Cointiply Labs — Privacy Policy

1. Who Is Responsible

3D Asset Holdings LLC ("Cointiply", "we", "us") is the data controller for personal information collected through Cointiply Labs. For privacy questions, contact privacy@cointiply.com.

2. Information We Collect

We collect the following categories of personal information when you use Cointiply Labs:

• Account identifiers from your bridged cointiply.com account: numeric user id, email address, display name, country, reward level, role.
• Authentication artifacts: an opaque session id placed in an httpOnly cookie, an upstream Cointiply API token kept server-side, the user-agent and a salted hash of your IP for the active session row.
• Conversation content: every prompt you send, every assistant message returned, every tool call invoked, and every embed rendered, plus token counts and timing.
• Conversational memory: facts the system extracts from your messages (goals, preferences, constraints, quirks, pinned reminders), with the source message id and a confidence score.
• Voice data when you use voice input: the audio recording sent to the speech-to-text provider, the resulting transcript, any text-to-speech audio rendered back, plus duration counters used for billing and cost-cap enforcement.
• Reward and earning telemetry: which embeds you opened, which offers you bookmarked, which reminders you set, which quests you completed in-Labs, which plugins you unlocked.
• Operational metadata: usage-ledger rows for token, voice-second, and tool-call accounting; coin-ledger rows for in-Labs coin movements; widget preferences and pinned-widget layouts.
• Anti-abuse signals: rate-limit counters, captcha challenge results, and risk metadata derived from your interaction pattern.

3. How and Why We Use It

We use the information described in Section 2 to operate Cointiply Labs — including authenticating your session, generating LLM responses, rendering accurate embeds, persisting memory, billing your usage against your quota, and synchronizing your coin and reward state with cointiply.com — and to perform the routine business activities of running an internet service: detecting and preventing fraud, enforcing our Terms of Service, complying with legal obligations, and improving the Service through aggregated, de-identified analytics.

4. Sharing With Third-Party AI Processors

To deliver Cointiply Labs, we share Inputs, selected portions of conversation history, derived memory facts, voice recordings (when you use voice input), and minimal metadata with third-party AI processors. These processors operate the underlying LLMs and voice models. The current set of processors is:

• Anthropic Claude — operated by Anthropic, PBC; primary jurisdiction: United States. Use: Primary chat model. Privacy policy: https://www.anthropic.com/legal/privacy.
• OpenAI — operated by OpenAI, L.L.C.; primary jurisdiction: United States. Use: Voice transcription, voice synthesis, and fallback chat models. Privacy policy: https://openai.com/policies/row-privacy-policy.
• DeepSeek — operated by Hangzhou DeepSeek AI Basic Technology Research Co., Ltd.; primary jurisdiction: People's Republic of China. Use: Mini-tier chat (rule-based easy route), rolling chat summaries, and long-term fact extraction. Privacy policy: https://chat.deepseek.com/privacy_policy.

5. Specific Notice About DeepSeek and PRC Data Transfers

Cointiply Labs routes some chat turns to DeepSeek, an LLM provider operated from the People's Republic of China. Data sent to DeepSeek (including your prompt, the relevant portion of your conversation history, and any context the system attaches to that turn) is processed and may be retained on infrastructure subject to PRC law, which permits state access to data on a basis broader than is generally permitted in the United States or European Economic Area.

By using Cointiply Labs you expressly consent to the international transfer of your data to the PRC for the purpose of generating LLM responses. You agree not to enter highly sensitive personal data into Cointiply Labs, including without limitation: identity-document numbers, banking credentials, payment-card numbers, social-security or national-id numbers, biometric identifiers, health records, attorney-client communications, classified material, or political-opinion content that would expose you to risk if disclosed to a foreign government.

If you do not wish your data to be transferred to the PRC under any circumstances, you must not use Cointiply Labs.

6. Other Sharing

We share information with: (a) the cointiply.com platform itself, since Labs is the AI-mediated surface of your underlying account; (b) infrastructure providers that host the application (currently Vercel for hosting and edge delivery, and a managed MySQL provider for the application database); (c) analytics and product-improvement vendors operating under contractual data-processing terms; (d) law-enforcement, regulators, courts, and other parties when we are legally required to do so; and (e) acquirers, in the event 3D Asset Holdings LLC or its assets are sold, merged, or reorganized, subject to the privacy commitments in this Policy.

7. Retention

Conversations, memory facts, usage rows, and coin-ledger rows are retained for the lifetime of your bridged Cointiply account, unless you delete them through the in-product controls or request deletion under Section 9. Anti-abuse and audit records may be retained for up to seven (7) years to comply with our legal and accounting obligations even after you delete the underlying chat content. Server access logs, the ipHash on session rows, and per-route rate-limit counters are typically retained for thirty (30) to ninety (90) days.

Once your data has been forwarded to a third-party AI processor, retention by that processor is governed by their own privacy policy. We cannot retroactively erase data from a processor's logs.

8. International Transfers

Cointiply Labs is operated from the United States. By using Cointiply Labs you consent to the transfer of your information to, and storage and processing in, the United States and in any other country where Cointiply or its processors operate, including (without limitation) the People's Republic of China for DeepSeek-routed turns. The data-protection laws in those countries may differ from, and may be less protective than, the laws of your home jurisdiction.

9. Your Rights

Depending on your jurisdiction, you may have the right to (a) request a copy of the personal information we hold about you; (b) request correction of inaccurate information; (c) request deletion of your information; (d) object to or restrict certain processing; (e) withdraw consent on which our processing relies; and (f) lodge a complaint with your local data-protection authority. You may exercise these rights by emailing privacy@cointiply.com. We may need to verify your identity before complying. Some rights are subject to exceptions — for example, we will continue to retain anti-abuse records as required by law.

California residents have additional rights under the California Consumer Privacy Act, including the right to know what categories of personal information we collect and disclose, the right to deletion, and the right to non-discrimination for exercising your privacy rights. Cointiply does not "sell" personal information as that term is defined under California law.

10. Children

Cointiply Labs is not directed to children under eighteen (18). We do not knowingly collect personal information from anyone under eighteen. If we learn that we have collected such information without verified parental consent, we will delete it.

11. Security

We use industry-standard technical and organizational measures to protect your information, including TLS for data in transit, server-side storage of upstream API tokens, httpOnly cookies for session ids, and least-privilege access controls. No security measure is perfect; we cannot and do not guarantee that an unauthorized third party will never gain access to your information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. The version of this Policy is "1.0", aligned with the Cointiply Labs Terms of Service. Substantive changes will trigger a new version and a new acceptance gate before you can continue to use Labs.

13. Contact

For privacy questions, requests, or complaints, write to privacy@cointiply.com. For all other legal matters, write to legal@cointiply.com. 3D Asset Holdings LLC is the data controller responsible for Cointiply Labs.