Privacy Policy

Last updated: 2026-04-12

1. Scope

This Privacy Policy applies to personal data processed in connection with the Interface — the websites and hosted services operated by the 9MM Pro team. It does not apply to on-chain activity, which is inherent to public blockchains and publicly visible to anyone. Once a transaction is submitted to a blockchain, it cannot be erased.

2. Data Controller

9mm Pro LLC, a Delaware limited liability company (formation in progress; final entity name and registered address to be inserted prior to publication), is the data controller for personal data processed through the Interface. You can contact us at privacy@9mm.pro for privacy-related requests.

3. Information We Collect

Collected automatically when you use the Interface:

• Wallet address (when you connect a wallet)
• IP address and approximate geolocation (for sanctions screening and fraud prevention)
• Device and browser information (user agent, screen size, language)
• Interaction events (pages viewed, buttons clicked, search queries)
• Referrer URL

Collected if you voluntarily provide it:

• Email address (e.g., if you subscribe to updates or contact support)
• Any information included in correspondence with us
• Governance forum participation data (if applicable)

On-chain information (public, not "collected" in the personal-data sense):

• Your transaction history and balances on any supported chain
• Your interactions with 9MM Pro smart contracts
• These are public and immutable — we do not store or control them

4. Information We Do Not Collect

• No KYC — we do not collect names, government IDs, dates of birth, passport numbers, selfies, or proof-of-address
• No private keys or seed phrases are ever transmitted to us. No 9MM Pro product or employee will ever ask for them
• No payment-card or bank information

5. How We Use Information

• To operate and maintain the Interface
• To prevent fraud, phishing, and unlawful use
• To comply with sanctions regimes and applicable laws (including automated wallet screening)
• To analyze aggregate usage patterns and improve the Interface
• To respond to your support requests
• To communicate important updates when necessary

6. Legal Bases for Processing

We rely on the following legal bases where required by applicable law:

• Contract — processing necessary to provide the Interface you are using
• Legitimate interest — fraud prevention, security monitoring, analytics, and defending legal claims
• Legal obligation — sanctions compliance, responding to valid legal requests
• Consent — where you voluntarily provide information such as an email for newsletters

7. Sharing With Third Parties

We may share limited data with:

• Infrastructure providers — hosting, CDN, DDoS protection (Cloudflare)
• Analytics providers — aggregate, anonymized usage metrics
• Error monitoring — crash and error reporting
• Compliance vendors — sanctions and wallet-screening services (Chainalysis or equivalent)
• Law enforcement — where required by valid legal process
• Professional advisors — lawyers, accountants, auditors

We do not sell personal data.

7a. Third-Party Wallet and RPC Telemetry

When you connect a wallet to the Interface, your wallet address, IP address, and request metadata are necessarily exposed to third parties that we do not operate, including:

• WalletConnect and similar wallet-connection relays, when used to connect a mobile or external wallet
• Public RPC endpoints (such as those operated by Infura, Alchemy, Ankr, the PulseChain public RPC, or chain-default endpoints), which receive your IP address and the read/write requests your wallet makes
• Block explorers that we link to (such as PulseScan, BaseScan, Etherscan)

These services have their own privacy policies and we have no control over what they collect or retain. If you wish to minimize this exposure, you can use a self-hosted RPC endpoint or a privacy-preserving wallet.

8. International Transfers

Because 9MM Pro is a global service, your data may be transferred to and processed in jurisdictions outside your country of residence. Where required, we rely on appropriate safeguards such as Standard Contractual Clauses (SCCs) or equivalent legal mechanisms.

9. Retention

• Server logs — up to 90 days for security and debugging, then deleted or anonymized
• Analytics data — retained indefinitely in anonymized, aggregated form
• Correspondence — up to 24 months from last contact, longer if required by law or for an active legal matter
• On-chain data — not within our control; public and immutable

10. Security

We implement commercially reasonable technical and organizational measures to protect data. However, no system is perfectly secure — especially in DeFi. You are responsible for securing your own wallet.

11. Your Rights

Where applicable law gives you rights regarding your personal data — including, depending on your jurisdiction, rights to access, correct, delete, port, restrict processing of, or object to the processing of your data — we will honor those rights to the extent required by law. Note that on-chain data cannot be erased, as it is recorded on public, immutable blockchains outside our control.

If you are a California resident, the CCPA/CPRA gives you the rights to know, delete, correct, and limit use of your personal information. We do not sell or share personal information for cross-context behavioral advertising.

To exercise any of these rights, contact us at privacy@9mm.pro. We may require additional information to verify your identity before responding.

12. Automated Decision-Making

We use automated systems to screen wallet addresses and IP geolocation against sanctions lists and to flag potentially fraudulent activity. These systems may result in access to the Interface being blocked. If you believe you have been incorrectly blocked, contact privacy@9mm.pro.

13. Children

The Interface is not directed at children under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, contact us and we will investigate.

14. Cookies and Similar Technologies

Our Interface uses cookies and similar technologies for the following purposes.

Essential Cookies — required for the Interface to function:

• Session state (which wallet is connected, which chain is selected)
• User preferences (theme, persistent tab selections across pages)
• Security and anti-abuse tokens
• Sanctions-screening state

These cannot be disabled without breaking the Interface.

Analytics Cookies — anonymized usage measurement (page views, referrer, browser, interaction counts). We do not attempt to identify individual users from analytics data.

What we do not use cookies for:

• Cross-site advertising tracking
• Building advertising profiles
• Selling data to third-party ad networks
• Retargeting across unrelated websites

You can disable cookies in your browser settings, but some Interface functionality — like remembering your chain selection or theme preference — will stop working between visits.

15. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be announced via the official Telegram and X channels. The "Last updated" date at the top of this page reflects the most recent revision.

16. Legal Requests and DMCA

We respond to valid legal process. Please allow up to 10 business days for an initial response. Submitting false or abusive notices may result in liability under 17 U.S.C. § 512(f) or equivalent law.