Trades Privacy Policy

Last updated: August 4, 2026

We Are Set, Inc., a Delaware corporation doing business as Recall Labs (“Recall,” “we,” or “us”), respects your privacy. This Privacy Policy describes how we collect, process, share, and safeguard personal information when you use the Trades iOS application (the “App”), visit trades.recall.network or another Trades website that references this Privacy Policy (the “Website”), contact us, or otherwise engage with the App and Website (collectively, the “Services”).

Recall is the controller responsible for your personal information in accordance with applicable data protection laws, including the laws of the European Economic Area and the United Kingdom. If you have any questions or comments about this Privacy Policy, please submit a request to data-privacy@recall.foundation.

This Privacy Policy does not apply to personal information processed independently by a wallet, supported trading venue, blockchain, bridge, Reown, Apple, or another third-party service. Their own privacy policies govern their processing.

1. Personal Information We Collect

We collect or process the following categories of personal information.

• Wallet and venue account information. When you connect a wallet, the App processes your public wallet address, the wallet provider you selected, the connected network, and public or venue-provided account information such as balances, positions, open orders, order history, fills, and funding activity. This information is used on your device and transmitted to the wallet, Reown infrastructure, supported venues, blockchains, bridges, or RPC providers as needed to provide the feature you request.
• Transactions and commercial information. The App processes the orders, deposits, withdrawals, transfers, leverage or margin changes, and other venue instructions that you create, together with related public blockchain and venue data. Supported venues and blockchains determine what transaction information becomes public or remains in their systems.
• Geographic access information. When the App calls our geographic access endpoint, Vercel processes the request’s source IP address and derives a country or region in order to apply our firewall rules. The App receives an allowed, restricted, or unavailable result. Our endpoint does not return your IP address or precise location to the App.
• Communications with us. We collect the communications that we exchange with you, including when you contact us with questions, feedback, support requests, or otherwise.
• App analytics information. If anonymous usage analytics is enabled in the App, we use Firebase Analytics to collect product-owned events such as screens viewed, feature entry points, wallet-connection stages, trade and funding workflow stages, venue selection, asset ticker, order choices, quoted fees, slippage, funding and costs, trade or funding amounts, outcomes, and error categories. Firebase may also automatically process app and device information, including a Firebase-generated app-instance identifier, device model, operating-system version, app version, language, and general location derived from IP address. Our analytics events intentionally exclude wallet addresses, venue account identifiers, delegated credentials, order identifiers, signing identifiers, and transaction identifiers. Advertising storage, ad user data, and ad personalization are disabled.
• Website analytics information. We use Vercel Web Analytics to collect anonymized and aggregated information about Website visits, including the page URL, referrer, coarse location, browser, operating system, and device type. Vercel Web Analytics does not use cookies.
• Device and usage data. We and our service providers may automatically log information about your device and your interaction with the Services, such as operating system, device model, browser type, IP address, unique or pseudonymous identifiers, language settings, general location, pages or screens viewed, feature interactions, access times, and diagnostic or security information.

Information Collected from Third Parties

• Wallets, Reown, venues, and infrastructure providers. We may receive a public wallet address, session status, venue account state, transaction result, or other information needed to complete the feature you request. Reown’s WalletConnect infrastructure independently processes information described in its Privacy Policy, which may include IP address, wallet address, country or region, a randomly generated client identifier, protocol metadata, SDK version, and encrypted data payloads.
• Blockchain information. We may obtain personal information from public blockchains and related infrastructure, such as wallet and smart-contract addresses, transaction data, balances, and positions.

Information That Stays on Your Device

The App stores settings, legal-acceptance records, wallet-connection state, and supported venue credentials locally on your device. Secret delegated credential material is protected by the iOS Keychain and is not intentionally transmitted to or stored on Recall servers. Biometric matching is performed by iOS. Recall does not receive your facial image or biometric template; the App receives only whether authentication succeeded. If you choose to scan a wallet QR code, the App uses the camera for that connection flow and does not retain the camera image.

2. How We Use Personal Information

We use personal information for the following purposes:

• To operate and deliver our Services. We will use your personal information to perform our contractual obligations, when it is in our legitimate business interests or based on your consent, including to:
  • Provide, operate, maintain, and secure our Services;
  • Connect your wallet and retrieve account information;
  • Display markets, balances, positions, orders, and transactions;
  • Construct and transmit the wallet, venue, or blockchain instruction you request;
  • Apply geographic access restrictions and other eligibility controls;
  • Provide support assistance and troubleshooting;
  • Send you updates about administrative matters such as changes to our terms or policies; and
  • Respond to your requests, questions, and feedback.
• To improve, monitor, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe, which includes:
  • Understanding how the App and Website are used;
  • Developing and improving product features, venue comparisons, reliability, and user experience;
  • Protecting the security of our Services; and
  • Preventing and detecting security threats, fraud, access-control evasion, or other criminal or malicious activity.
• Research and development. It is in our legitimate business interests to use personal information to develop, analyze, and improve the Services and our business. As part of these activities, we may create or use aggregated, de-identified, or other anonymized data from personal information we collect. We may use this anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Services.
• To comply with legal obligations and to defend Recall against legal claims or disputes. We may use your personal information to comply with our legal obligations or when it is in our legitimate business interests, which includes to:
  • Comply with applicable laws, sanctions, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your, or others’ rights, privacy, safety, or property, including by making and defending legal claims;
  • Audit our compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern the Services; and
  • Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.
• To facilitate corporate acquisitions, mergers, or transactions. We may use your personal information, when it is in our legitimate business interests, when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.

3. How We Share Personal Information

We may share personal information with:

• Service providers. We may share personal information with companies and individuals that provide services on our behalf or help us operate our Services or our business. These include Vercel for Website hosting, firewall enforcement, and Website analytics; Google Firebase for App content delivery and optional App analytics; communications and support providers; and security, fraud-detection, investigation, and infrastructure providers.
• Wallet, connection, venue, blockchain, and bridge services. At your direction, the App transmits information and instructions to your selected wallet; Reown and WalletConnect infrastructure; supported venues currently including Hyperliquid and Lighter; and related blockchains, bridges, RPC providers, and other infrastructure. These third parties independently process information under their own terms and privacy policies.
• Professional advisors. We share personal information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. We may share personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.
• Business transferees. We may share personal information with acquirers and other relevant participants in business transactions or negotiations involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale, or other disposition of all or any portion of our business, assets, or equity interests, including in connection with bankruptcy or similar proceedings.

4. Cookies and Analytics Choices

Website cookies

The public Trades Website does not currently set analytics or advertising cookies. We use Vercel Web Analytics, which measures anonymized and aggregated Website usage without cookies. Because no non-essential cookies are currently used on the public Website, we do not display an analytics consent banner. If we introduce non-essential cookies or another technology that requires consent, we will update this Privacy Policy and request consent where required by law.

App analytics

Anonymous Firebase Analytics is enabled by default in the App. You can turn it off at any time under Settings by disabling “Share anonymous usage analytics.” Turning it off stops future analytics collection through the App, denies analytics storage, clears any Firebase user ID set by the App, and resets Firebase Analytics data stored on the device. Advertising storage, ad user data, and ad personalization remain disabled whether or not App analytics is enabled.

Do Not Track

Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. The public Trades Website does not use cross-site advertising trackers.

5. Your Rights

Depending on where you are based, and as provided under applicable law and subject to any limitations in such law, you may have the right to:

• Access your personal information;
• Correct incomplete or inaccurate data we hold about you;
• Ask us to erase the personal information we hold about you;
• Ask us to restrict our handling of your personal information;
• Receive any personal information we hold about you in a structured and commonly used machine readable format or have such personal information transmitted to another company;
• Object to how we are using your personal information; and
• Withdraw your consent to us handling your personal information.

Requests can be made to data-privacy@recall.foundation. You may update or correct information about yourself by emailing us at that address.

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. Depending on where you reside, you may be entitled to empower an “authorized agent” to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination. In addition, we may have valid legal reasons to refuse your request, and will inform you if that is the case.

Limits on your privacy rights and choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. Recall cannot amend or delete information stored on a public blockchain, and third-party requests must be directed to the applicable third party.

6. Data Security

Recall maintains administrative, technical, and physical safeguards designed to protect your personal information against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. We implement appropriate technical and organizational measures to ensure an adequate level of security, while taking into account the technological reality, cost, scope, context, and purposes of processing weighted against the severity and likelihood that processing could threaten individual rights and freedoms.

Secret delegated credential material is protected on your device using the iOS Keychain and device biometrics as described above. While we take steps designed to protect your personal information, no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure. We cannot and do not guarantee or warrant the security of your personal information or any information you disclose or transmit to us or a third party.

7. Data Retention

We may retain your personal information for as long as it is reasonably needed in order to provide and improve the Services; comply with legal and contractual obligations; or protect ourselves from potential disputes. To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, and applicable legal requirements.

App settings and secret delegated credentials remain on your device until you change the relevant setting, revoke or remove the credential, delete the App, clear local data, or the operating system removes them. Our service providers retain information under their own retention schedules and our agreements with them. It may not be technically feasible to delete information transmitted to and stored on a blockchain, and such information may remain indefinitely.

8. Children

Our Services are not intended for use by anyone under 18 or the age of legal majority required to use the App where they live, whichever is higher. If we learn that we have collected personal information through our Services from a child without the consent of the child’s parent or guardian as required by law, we will endeavor to delete it.

9. Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as through the App or another manner. Where required, we will ask you to acknowledge the updated Privacy Policy before using a Trading Feature.

10. Contact Us

If you have specific questions about this Privacy Policy or wish to exercise a privacy right, you can reach us at data-privacy@recall.foundation. For general product support, contact contact@recall.network.

If you wish to lodge a complaint about how we process your personal information, you can contact us using the privacy email provided above. We will endeavor to respond to your complaint as soon as possible. Depending on where you reside, such as if you reside in the European Economic Area or United Kingdom, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Recall Labs

We Are Set, Inc.

1500 N Grant St Ste 5815

Denver, CO 80203

United States