handld.

handld Privacy Notice

Version: to be confirmed. Effective date: to be confirmed. Last updated: 9 Oct 2026.

1. Who is responsible for your data

handld (company in formation) ("handld", "we") is the controller of the personal data described here. Contact for privacy questions and requests: therestishandled@gmail.com.

This notice covers handld.xyz, the web desk at app.handld.xyz, invitations, onboarding, support and any waitlist.

2. What we collect

Category Examples Where it comes from
Contact and account Email address, login identifiers, account settings, invitation code, Terms and Ruleset acceptance records (version, time) You
Wallet Your Hyperliquid account (wallet) address; the public address of the trade-only agent wallet you authorise You, Hyperliquid
Eligibility declarations Declared country of residence; every nationality you declare; age confirmation (18+) You
Location and device signals IP address, IP-derived country/region, VPN/proxy/datacenter indicators, browser and device data, session times Your device. IP geolocation: DB-IP (db-ip.com) IP to City Lite database, processed locally on our server; your IP is not sent to DB-IP.
Sanctions screening record Name, date of birth, nationalities and residence as screened; wallet address screened; lists checked, results, reviewer, date You, public sanctions lists
Trading data and audit log The symbol, direction and invalidation you send; the size and stop the Ruleset calculates; allow/refuse reason; Ruleset version; orders, fills, fees and positions on your Hyperliquid account placed or affected by the desk; timestamps You, the desk, Hyperliquid
Support and communications Messages you send us, and our replies You
Billing (only once paid seats exist) Name, billing country, payment status and limited card details as handled by Stripe. We do not see full card numbers You, Stripe
Website and analytics none none

We do not ask for, and you must never send us, your Hyperliquid master private key or seed phrase.

Note on the opacity of the desk: the trading screen does not show you size, stop or refusal reasons, but we do record them in the operator tools and audit log, and they are personal data about you. See section 8 on your right of access.

3. Why we use it and our legal basis

Lawful bases are under the EU General Data Protection Regulation (GDPR). The basis for each purpose below is to be confirmed.

Purpose Data used Lawful basis (to be confirmed)
Create and run your account; send your trades to Hyperliquid under your accepted Ruleset; enforce lockouts; keep the desk working Account, wallet, trading data, device data Performance of a contract (Art. 6(1)(b))
Check eligibility (age, residence, location, nationality) and enforce the geo gate, including VPN/proxy detection Eligibility declarations, location and device signals to be confirmed
Sanctions screening of invitees and users, including wallet address Screening record, eligibility declarations, wallet to be confirmed
Keep an audit log of instructions, calculated parameters and outcomes Trading data and audit log to be confirmed
Security, fraud and abuse prevention; investigating incidents Device, location, account, logs Legitimate interests (Art. 6(1)(f)) in securing the Service and users' accounts
Support and complaints Support messages, account, relevant trading data Contract; legitimate interests
Service emails (onboarding, Ruleset or Terms changes, security notices) Email Contract; legitimate interests
Waitlist or product news emails (if any) Email to be confirmed
Billing (once paid seats exist) Billing data Contract; legal obligation (accounting and tax)
Establishing or defending legal claims; responding to lawful requests from authorities Any relevant data Legitimate interests; legal obligation

Nationality data is not a "special category" under GDPR, but it is sensitive in practice. We use it only for eligibility and sanctions purposes.

Automated decisions. The desk applies the Ruleset automatically, including refusing trades and applying lockouts. Signup and access may also be refused automatically on eligibility or location signals. Sanctions matches are always reviewed by a person before any final decision.

4. Who we share it with

We do not sell your personal data, and we do not share it for third-party advertising.

We share personal data only as needed with:

5. International transfers

Some processors may process data outside the European Economic Area. Where they do, we rely on a transfer mechanism to be confirmed. You can request a copy of the relevant transfer terms at therestishandled@gmail.com. Data on Hyperliquid is recorded on a public ledger that is not located in any one country.

6. How long we keep it

Data Retention (to be confirmed)
Account and contact data to be confirmed
Eligibility declarations and geo-gate logs to be confirmed
Sanctions screening records (including refused invitees) to be confirmed
Trading data and audit log to be confirmed. The audit log is designed to be tamper-evident and append-only; see section 8 on erasure
Support messages to be confirmed
Security and access logs IP address and IP-derived location: 90 days. Event record (type and time): up to 2 years from the event.
Billing records (once paid seats exist) to be confirmed
Waitlist email to be confirmed

When a retention period ends we delete or irreversibly anonymise the data.

7. Security

We use technical and organisational measures appropriate to the risk, including access controls, encryption in transit, and limiting operator access to the audit log. The desk holds only a trade-only agent key that cannot withdraw funds. No system is free of risk. If a personal data breach is likely to put you at high risk, we will tell you without undue delay.

8. Your rights

Where GDPR applies, you have the right to:

To exercise a right, email therestishandled@gmail.com. We may need to verify your identity. We respond within one month, extendable where the law allows.

If you live outside the EEA, you may have similar rights under your local law.

9. Complaints

You can complain to us first at therestishandled@gmail.com. You also have the right to complain to a data protection supervisory authority, in particular in the EU Member State where you live or work or where an alleged infringement took place. Our lead authority in Estonia is:

Andmekaitse Inspektsioon (Estonian Data Protection Inspectorate)

Tatari 39, 10134 Tallinn, Estonia. Phone +372 627 4135. https://www.aki.ee/en

10. Age

The Service is only for people aged 18 or over. We do not knowingly collect data from anyone under 18. If we learn we have, we will delete it, subject to section 6.

11. Cookies

Cookie use on the Service is to be confirmed.

12. Changes

We will post updates here and, for material changes, tell you by a method to be confirmed before they apply.