--- title: Privacy notice draft description: Current analytics behaviour and proposed eligibility-data handling for OptionHouse. --- Version: draft-2026-11-14-3. Dated: 2026-11-14. Effective date: **[OWNER AND COUNSEL TO COMPLETE]**. Mainnet is not open. This notice separates current app behaviour from proposed handling of eligibility and acceptance records. The proposed processing is not established merely by publishing this page. ## Who is responsible The operator uses the name OptionHouse and has no company yet. Data controller's legal identity details, address and privacy contact: **[OWNER AND COUNSEL TO COMPLETE]**. Applicable representative and data protection officer, if required: **[OWNER AND COUNSEL TO COMPLETE]**. The final notice must identify who handles requests before it can offer a usable request route. A public wallet address can identify a person when linked to network information, a signature or activity. We do not treat those linked records as anonymous just because transactions use a blockchain. Blocking trading in a place does not by itself settle which privacy laws apply there. ## Current website and app Cloudflare serves the website and receives network requests, including IP addresses and request metadata. Wallet and transaction services receive the wallet addresses, transaction contents and network information needed for the requests you send. Your wallet provider and Solana network providers also process requests under their own terms. Where analytics is enabled, the app uses PostHog through the site's analytics relay for page views and selected app interactions. It uses browser storage and cookies for analytics identifiers and remembers your analytics choice. The current setup disables session recordings and automatic capture of every click, and strips query strings and fragments from captured URL properties. The app turns analytics off in its excluded tracking regions, when region lookup fails, when your browser sends Global Privacy Control, or when you have chosen to turn it off. Elsewhere analytics is on by default. Where shown, "Privacy choices" lets you turn it off or on. Declining analytics does not itself change trading eligibility. This draft does not describe the current default as an affirmative opt-in. The app remembers a decline in local storage and an analytics-choice cookie. Clearing browser data may remove that preference. Vendor retention, storage countries and the final legal basis for the current analytics setup remain **[OWNER AND COUNSEL TO COMPLETE]**. A final notice must describe the actual configured services and any required consent before relying on them. ## Proposed eligibility and acceptance records The proposed launch checks may use your IP address, approximate country and subdivision, wallet address, signing authority, signature, request time and device or session metadata. Declared eligibility, the decision and its reason, terms version and an evidence reference may form part of an acceptance record. VPN, proxy or hosting indicators would be additional data if a provider is adopted; this draft does not claim such a provider is installed. Network location is an estimate. It can be wrong and cannot prove citizenship, residence or who controls a wallet. Sanctions address results can miss a person restriction or flag an address needing review. Linking these checks with a wallet makes a more detailed record of your activity. The intended purposes are eligibility checks, applicable sanctions compliance, security, fraud prevention, support and evidence of the agreement you accepted. Each purpose needs its own applicable legal basis. Legal bases, any legitimate-interest assessment and required consent: **[OWNER AND COUNSEL TO COMPLETE]**. A voluntary risk check is not automatically a legal obligation. Withholding data needed for a lawful eligibility decision may prevent new positions or deposits. Refusing optional analytics must not itself prevent an otherwise eligible transaction. The proposed policy does not reuse screening records for marketing without a separately justified basis and any required consent. ## Recipients and transfers Cloudflare and PostHog are part of the current website and analytics setup. Wallet, Solana network and hosting or storage providers can receive data needed to perform their services. Proposed eligibility records may also involve address-screening or IP-information providers, authorised staff, professional advisers and authorities where disclosure is lawful. A public sanctions-list download alone does not mean a wallet is sent to that list's publisher. Actual contracted providers, their roles as processors or independent controllers, subprocessors, storage countries and cross-border safeguards: **[OWNER AND COUNSEL TO COMPLETE]**. Optional vendors are not represented as appointed. The final notice needs the actual contracts and processing arrangements; this draft promises no specific transfer safeguard. ## Retention and security Retention periods or decision criteria for raw network telemetry, screening decisions, acceptance evidence, analytics, support and incident records: **[OWNER AND COUNSEL TO COMPLETE]**. Legal holds and deletion from backups also need defined limits. There is no blanket retention period in this draft and no claim that every record must be kept for the same time. The proposed policy keeps raw network data only as long as its purpose requires and keeps agreement or incident evidence separately when there is a justified need. It calls for restricted access, encryption, redacted logs and tested deletion for records under the operator's control. Those are intended safeguards, not a guarantee that this page has implemented them or that a breach is impossible. IP addresses and personal eligibility declarations should remain off chain. A transaction on Solana is public and can be copied by others. Wallet addresses, amounts and transaction history can persist indefinitely. The team cannot erase public-chain history or copies held independently by other people. ## Your choices and requests Depending on applicable law, you may have rights to access, correct, obtain a copy of, delete or restrict use of personal data, object to processing, withdraw consent where it is the basis, and complain to a supervisory authority. Rights can have limits for legal duties, other people's rights or the establishment and defence of claims. Deleting an off-chain record does not delete a public transaction. Request contact, identity-check process, response periods, relevant supervisory authority and complaint route: **[OWNER AND COUNSEL TO COMPLETE]**. No working contact or response deadline is invented here. The final process should request only the evidence needed to handle a request and protect it from misuse. Proposed eligibility checks can automatically refuse new risk based on network location, sanctions results or unavailable data. This may affect access to trading or deposits. Final automated-decision rules, human review and any applicable rights relating to profiling or decisions: **[OWNER AND COUNSEL TO COMPLETE]**. A review of a location or screening error must not promise an exception to sanctions law. ## Changes A material change needs a new dated notice explaining the changed processing and its effective date. Any required consent must be obtained separately from acceptance of trading terms. Historic notices remain available so you can see what a particular version said. Read this draft with the [terms](/docs/legal/terms-2026-11-14-3) and [restricted persons schedule](/docs/legal/restricted-2026-11-14-3).