Privacy Policy
Last updated: September 2026
This privacy policy (this “Privacy Policy”) describes how Glare Foundation (“Glare”, “we”, “us”, or “our”) collects, uses, and discloses certain information, including your personal data, and the choices you can make about that information.
Glare is the developer and operator of a web interface and non-custodial protocol that allows users to connect a self-custodied wallet and interact with algorithm-driven vaults (the “Interface” and, together with the underlying protocol, the “Services”). This Privacy Policy explains and discloses the use, processing, and sharing of personal data collected directly or indirectly when you connect a wallet to or otherwise use the Services (as a “User”), or merely when interacting with our website available at glarefi.xyz, our blog, or other similar forums (as a “Visitor”). Users and Visitors shall be, collectively and separately, referred to as “you” or “your”.
This Privacy Policy is hereby incorporated into our Terms of Use (the “Terms”). Any capitalized term used but not defined herein shall have the meaning ascribed to it in the Terms.
BECAUSE THE SERVICES ARE NON-CUSTODIAL, GLARE DOES NOT HOLD, AND YOU ARE NOT REQUIRED TO PROVIDE, ANY PRIVATE KEY, SEED PHRASE, OR OTHER WALLET CREDENTIAL. YOU ARE NOT UNDER ANY STATUTORY OBLIGATION TO PROVIDE PERSONAL DATA TO GLARE; HOWEVER, IF YOU DO NOT PROVIDE CERTAIN PERSONAL DATA, WE MAY NOT BE ABLE TO PROVIDE CERTAIN SERVICES TO YOU, SUCH AS RESPONDING TO A SUPPORT REQUEST, OR VERIFYING YOUR ELIGIBILITY TO USE A VAULT, ALL AS DESCRIBED UNDER “DATA SETS WE COLLECT AND FOR WHAT PURPOSE” BELOW.
This Privacy Policy governs the use, processing, and sharing of personal data that applies to all individuals worldwide. It further includes disclosures required under certain data protection laws, including our lawful basis for processing personal data under the EU and UK General Data Protection Regulations (“GDPR”) and the German Federal Data Protection Act (“BDSG”). Certain jurisdictions require applicable disclosures to be provided in a specific format; if you are a US resident, refer to Section 12 (Additional Notice for US Residents), which includes additional information about privacy rights for US residents.
Policy Amendments
We reserve the right to amend this Privacy Policy from time to time, at our sole discretion. The most recent version will always be posted on glarefi.xyz and reflected in the "Last updated" heading. We will provide notice to you if changes are material and, where required by applicable law, obtain your consent. Otherwise, amendments become effective immediately upon posting. We recommend you review this Privacy Policy periodically.
Contact Information and Data Controller Information
Glare Foundation, organized under the laws of Germany, with its registered address in Mainz, Germany, is the controller of the data described in this Privacy Policy (as such term is defined under applicable data protection laws). You may contact us and our privacy team at: glareprivacy@gmail.com.
1. Data Sets We Collect and For What Purpose
We may collect the following types of information from you, depending on your interaction with us.
The first type is non-identifiable and anonymous information ("Non-Personal Data"), such as aggregated Vault statistics or on-chain data that is not linked to an identifiable individual. The second type is individually identifiable information, information that identifies you, or may with reasonable effort identify you ("Personal Data"). Any Non-Personal Data connected or linked to Personal Data is deemed Personal Data for as long as that connection exists.
Please note that actual processing operations may differ per purpose and typically include collection, storage, use, disclosure, or erasure by automated means. The transfer of Personal Data to third countries, as detailed in Section 8 (International Data Transfer), is based on the same lawful basis as stated above.
We may also use certain Personal Data to prevent potentially illegal activity, fraud, exploits, or other misuse of the Services, and to enforce the Terms, based on our legitimate interests.
| Data Set | Purpose and Operation | Lawful Basis (GDPR / UK GDPR) |
|---|---|---|
| Contact Information. Your email address, and any name or message you provide, when you contact us with an inquiry. | To respond to your inquiry and, where you have opted in, send you product updates or other communications ("Direct Marketing"). | Consent (where you contact us or opt in) or our legitimate interest in responding to inquiries. |
| Wallet Address and On-Chain Data. Your public wallet address and the Transactions you submit to a Vault, as recorded on the Network. This data is public on the Network independently of Glare. | To display your Vault positions and history through the Interface, to operate and secure the Services, and to detect and prevent fraud, exploits, or Prohibited Use under the Terms. | Legitimate interest in operating, securing, and improving the Services; and, where applicable, our legal obligation to prevent illegal use of the Services. |
| Eligibility and Compliance Screening Data. Your wallet address, approximate location (derived from IP address), and, where applicable, any information you submit to verify that you are not a Sanctioned Person or Restricted Person under the Terms. | To determine and enforce eligibility restrictions, including geoblocking and sanctions-list screening, in accordance with Sections 1 and 5 of the Terms. | Compliance with legal obligations (sanctions, anti-money laundering) and our legitimate interest in preventing unlawful use of the Services. |
| Online Identifiers and Telemetry Data. Your IP address, cookie identifiers, browser and device type, referring URL, and your interactions with glarefi.xyz (such as pages viewed and session duration). | To operate and secure the Interface, recognize you across sessions, troubleshoot issues, and understand usage patterns to improve the Services. | Legitimate interest in operating and improving the Services. Where used for marketing or advertising, your consent (obtained through our cookie notice). |
| Support Communications. The contact information and content of any communication you send us for support. | To respond to and resolve your request, and to maintain records of support provided. | Legitimate interest in providing customer support and improving the Services. |
2. How We Collect Your Information
- Information you provide directly, for example, when you connect a Wallet or correspond with us.
- Information we receive automatically, your Wallet address and Transactions are recorded on the Network, which is public and independent of Glare; we also collect Online Identifiers and Telemetry Data automatically through first- or third-party tools.
- Information we receive from third parties, for example, from blockchain analytics or sanctions-screening providers used to help us assess eligibility and detect Prohibited Use.
3. Cookies and Similar Tracking Technologies
We use cookies and similar tracking technologies on glarefi.xyz. A "cookie" is a small piece of information a website stores on your device. Some cookies are strictly necessary for the Services to function; others help us understand usage or serve relevant content.
| Cookie & SDK | Purpose | Privacy Policy |
|---|---|---|
| Wallet Connect | Operational & Functional, remembers your connected Wallet session so you don't need to reconnect on every page load | https://walletconnect.network/privacy-policy |
| Plausible | Analytical & Measurement, privacy-focused, cookieless usage analytics as an alternative/supplement to Google Analytics | https://plausible.io/privacy |
| X (Twitter) | Marketing & Advertising, measuring the performance of our social media campaigns | https://x.com/en/privacy |
| Discord | Operational & Functional, displaying live community activity if embedded on the website | https://discord.com/privacy |
Most browsers let you erase, block, or receive warnings about cookies. Disabling cookies may limit certain features of the website. We honor the Global Privacy Control signal, where applicable, as a valid request to opt out of the sharing of information linked to your browser.
4. Data Sharing: Categories of Recipients
| Category of Recipient | Data Shared | Purpose |
|---|---|---|
| Service Providers | All applicable data | We engage vendors to perform functions on our behalf, such as sending communications, hosting the Interface, analyzing usage, and providing customer support. These vendors may only use Personal Data to provide services to us. |
| Compliance and Screening Providers | Wallet address, IP-derived location, eligibility screening data | We may share data with blockchain analytics or sanctions-screening providers to help us assess eligibility under Section 5 of the Terms and detect Prohibited Use. |
| Regulators, Law Enforcement, and Government Authorities | As required under applicable request | We may disclose data where required or permitted by applicable law, or where we believe disclosure is necessary to investigate fraud, exploits, or violations of the Terms, or as evidence in litigation involving Glare. |
| Routing and Liquidity Providers | Wallet address, source and target chain, token selection | Where you use Swap or Bridge, we share the information needed for those providers to source liquidity and route an order on your behalf. Your Funds are exchanged under the terms those providers publish, and Glare does not take custody of them. |
| Wallet Connection Infrastructure (Reown and WalletConnect) | Wallet address, chain ID, and session metadata | To establish and maintain a wallet session, present wallet options, and relay signing requests between your wallet and the Interface. These providers act as connectivity infrastructure and do not receive your private keys. |
| Marketing Partners (if applicable) | Online Identifiers, Telemetry Data | Where you have opted in, we may share data with marketing partners to promote the Services. |
5. Data Retention
We retain Personal Data for as long as necessary for the purposes described above, or until you exercise an applicable opt-out. We may retain data for longer where required by legal, regulatory, or tax obligations, to maintain accurate records in the event of a dispute, or where we reasonably believe litigation is possible. Except as required by applicable law, we are not obligated to retain data for any particular period and may delete it at any time.
Note that Wallet addresses and Transactions recorded on the Network are public and immutable; Glare has no ability to delete or modify data recorded on the Network itself, even upon your request (see Section 7, Security Measures).
6. Security Measures
We implement physical, technical, and administrative security measures designed to protect the Personal Data we process, including encryption in transit (SSL/TLS) and restricting access to Personal Data to authorized personnel and contractors. We cannot be held responsible for unauthorized or unintended access beyond our reasonable control, and we make no warranty that we will always be able to prevent such access.
For the avoidance of doubt, Glare never holds your private keys, seed phrase, or other Wallet credentials, and has no ability to access or move your digital assets. Please refer to Section 1.2 (Wallet and Credentials) of the Terms for further detail on your responsibility for Wallet security.
Please contact us at glareprivacy@gmail.com if you believe your privacy was not handled in accordance with this Privacy Policy, or if you become aware of a third party's attempt to gain unauthorized access to your Personal Data. We will make reasonable efforts to notify you and applicable authorities, where required by law, in the event of a security incident affecting your Personal Data.
7. Nature of On-Chain Data
Certain data associated with your use of the Services, including your Wallet address and Transactions, is recorded directly on the Network, a public and decentralized blockchain that is not operated or controlled by Glare. Such data is inherently public, permanent, and outside Glare's control. This Privacy Policy governs Glare's own collection, use, and disclosure of data; it does not govern, and Glare is not responsible for, data recorded on or accessible through the Network itself.
8. International Data Transfer
Our data infrastructure may be located in Germany, the European Economic Area ("EEA"), the United Kingdom, and other jurisdictions where our service providers operate. Our registered office is in Mainz, Germany, which is located within the EEA, so transfers between our office and service providers elsewhere in the EEA do not constitute an international transfer. Where Personal Data collected within the EEA is transferred to a country that has not received an adequacy decision from the European Commission, we take steps to ensure adequate safeguards are in place, including through the EU Standard Contractual Clauses or equivalent mechanisms recognized under the GDPR. Data processed under the UK GDPR is safeguarded in the same way, using the UK International Data Transfer Addendum or the UK Addendum to the EU Standard Contractual Clauses where a transfer requires it.
9. Your Privacy Choices
Depending on your relationship with us, your jurisdiction, and applicable data protection laws, you may have the following rights:
| Right | Description |
|---|---|
| Right to Be Informed / Right to Know | Confirm whether we process Personal Data about you (see this Privacy Policy). |
| Right to Access | Request a copy of, or access to, the Personal Data we hold about you. Contact glareprivacy@gmail.com. |
| Right to Correction | Request correction of inaccuracies in your Personal Data. Contact glareprivacy@gmail.com. |
| Right to Deletion | Request erasure of certain Personal Data, subject to exceptions (e.g., legal obligations, fraud prevention, or data recorded immutably on the Network, which Glare cannot delete). Contact glareprivacy@gmail.com. |
| Right to Restriction of Processing | Request that we limit processing under certain conditions (e.g., while we verify accuracy of contested data). Contact glareprivacy@gmail.com. |
| Right to Portability | Request your Personal Data in a portable, machine-readable format. Contact glareprivacy@gmail.com. |
| Right to Withdraw Consent / Object | Withdraw consent at any time where processing is based on consent, or object to processing based on our legitimate interests. |
| Right to Appeal or Lodge a Complaint | If we decline to act on your request, we will explain why and how to appeal. EEA and UK residents may lodge a complaint with their local data protection authority or the UK Information Commissioner. German residents may lodge a complaint with the Bundesbeauftragte für den Datenschutz und die Informationsfreiheit (BfDI) or the competent Landesdatenschutzbehörde of the state where they reside. |
Non-Discrimination.
We do not discriminate against Users or Visitors for exercising their privacy rights, including by denying services or providing a different level or quality of service.
10. Eligibility and Age Restrictions
The Services are not intended for use by, and we do not knowingly collect Personal Data from, individuals under the age of 18. This threshold reflects the financial risk associated with the Services, as described in Section 4 (Risk Disclosure and No Advice) of the Terms, and is independent of any lower age threshold that may otherwise apply to general-audience websites under applicable law. If you believe a minor has provided us with Personal Data, please contact us at glareprivacy@gmail.com so we can address it.
11. Sanctioned and Restricted Persons
Consistent with Section 5 of the Terms, the Services are not offered to Sanctioned Persons or Restricted Persons (including, as applicable, U.S. Persons). We process limited data, such as your wallet address and IP-derived location, to screen for and enforce this restriction, as described in Section 1 above.
12. Additional Notice for US Residents
Residents of certain US states (acting in an individual or household context, not a commercial or employment context), including California, Colorado, Connecticut, Virginia, and Utah, may have additional rights under applicable privacy laws.
"Personal Data" under applicable US privacy laws generally means information that is linked or reasonably linkable to an identified or identifiable individual, and generally excludes publicly available government records, de-identified or aggregated data, and data excluded from a given state law's scope.
We do not "sell" Personal Data as most people would understand that term. We do not disclose your Personal Data in direct exchange for money. However, to the extent our use of cookies or similar technologies for analytics or marketing purposes falls within the definition of a "sale" or "share" under applicable US privacy laws, you may opt out using the cookie preference tool on glarefi.xyz, or by contacting glareprivacy@gmail.com.
Residents of certain US states may have the right to: (a) access and obtain a copy of their Personal Data; (b) delete Personal Data we hold about them; (c) correct inaccuracies in their Personal Data; and (d) opt out of the sale of Personal Data, targeted advertising, or profiling that produces legal or similarly significant effects.
You may submit a request to exercise these rights by contacting us at glareprivacy@gmail.com. We will take steps to verify your identity before acting on your request, and may deny a request we cannot verify, explaining the basis for denial and how to remedy any deficiency. Authorized agents may submit a request on your behalf by contacting glareprivacy@gmail.com and providing proof of authorization. If we decline to act on your request, you may appeal by contacting us, and, if the appeal is denied, submit a complaint to the applicable state Attorney General.