or other real-world occurrences, and to apply the sensitive-topic guardrails described in the Sensitive Information section. Compliance and Regulatory Purposes. We may use information we collect to maintain jurisdiction-specific legality assessments, fulfill diligence and reporting obligations, and support compliance programs as required by applicable law and regulation. Personalized Advertising. We gather data and work with advertising partners, marketing partners, and third parties to measure the performance of personalized ads on behalf of advertisers. We may combine information collected through registration with information collected automatically using tracking technologies to build models and measure non-sensitive user attributes for advertising. We do not build models or measure attributes for the purpose of inferring your sensitive characteristics, as described in the Sensitive Information section. Depending on your jurisdiction, this activity may be considered targeted advertising or the sharing of personal information, and you may opt out as described in the Your Choices and Your U.S. State Privacy Rights sections. ## 3. Sharing Information In connection with our Everyday Business Activities, we may share information collected from and/or about you in the following circumstances: Service Providers. We may share your information with service providers that perform functions or provide services on our behalf, such as business, professional, or technical support; helping us with our business and the Services; and administering activities in connection with our business. Wallet Infrastructure Providers. We may share information with the third-party provider that powers the platform’s embedded wallet functionality. Chomp uses a non-custodial embedded wallet architecture and does not receive, hold, or have signatory authority or unilateral control over user funds. See the Technical Infrastructure and Your Data section for further detail. Data Product Recipients. We may disclose aggregated and de-identified information, including bracketed demographic information and aggregated responses, to third parties that commission questions through the data product described in Section 4. We do not disclose your name, email address, account credentials, wallet address, or other direct identifiers as part of this product. Advertising Partners. So that we can deliver more relevant content to you and measure the effectiveness of ads. Comply with Laws and Protect Our Rights. We may share your information as we believe to be necessary or appropriate to comply with applicable law and legal processes; respond to requests from public and government authorities; protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit damages. Regulatory and Compliance Disclosures. We may share information with regulatory bodies, gaming authorities, or other governmental entities as required to fulfill jurisdiction-specific diligence, reporting, and monitoring obligations. Investors and Acquirers. We may transfer your information to advisors, investors, potential transactional partners, or other third parties in connection with a merger, acquisition, sale, change in control, financing, bankruptcy, or similar transaction. With Your Consent or at Your Direction. We may share your information with third parties when you direct us to do so or if you have consented to additional sharing. Some of the disclosures described above, including disclosures to advertising partners and to recipients under the data product, may be considered a “sale” or “sharing” of personal information, or processing for purposes of targeted advertising, under certain U.S. state privacy laws. You have the right to opt out of these activities as described in the Your Choices and Your U.S. State Privacy Rights sections. ## 4. Commissioned Questions In the future, third parties may commission questions to be presented within Activities. This section describes how that product works and how we protect your information within it. We do not disclose any information through the data product except in aggregated and de-identified form. The following conditions govern the data product, and where a control described below is not yet in place, we do not make the corresponding disclosures. What is shared. When a third party commissions a question, that party receives aggregated responses to the question together with self-reported demographic brackets associated with those responses. The third party does not receive your name, email address, username, account credentials, wallet address, device identifiers, or other direct identifiers. De-identification and aggregation. Information made available through the data product is aggregated and de-identified before disclosure. We apply technical safeguards and processes designed to prohibit re-identification, we commit not to attempt to re-identify the information, and we contractually require recipients to honor the same non-re-identification commitment, to refrain from combining the information with other data to identify any individual, and to flow these obligations down to any onward recipient. Minimum cohort sizes. We do not return a commissioned result unless it meets the minimum cohort-size threshold set in our internal de-identification methodology, so that responses are not disclosed for groups small enough to enable re-identification. Sensitive topics. Questions whose answers would function as a proxy for a sensitive characteristic are handled as described in the Sensitive Information section, including exclusion from the data product or, where applicable, an opt-in consent flow. Your choices. Because participation in the data product may be considered a sale or sharing of personal information under certain U.S. state laws, you may opt out as described in the Your Choices and Your U.S. State Privacy Rights sections. ## 5. Sensitive Information Certain categories of information are treated as sensitive or special-category data under privacy laws, including the General Data Protection Regulation (“GDPR”) and various U.S. state privacy laws. We have designed the Services to minimize our handling of these categories. Categories we do not collect. We do not collect, as a registration or profile field, information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying you, data concerning health, data concerning your sex life or sexual orientation, precise geolocation, or government identifiers such as Social Security, passport, or driver’s license numbers. Information that may be revealed through responses. Because Activities involve opinions and beliefs, a response to a question may in some cases reveal, or allow an inference about, a sensitive characteristic. Questions whose answers would function as a high-confidence proxy for a sensitive characteristic are excluded from the data product. Where we elect to offer such a question, we present it only with an opt-in consent prompt in the Chomp app that explains the processing before you choose to participate. We do not use the data product to draw or retain inferences about your sensitive characteristics. Your rights. Where required by applicable law, you may have the right to limit our use and disclosure of sensitive personal information, and we will not process sensitive data that requires your consent without first obtaining it. See the Your U.S. State Privacy Rights section and the What Is Our Legal Basis section for further detail. ## 6. Cookies and Similar Technologies Like most other online services, Chomp uses cookies and similar technologies to collect some of the data discussed in this Privacy Policy. These help us provide certain features to you and analyze usage information. See the Your Choices section below for additional information about managing cookies. Our uses of cookies and similar technologies fall into the following general categories: Essential. Technologies necessary to provide the Services, including those that allow you to access our sites and applications, or are required to identify irregular site behavior and improve security. Performance. Technologies used to assess the performance of the Services, including as part of our analytic practices to understand how visitors use our websites and whether you have interacted with our messaging. Functionality. Technologies that allow us to offer enhanced functionality, including delivering error messages and enhancing the presentation of content. Advertising Cookies. Cookies that allow management of advertising by third parties and our advertising partners. Where required by applicable law, we present a consent prompt, including on first use of the Chomp app, that allows you to accept or reject non-essential cookies and similar technologies before they are set, and we record and honor your consent choices. ## 7. Analytics and Advertising We may engage others to provide analytics services and serve advertisements across the web and in mobile applications. These entities may use cookies and similar technologies to collect information about your use of the Services and your activities across other websites and online services, which they may associate with persistent identifiers. Sometimes these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising. Their activities and your choices regarding their use of your information to personalize ads are subject to their own policies. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device by non-affiliated third-party providers. As described in the Your Choices section, these providers may offer you a way to opt out. ## 8. Your Choices You may have certain choices about how to protect and limit the collection, use, and sharing of information about you, including: ### 8.1 Opt-Out of Marketing Communications You may opt out of receiving marketing communications from us by following the instructions in those communications, by adjusting your communication preferences in the Chomp app under Settings › Notifications, or by submitting a request to . If you opt out, we may still send you non-promotional messages such as messages about our ongoing business relationship. ### 8.2 Opt-Out of Sale or Sharing and Targeted Advertising You may opt out of the “sale” or “sharing” of your personal information and of processing for targeted advertising, including disclosures to advertising partners and participation in the data product described in Section 4. You may exercise this choice by y emailing with “Do Not Sell or Share” in the subject line, or by enabling a recognized opt-out preference signal as described in Section 8.4. See the Your U.S. State Privacy Rights section for further detail. ### 8.3 Opt-Out of Cookies and Tracking Technologies You can often adjust your browser settings to remove or reject browser cookies. If you remove or reject cookies, the availability and functionality of the Services may be affected. In the Chomp app, you can also manage ad personalization under Settings › Privacy, and on supported devices you can respond to the app’s tracking permission prompt. You may also limit or block cookies and similar tracking technologies by: 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 can block our websites from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins configured to block third-party cookies or trackers. ### 8.4 Opt-Out Preference Signals (Global Privacy Control) Some browsers and extensions let you send an opt-out preference signal, such as the Global Privacy Control (“GPC”), that communicates your choice to opt out of the sale or sharing of personal information and of targeted advertising. Where required by applicable law, we treat a recognized opt-out preference signal as a valid request to opt out for the browser or device from which it is sent. We do not currently respond to “Do Not Track” signals, which are separate from and do not carry the legal effect of a recognized opt-out preference signal. Because opt-out preference signals are sent by web browsers, you can exercise the equivalent choice within the Chomp app using the control described in Section 8.2. ### 8.5 Platform Opt-Outs The following platforms offer opt-out features that let you opt out of use of your information for interest-based advertising. We currently do not engage in services with all of these platforms, but in the event that we do, you have the option to opt out: * Google Analytics: * Facebook: * Twitter: ### 8.6 Advertising Industry Opt-Out Tools You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: * Digital Advertising Alliance: * Network Advertising Initiative: ### 8.7 Mobile Notifications We may send promotional and non-promotional push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or in the Chomp app under Settings › Notifications. ### 8.8 Other Rights and Choices Where required by applicable law and depending on your jurisdiction, you may have additional rights, including the right to obtain confirmation that we maintain certain personal information relating to you, to verify its content, origin, and accuracy, and the right to access, review, port, delete, correct, or restrict, or to withdraw consent to, the processing of certain personal information. The Your U.S. State Privacy Rights section describes how to exercise these rights. You may submit these requests in the Chomp app under Settings › Privacy, or email us at . We may ask you to provide information necessary to reasonably verify your identity before responding to your request. If we cannot verify your identity, we will not be able to fulfill your request. ## 9. Your U.S. State Privacy Rights This section applies to residents of U.S. states that have enacted comprehensive privacy laws, including California, Virginia, Colorado, Connecticut, Utah, and other states with comparable statutes, to the extent those laws apply to us. The specific rights available to you depend on your state of residence. ### 9.1 Your Rights Depending on your state, you may have the right to: * Know and Access. Confirm whether we process your personal information and obtain access to it, including the categories of personal information collected, the categories of sources, the purposes for processing, and the categories of third parties to which we disclose it. * Correct. Request that we correct inaccurate personal information. * Delete. Request that we delete personal information we have collected from you, subject to legal exceptions and the on-chain limitations described in the Technical Infrastructure and Your Data section. * Portability. Obtain a copy of your personal information in a portable and, to the extent technically feasible, readily usable format. * Opt Out of Sale or Sharing and Targeted Advertising. Opt out of the sale or sharing of your personal information and of processing for targeted advertising, as described in Section 8.2. * Limit Sensitive Personal Information. Limit our use and disclosure of sensitive personal information, where applicable, as described in the Sensitive Information section. * Opt Out of Profiling. Opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, where applicable. * Appeal. Appeal a denial of a rights request, where your state law provides an appeal mechanism. * Non-Discrimination. Exercise these rights without receiving discriminatory treatment. ### 9.2 How to Submit a Request You may submit a request to exercise your rights through at least two methods: by emailing us at . You may opt out of sale or sharing and of targeted advertising through the methods described in Section 8.2, including a recognized opt-out preference signal. ### 9.3 Verification and Authorized Agents We will take steps to verify your identity before responding to a request to know, correct, delete, or port your personal information. We may ask you to provide information that we can match against information already in our possession. You may use an authorized agent to submit a request on your behalf. We may require the agent to provide proof of your authorization and may require you to verify your own identity directly with us. ### 9.4 Timing and Appeals We will respond to your request within the time period required by your state law, which is generally 45 days, subject to an extension where permitted. If we decline to act on your request, we will explain why. Where your state law provides an appeal right, you may appeal our decision by contacting us at , and if your appeal is denied, you may contact your state attorney general. ## 10. International Transfers We have operations in the United States. If you are located outside of the United States, your information is collected in your country and then transferred to the United States, or to another country in which we (or our affiliates or service providers) operate. If we transfer your data out of the European Economic Area (“E.E.A.”), the United Kingdom, or Switzerland, we implement at least one of the following safeguards: * We transfer your information to a country that has been recognized by the European Commission (or, for the United Kingdom, by the relevant UK authority) as providing an adequate level of data protection. * We rely on the recipient’s active self-certification under the EU-U.S. Data Privacy Framework (“DPF”), the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, as applicable, where we have verified that the certification is active and covers the relevant data. * We put in place E.U. Standard Contractual Clauses, together with the UK Addendum or Swiss addendum as applicable, and additional safeguards to protect your personal data. In certain situations, the courts, law enforcement agencies, or regulatory authorities in those countries might be entitled to access your personal information. If you are located in the E.E.A. or the United Kingdom and we do not have an establishment there, we will designate a representative where one is required. Our representative for the European Economic Area and the United Kingdom is identified below. EU / UK Representative. We are currently in the process of appointing an EU and UK representative pursuant to applicable data protection laws. While this appointment is in progress, if you are located in the European Economic Area or the United Kingdom, you may direct any privacy inquiries or exercise your rights by contacting us directly at . We will ensure your inquiry is addressed promptly and will update this section with the representative's official contact details once finalized. ## 11. Legal Basis for Collection In some jurisdictions like the European Union and the E.E.A., we only collect, use, or share information about you when we have a valid reason. This is called a “lawful basis.” Specifically, this is one of the following: * The consent you provide to us at the point of collection of your information; * The performance of the contract we have with you; * The compliance of a legal obligation to which we are subject; or * The legitimate interests of Chomp or a third party. “Legitimate interest” is a technical term under international laws, including the GDPR. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business; (3) to prevent fraud; (4) to conduct our marketing activities; and (5) to maintain platform integrity and ensure that Activities resolve endogenously in accordance with the platform’s deterministic rules. To the extent we process any special category data within the meaning of Article 9 of the GDPR, we will do so only where an Article 9 condition applies, which in the context of the Services means your explicit consent obtained before the processing. As described in the Sensitive Information section, our design objective is to avoid processing special category data in the first instance. ## 12. How We Protect Your Information We use reasonable procedural, physical, and electronic safeguards to protect your information from unauthorized access or use. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no method of transmission over the internet or electronic system is completely secure, so we are unable to guarantee absolute security. The safety and security of your information also depends on you. Do not share your account credentials, passwords, wallet private keys, recovery phrases, or any associated authentication details with anyone. We may provide you with additional security features like multifactor authentication, and we strongly recommend that you utilize these features. ## 13. Information Storage and Retention We retain your information for as long as necessary to provide the Services, fulfill our legal obligations, enforce our legal agreements, and resolve disputes. Retention periods are determined on a case-by-case basis depending on the nature of the information, why it was collected, and the applicable legal reason(s) for retention. We may also keep certain information when necessary to protect the safety and security of the Services, to maintain audit logs and records sufficient to reconstruct Activity outcomes and verify the platform's deterministic scoring, and to support jurisdiction-specific compliance and reporting obligations. Rather than delete your data, we might de-identify it by removing identifying information. ## 14. Age Restrictions The Services are not intended for anyone under the age of 18. We do not knowingly collect or solicit personal information from anyone under 18. In the event that we become aware of information from an individual under the age of 18, we will promptly take steps to delete such information. If you believe a person under 18 has provided information to us in connection with the Services, please contact us at ## 15. Changes to This Privacy Policy We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information or use what we already have differently. Further, the laws regarding personal information and privacy frequently change. We will notify you of any changes we make by revising the date at the top of this page. We will also provide you with reasonable notice of material changes before they take effect, by email, in-app notice, or other means, or as otherwise required by applicable law. If you object to any change, you can stop using the Services. After a change takes effect, your continued use of the Services is subject to the updated Privacy Policy. ## 16. Third-Party Links and Features The Services may contain links, banners, or widgets to third-party sites, applications, and services. We may also incorporate third-party software (including open-source software) in the Services. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through them, nor any association with their operators. Chomp is not responsible for the practices of such third parties. Any information you provide to third parties on their sites or services is covered under their privacy and data collection practices and not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties. ## 17. Contact Us If you have any questions about this Privacy Policy or our data practices, please email us at