Privacy Policy

CHOMP — Privacy Policy

Effective Date: February 19, 2026

This Privacy Policy describes how Gator Labs, Inc. ("CHOMP," "we," "our," or "us") collects, uses, and discloses information about you. This Privacy Policy applies to information we collect when you access or use our website, mobile application, services, products, and any other online services we provide, as well as any other interaction you may have with CHOMP (collectively, the "Services").

Please read this Privacy Policy carefully so you understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to interact with the Services. By accessing or using the Services you agree to this Privacy Policy. We encourage you to check this Privacy Policy regularly so you stay informed about our practices and the choices available to you.

This Privacy Policy includes the following sections:

Information We Collect

How We Use Your Information

Sharing Information

Cookies and Similar Technologies

Analytics and Advertising

Your Choices

International Transfers

What Is Our Legal Basis?

How We Protect Your Information

Information Storage

Technical Infrastructure and Your Data

Age Restrictions

Changes to This Privacy Policy

Third-Party Links and Features

Contact Us

1. Information We Collect

Depending on how you use the Services, we may collect information about you in the following ways:

1.1 Information You Provide

You provide us with information when you create an account, update your profile, participate in Activities (such as structured prompts, nowcasting questions, or challenges), communicate with us by email, or otherwise interact with the Services.

1.2 Information Collected Automatically

We automatically collect information about your interactions with the Services, including when you view or click content, navigate between pages, or engage with features.

1.3 Information from Third Parties

We may receive information about you from third parties. Our advertising and business partners may also share information about you with us.

1.4 Categories of Information

In connection with using the Services, we may collect the following categories of information:

Profile Content. Your name, username, profile picture, email address, preferences, and phone number.

Device Data. Device type, software and hardware details, browser type and version, operating system, IP address, location information, unique device identifiers, and mobile device ID.

Log and Usage Data. Information about your activity on the Services, such as content viewed, pages visited, links clicked, usage patterns, and ranking information relative to other users.

Response and Contribution Data. Your first-order responses, second-order beliefs about peer responses, calibration and reputation signals, contribution quality scores, and other data generated through your participation in Activities within the Services. This data is used by the platform's deterministic aggregation mechanism to resolve outcomes endogenously and to calculate informational contribution quality.

Communication Information. Information about your communications with us and messages sent through the Services.

Third-Party Connections and Integrations. If you access the Services through a third-party connection or login, you allow us to access and store certain information from that third party, depending on your settings with that service. Please see the privacy policies and terms for these third parties for more information.

Information Collected Through Tracking Technologies. Like many online services, we may use cookies and similar technologies to collect additional usage data and to operate our business. For more information, see the Cookies and Similar Technologies section below.

Transaction, Credit, and Rewards Data. Information relating to your participation in Activities, credits earned and staked, account-level accrual balances, rewards redistributed under the platform's deterministic rules, redemption history (where applicable), wallet addresses, and transaction history within the Services.

Other Information. Any other information that you choose to provide or that we request.

Sometimes we aggregate or de-identify information so that it can no longer identify you, as defined under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments, or compile aggregated results. We can use and disclose this aggregated or de-identified information for any purpose unless an applicable law says otherwise.

2. How We Use Your Information

We use the information we collect in connection with what we consider our Everyday Business Activities, which may include using your information to:

Operate and Provide the Services. We may use the information we collect to provide and operate the Services, including maintaining your account and profile, processing credits and Rewards, resolving Activity outcomes through the platform's deterministic aggregation mechanism, calculating informational contribution quality and reputation signals, contacting you about technical notices or security alerts, and personalizing your user experience.

Monitor and Improve the Services. We may use the information we collect to analyze the effectiveness of the Services, review usage patterns, evaluate calibration and scoring accuracy, and improve the Services.

Research. We may use information you share with us, or that we collect, to conduct research, product testing, and troubleshooting to help us operate and improve the Services. This may include analysis of aggregated participant responses and contribution quality metrics to evaluate mechanism performance and to demonstrate that informational contribution quality, rather than chance, drives outcomes on the platform.

Communicate with You. We may use information we collect to communicate with you about the Services, including offers, promotions, and other news and information we think will be of interest to you.

Facilitate a Corporate Transaction. We may use the information we collect during negotiations or in connection with a sale, acquisition, financing, bankruptcy, or similar corporate transaction.

Foster Safety and Security. We use the information we collect to provide for the safety and security of our users and the Services. This includes detecting and preventing malicious, deceptive, fraudulent, or illegal activities, monitoring for platform integrity violations including strategic misreporting and exogenous outcome manipulation, improving our security, exercising our legal rights, and complying with applicable law.

Content Moderation. We use information we collect to review user-generated prompts and content to ensure that all Activities remain endogenous and do not anchor outcomes on external events, scores, results, award announcements, elections, financial instruments, or other real-world occurrences.

Compliance and Regulatory Purposes. We may use information we collect to maintain jurisdiction-specific legality assessments, fulfill diligence and reporting obligations, and support compliance programs as required by applicable law and regulation.

Personalized Advertising. We gather data and work with advertising partners, marketing partners, and third parties to measure the performance of personalized ads on behalf of advertisers. We may combine information collected through registration with information collected automatically using tracking technologies to build models and measure user attributes.

3. Sharing Information

In connection with our Everyday Business Activities, we may share information collected from and/or about you in the following circumstances:

Service Providers. We may share your information with service providers that perform functions or provide services on our behalf, such as business, professional, or technical support; helping us with our business and the Services; and administering activities in connection with our business.

Payment and Wallet Infrastructure Providers. We may share information with third-party providers that power the platform's payment, wallet, and redemption infrastructure. CHOMP utilizes a non-custodial wallet architecture and does not receive, hold, or have signatory authority over user funds. Where optional cash redemption is available, compliance obligations including identity verification (KYC), sanctions screening, and tax reporting are contractually allocated to the licensed third-party provider.

Advertising Partners. So that we can deliver more relevant content to you and measure the effectiveness of ads.

Comply with Laws and Protect Our Rights. We may share your information as we believe to be necessary or appropriate to comply with applicable law and legal processes; respond to requests from public and government authorities; protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and allow us to pursue available remedies or limit damages.

Regulatory and Compliance Disclosures. We may share information with regulatory bodies, gaming authorities, or other governmental entities as required to fulfill jurisdiction-specific diligence, reporting, and monitoring obligations.

Investors and Acquirers. We may transfer your information to advisors, investors, potential transactional partners, or other third parties in connection with a merger, acquisition, sale, change in control, financing, bankruptcy, or similar transaction.

With Other Third Parties. There are situations when we disclose your information to third parties beyond our service providers. While we try to control the behavior of our vendors, some may engage in activities beyond our control.

With Your Consent or at Your Direction. We may share your information with third parties when you direct us to do so or if you have consented to additional sharing.

You acknowledge that you have no expectation of privacy for or concerning information you submit to us (including responses to Activities), content you provide in connection with the Services, information from your profile that you choose to make public, or your use of these features of the Services.

4. Cookies and Similar Technologies

Like most other online services, CHOMP uses cookies and similar technologies to collect some of the data discussed in this Privacy Policy. These help us provide certain features to you and analyze usage information. See the Your Choices section below for additional information about managing cookies.

Our uses of cookies and similar technologies fall into the following general categories:

Essential. Technologies necessary to provide the Services, including those that allow you to access our sites and applications, or are required to identify irregular site behavior and improve security.

Performance. Technologies used to assess the performance of the Services, including as part of our analytic practices to understand how visitors use our websites and whether you have interacted with our messaging.

Functionality. Technologies that allow us to offer enhanced functionality, including delivering error messages and enhancing the presentation of content.

Advertising Cookies. Cookies that allow management of advertising by third parties and our advertising partners.

5. Analytics and Advertising

We may engage others to provide analytics services and serve advertisements across the web and in mobile applications. These entities may use cookies and similar technologies to collect information about your use of the Services and your activities across other websites and online services, which they may associate with persistent identifiers. Sometimes these identifiers may be derived from a hashed or encrypted version of personal information such as your email address. We may use this information to measure the performance of our advertising.

Their activities and your choices regarding their use of your information to personalize ads are subject to their own policies. We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on your device by non-affiliated third-party providers. As described in the Your Choices section, these providers may offer you a way to opt out.

6. Your Choices

You may have certain choices about how to protect and limit the collection, use, and sharing of information about you, including:

6.1 Opt-Out of Marketing Communications

You may opt out of receiving marketing communications from us by following the instructions in those communications or by submitting a request to [e-mail]. If you opt out, we may still send you non-promotional messages such as messages about our ongoing business relationship.

6.2 Opt-Out of Cookies and Tracking Technologies

You can often adjust your browser settings to remove or reject browser cookies. If you remove or reject cookies, the availability and functionality of the Services may be affected. You may also limit or block cookies and similar tracking technologies by:

Blocking Advertising ID Use in Your Mobile Settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.

Using Privacy Plug-Ins or Browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins configured to block third-party cookies or trackers.

6.3 Do Not Track

Please note that, while we provide tools to manage your privacy as described in this Privacy Policy, we do not support "Do Not Track" browser settings at this time.

6.4 Platform Opt-Outs

The following platforms offer opt-out features that let you opt out of use of your information for interest-based advertising. We currently do not engage in services with all of these platforms, but in the event that we do, you have the option to opt out:

Google Analytics: https://adssettings.google.com/

Facebook: https://www.facebook.com/about/ads

Twitter: https://twitter.com/personalization

6.5 Advertising Industry Opt-Out Tools

You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:

Digital Advertising Alliance: https://optout.aboutads.info

Network Advertising Initiative: https://optout.networkadvertising.org/

6.6 Mobile Notifications

We may send promotional and non-promotional push notifications to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

6.7 Other Rights and Choices

Where required by applicable law and depending on your jurisdiction, you may have access to certain rights, including the right to obtain confirmation that we maintain certain personal information relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or block or withdraw consent to the processing of certain personal information. If you are unable to exercise your rights using the mechanisms described above, you may email us at [e-mail]. We may ask you to provide information necessary to reasonably verify your identity before responding to your request. If we cannot verify your identity, we will not be able to fulfill your request.

7. International Transfers

We have operations in the United States. If you are located outside of the United States, your information is collected in your country and then transferred to the United States, or to another country in which we (or our affiliates or service providers) operate. If we transfer your data out of the European Economic Area (E.E.A.), we implement at least one of the following safeguards:

We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards.

We confirm that the service provider to which we are transferring data has an active self-certification under the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, as applicable.

We take steps to ensure that the recipient is bound by contractual obligations, including E.U. Standard Contractual Clauses together with addenda or language to cover the UK and/or Switzerland, as applicable, and additional safeguards to protect your personal data.

In certain situations, the courts, law enforcement agencies, or regulatory authorities in those countries might be entitled to access your personal information.

8. What Is Our Legal Basis?

In some jurisdictions like the European Union and the E.E.A., we only collect, use, or share information about you when we have a valid reason. This is called a "lawful basis." Specifically, this is one of the following:

The consent you provide to us at the point of collection of your information;

The performance of the contract we have with you;

The compliance of a legal obligation to which we are subject; or

The legitimate interests of CHOMP or a third party.

"Legitimate interest" is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business; (3) to prevent fraud; (4) to conduct our marketing activities; and (5) to maintain platform integrity and ensure that Activities resolve endogenously in accordance with the platform's deterministic rules.

9. How We Protect Your Information

We use reasonable procedural, physical, and electronic safeguards to protect your information from unauthorized access or use. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no method of transmission over the internet or electronic system is completely secure, so we are unable to guarantee absolute security.

The safety and security of your information also depends on you. Do not share your account credentials, passwords, wallet private keys, recovery phrases, or any associated authentication details with anyone. We may provide you with additional security features like multifactor authentication, and we strongly recommend that you utilize these features.

10. Information Storage

We retain your information for as long as necessary to provide the Services, fulfill our legal obligations, enforce our legal agreements, and resolve disputes. Retention periods are determined on a case-by-case basis depending on the nature of the information, why it was collected, and the applicable legal reason(s) for retention. We may also keep certain information when necessary to protect the safety and security of the Services, to maintain audit logs and records sufficient to reconstruct Activity outcomes and verify the platform's deterministic scoring, and to support jurisdiction-specific compliance and reporting obligations. Rather than delete your data, we might de-identify it by removing identifying information.

11. Technical Infrastructure and Your Data

Certain features of the Services are powered by third-party technical infrastructure, including distributed ledger (blockchain) networks, digital wallets, and stablecoin-denominated payment systems. This section describes how these technologies may interact with your data.

11.1 Publicly Recorded Data

When transactions are processed through the Services, certain data, such as wallet addresses, transaction amounts, and transaction identifiers, may be recorded on public distributed ledger networks. This data is publicly visible and, due to the nature of blockchain technology, generally cannot be modified, deleted, or reversed after confirmation. We do not control the public accessibility of data recorded on these networks.

11.2 Wallet-Related Information

To use certain features of the Services, you may be required to create or connect a digital wallet. CHOMP utilizes an embedded non-custodial wallet architecture in which CHOMP does not receive, hold, or have signatory authority or unilateral control over user funds. In connection with your wallet, we may collect or have access to your wallet address and associated transaction history on public networks. If you use a third-party wallet provider, that provider's collection and use of your data is governed by their own privacy policy and terms, not this Privacy Policy.

11.3 On-Chain vs. Off-Chain Data

We store most of your personal information (such as your name, email, profile details, and Activity responses) in our own databases, which are protected by the security measures described in Section 9. Only limited transaction-related data is recorded on public blockchain networks. We take care to minimize the amount of personally identifiable information that is recorded on-chain.

11.4 Redemption Data

Where optional cash redemption is available, redemption is processed at the account level outside the core mobile application through a licensed third-party provider. CHOMP does not receive, hold, or control user funds at any point in the redemption process. The third-party provider may collect additional information from you in connection with redemption, including for identity verification (KYC), sanctions screening, and tax reporting purposes. That provider's collection and use of your data for those purposes is governed by their own privacy policy and terms.

11.5 Limitations on Deletion

While we can delete or de-identify personal information stored in our own systems in accordance with your rights under applicable law, we cannot delete or modify data that has been recorded on a public blockchain network. If you exercise a right to deletion, we will delete the information we control, but on-chain data will remain as a permanent record on the applicable network. We will clearly inform you of these limitations when responding to any deletion request.

12. Age Restrictions

The Services are not intended for anyone under the age of 18. We do not knowingly collect or solicit personal information from children. In the event that we become aware of information from an individual under the age of 18, we will promptly take steps to delete such information. If you believe a child under 18 has provided information to us in connection with the Services, please contact us at [e-mail].

13. Changes to This Privacy Policy

We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information or use what we already have differently. Further, the laws regarding personal information and privacy frequently change.

We will notify you of any changes we make by revising the date at the top of this page. We may also provide you with reasonable notice of material changes before they take effect or as otherwise required by applicable law. If you object to any change, you can stop using the Services. After we post any changes, your continued use of the Services is subject to the updated Privacy Policy.

14. Third-Party Links and Features

The Services may contain links, banners, or widgets to third-party sites, applications, and services. We may also incorporate third-party software (including open-source software) in the Services. These links and features are provided for your reference and convenience only and do not imply any endorsement of information provided through them, nor any association with their operators. CHOMP is not responsible for the practices of such third parties. Any information you provide to third parties on their sites or services is covered under their privacy and data collection practices and not covered by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

15. Contact Us

If you have any questions about this Privacy Policy or our data practices, please email us at [e-mail].