Privacy Policy

Last Updated: May 6, 2026 — pursuant to Art. 13 Reg. EU 2016/679 (GDPR) and D.Lgs. 196/2003 as amended by D.Lgs. 101/2018

1. Data Controller

This platform is operated by Arbitrage Inception, an anonymous, community-driven open-source project (MIT License) with no registered legal entity. For privacy-related requests, reach us via: Telegram or GitHub Issues. We will respond within 30 days as required by Art. 12 GDPR.

No Data Protection Officer (DPO) has been appointed as the processing does not fall within the mandatory cases under Art. 37 GDPR.

2. Data Processed, Purposes, and Legal Bases

2.1 Technical Navigation Data

Systems automatically collect data implicit in internet communications:

• IP address (used only for security and abuse prevention; no analytics tracking is performed)
• Browser type and version
• Operating system and device type
• Pages visited and time spent
• Referring website

Legal basis: Legitimate interest (Art. 6(1)(f) GDPR) — platform security and functionality.

Retention: Maximum 12 months, unless required by law.

2.2 Blockchain Wallet Address

When you connect a crypto wallet, the public address becomes visible to the interface. Wallet addresses are publicly available on-chain. We process this data solely to enable the service you requested.

Legal basis: Performance of requested service (Art. 6(1)(b) GDPR).

3. What We Do NOT Collect

We do not store private keys, seed phrases, or wallet passwords. All transactions are executed directly on-chain via the user's own wallet. No party associated with this project has access to user funds.

4. Data Sharing

Personal data is not sold or transferred to third parties for commercial purposes. Data may be shared with:

• Technical service providers (hosting, CDN) to the extent strictly necessary
• Public authorities upon lawful request

5. Your Rights (Arts. 15–22 GDPR)

• Access (Art. 15): Obtain confirmation of processing and a copy of your data
• Rectification (Art. 16): Correct inaccurate personal data
• Erasure / Right to be Forgotten (Art. 17)
• Restriction of Processing (Art. 18)
• Data Portability (Art. 20)
• Objection (Art. 21): Object to processing based on legitimate interest
• Withdrawal of Consent: Withdraw at any time without prejudice to prior lawful processing

Exercise your rights via Telegram or GitHub Issues.

6. Right to Lodge a Complaint

Italian users may lodge a complaint with the Garante per la Protezione dei Dati Personali: www.garanteprivacy.it — garante@gpdp.it — Tel: +39 06 69677 1

7. Cookies

See our Cookie Policy for full details.

8. Minors

The platform is not intended for users under 18. We do not knowingly collect data from minors. Contact us immediately if you believe a minor has provided data.

9. Policy Updates

Significant changes will be announced via the GitHub repository with at least 30 days notice. The current version is always available at this address.

10. Contact

Privacy questions: Telegram Community or GitHub Issues.