ChainThink Privacy Policy

Last Updated: July 17, 2026

We fully recognize the importance of your personal data and are committed to protecting your privacy in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and other applicable UK data protection laws. This Privacy Policy aims to clearly explain how we collect, use, share, disclose, store and protect your personal data when you visit our website, use the ChainThink App, or subscribe to our news briefs, newsletters, and research reports (collectively, the ‘Services’).

This Privacy Policy serves as a transparent notice regarding our data processing activities in accordance with legal requirements. We want to ensure you fully understand how your data is handled.

Please read this policy carefully before using our products and services and ensure that you fully understand its contents. Once you begin using our services, it will be deemed that you have thoroughly understood and agreed to all terms of this policy. We reserve the right to revise this policy in a timely manner based on business developments or legal and regulatory requirements. The updated version will be marked by the "Last Updated" date at the top of this document. You may refer to the latest version of this policy at any time on the ChainThink official website or within the App settings page.

By utilizing our website or App, you acknowledge that you have been informed of the data practices described herein. If you have any questions, concerns, or objections regarding our data processing practices, or if you do not wish your data to be processed under certain legal bases (such as our legitimate interests), you are not required to provide your information and may contact our Data Protection Officer at contact@momentumgrowthagency.co.uk at any time.

Privacy Policy Summary

• We explain the types and purposes of personal data collected during your registration, login, and use of our services;
• We use your information within the scope of legality, legitimacy, and necessity, in strict accordance with applicable legal bases;
• You have the right to manage, modify, or delete your personal data, and you retain the right to be informed and in control;
• We do not disclose or unlawfully share your information without legal justification or your explicit consent;
• We adopt technical and managerial measures to ensure the security of your data.

1. Personal Data We Collect

In accordance with applicable data protection laws and relevant regulatory standards, ChainThink may collect the following types of personal data in the course of providing services. We do not collect non-essential permissions or process your data without justified legal grounds.

1.1 Registration and Login Information

To create, verify, and secure your account infrastructure, we may collect:

• Account Credentials: Your email address and verification codes, which are used for registration, identity verification, maintaining your login status, and securing your account.
• Third-Party Login Authorized Info: Authorized account information from third-party platforms (e.g., Google account) if you choose to log in via those methods, which is used to facilitate seamless account creation.

1.2 Profile Information and Notification Channel

We collect the following information to personalize your user interface and route requested updates to your preferred services. We rely on your explicit, freely given chooses for specific processing activities. You are not required to provide this information or subscribe to these features to use our notification services, and you have the right to withdraw your services or unsubscribe at any time.

You may voluntarily provide or manage the following information to complete your profile and secure your account, we may collect:

• Profile Customization: Your chosen nickname, avatar, and other basic information you voluntarily provide, which are used for the purpose of personalizing your dashboard and displaying your identity during platform social interactions or comment displays.
• Account Binding and Linking Preferences: You may also bind multiple login methods such as Google account, and unlink them at any time via the "Account Settings" section.

You may voluntarily subscribe memberships, newsletter, on-chain signals and market alerts, we collect:

• Subscriptions and Transaction Data: Your membership details (including current plan, subscription status, current billing period, next billing date, and next renew amount), subscription records (including time, record type, and descriptions), stripe billing history (including payment date, payment channel, billing period, payment type, amount, order number, and invoice), which are collected only if you choose to subscribe to our in-app/on-site premium services, and are used for the purpose of viewing and managing plans, renewals, invoice requests, and billing history. You can cancel your renewal or edit your subscription at any time.
• Newsletter Choices: Your newsletter subscription status, delivery email address, and subscription frequency, which are collected only if you choose to subscribe to our newsletter, and are used for the purpose of viewing and managing your email preferences and subscription status. You can unsubscribe or edit your email and frequency at any time.
• On-chain Signal Alerts: Your delivery email address, telegram username/ID, your perferrences of the signals you want to receive by Email or Telegram (including Basic price alerts, Airdrop Radar, Whale and institutional flowPro, On-chain contract movementsPro), ,and are used for the purpose of viewing and managing your email and telegram delivery channel, plus market, on-chain, airdrop and research alerts. You can cancel your renewal or manage your subscription at any time.
• API: Your API account configurations (including your designated API email, system-generated API Key, current account type, and license expiration date), usage quota statistics (including daily API calls by membership tier), and API content access parameters (including feature permissions for News, Airdrops, Depth, and Research based on your Free, Pro, Research/Trader, or Enterprise status), which are collected and generated only if you choose to activate and utilize our API services, and are used for the purpose of managing API authentication, reviewing member quotas, and confirm the available historical data range. You can reset your API Key, or manage your developer access status at any time.

1.3 Usage Records and Content Preferences

To optimize user experience, perform statistics, and continuously refine our platform features, we may collect:

• Content Engagement Data: Your reading history, saved articles, likes, comments, followed authors or subscribed keywords.;
• Search Keywords: Your search keywords within our services, which is stored locally on your device and can be cleared through your App or browser settings at any time.
• Favorites Content: Your designated bookmarking indicators and saved categories (including curated lists under Depth, Airdrops, or Research), which are collected and stored only when you voluntarily add items to your personal collection, and are used for the purpose of maintaining your personalized dashboard, delivering quick-access content links, and refining our interface presentation. You can add or remove items from your favorites at any time.
• Interface and Display Preferences: Your selected platform settings, including system display language (such as English) and application interface themes (such as Follow System, Light, or Dark modes), which are collected and processed based on your interactive toggles, and are used for the purpose of rendering the user interface according to your customized visual preferences and technical language environments. You can update your display preferences or request permanent account erasure (via the "Request Deletion" option) at any time.

1.4 Device and System Information (for operational and security purposes)

To monitor system access, maintain service integrity, establish fundamental network connections, and prevent malicious activities, we may collect and receive:

• System Operations Data: Your device model, operating system version, unique device identifiers (e.g., IDFA, Android ID, or other hardware identifiers), network status, and App usage logs (such as crash reports, error codes, and access times), which are used to detect abnormal behavior and safeguard our infrastructure.
• IP Addresses and Technical Connectivity: When you access the ChainThink website or App, ChainThink receives, as an essential technical requirement, the Internet Protocol address (IP address) or the device ID of the device used to access our services. Without this information, you will not be able to establish a technical connection between your devices and our server infrastructure.
• System Permission Requests (App Only): System-level operational permissions including push notifications, local storage access, and camera permissions, as detailed in our ‘Permission Usage Statement’. Please note that these device permissions are requested separately and on an as-needed basis through your device's native authorization prompts. We cannot access or collect data under these permissions unless you explicitly grant consent. You retain full control and may modify or revoke these permissions at any time via your device's operating system settings.

We will not access or collect non-essential permissions or sensitive data—including but not limited to contacts, clipboard contents, call records, or microphone audio—without your explicit, separate authorization.

1.5 Personalized Recommendations

ChainThink does not currently provide personalized or algorithmically generated content recommendations based on your individual browsing history, behaviour, or interaction data. Content on our website and App is organised by fixed content categories (for example, by asset type or topic) that are the same for all users, rather than an individually tailored feed. Should we introduce personalized recommendation features in the future, we will update this Privacy Policy accordingly and, where such processing relies on your consent, obtain your explicit consent beforehand in accordance with applicable UK data protection laws.

We respect your right to control how your data drives your user experience. You can manage or disable personalized content features at any time:

• Opt-Out Pathway: You may turn off the personalized recommendation toggle entirely via the Settings / Privacy Settings.
• Effect of Disabling: Once turned off, we will immediately cease utilizing your individual tracking data or historical behavioral logs for the purposes of algorithmic content sequencing. The platform will automatically revert to displaying a standard, non-personalized feed or a purely time-based content layout instead.

Turning off personalized recommendations will not reduce the volume of content available on the platform; it simply ensures that the layout you see is delivered without the use of individualized algorithmic targeting.

2. Lawful Bases for Processing Your Data

In accordance with applicable UK data protection laws (including the UK GDPR), ChainThink relies on the following lawful bases to process the personal data categories collected under Section 1:

Performance of a Contract: When you register an account, customize your profile, activate subscription plans, or access ChainThink products and services, the purposes of processing your personal data are primarily determined by that specific service scenario, and we process your personal data so that we can deliver those core functionalities to you. Please note that providing some of your personal data is mandatory to maintain account infrastructure or process transactions (e.g., as indicated within the specific service interface). If you do not provide such information, we may not be able to provide you with the relevant products or services.

Consent: For optional interactions, customized channel alerts, newsletter distribution, or advanced developer features (such as API integration), we process your personal data based on your explicit, freely given consent. You have the right to withdraw your consent or update your preferences at any time through the relevant account or system settings. Please note that withdrawal of consent does not affect the lawfulness of processing carried out prior to your withdrawal.

Legitimate Interests: We process your data when necessary for our legitimate operational and IT security interests, provided they do not override your privacy rights. This primarily applies to receiving essential technical connectivity metrics (such as IP addresses), preserving user interface preferences (such as language and theme settings), maintaining core user engagement structures (such as favorites), analyzing system crash logs, and safeguarding our infrastructure against malicious behavior.

Legal Obligations: We may process or disclose relevant categories of personal data when mandatory for compliance with applicable regulatory laws, statutory tax codes, official financial audits, or lawful court orders to which ChainThink is subject.

3. How We Use Your Information

Your information may be used for the following purposes:

• To provide core functions and services as requested by you;
• For account security verification, customer support, and risk prevention;
• To organise content into categories and improve user experience;
• For transaction payment processing and after-sales support;
• To comply with laws, regulations, or platform compliance obligations;
• For statistical analysis, data modeling, and product iteration (with anonymization or de-identification applied);
• With your authorization, for participation in interactive activities, personalized marketing, or push notifications.

If we intend to use your personal data for any purposes materially distinct from those outlined in this policy, we will process such data under an appropriate lawful basis (such as fulfilling contractual necessity or pursuing legitimate interests), or, where mandated by applicable laws, obtain your express consent or provide you the prior notice.

4. Use of Cookies and Similar Technologies

To improve service quality, enhance use experience, and ensure account security, ChainThink may utilize local storage or identification technologies such as Cookies, LocalStorage, Web Beacons, and SDKs during your use of the App or website (collectively referred to as "similar technologies"). All cookies used on our website can be managed on our Cookie Banner. These technologies fall into two groups: (i) strictly necessary cookies, which do not require your consent because they are essential to providing the service you request, and (ii) optional cookies, which are only activated with your prior consent given via our Cookie Banner.

The primary purposes of using these technologies include:

• Identity recognition (Login Cookies – Strictly Necessary): to help maintain login status and avoid repeated authentication, these cookies do not require your consent, as they are strictly necessary to provide the service you request;
• Security (Strictly Necessary): to keep our services safe and reliable, the cookies do not require your consent for the same reason as above;
• Preference storage (Language and Consent Settings – Strictly Necessary): such as language and your cookie consent choice, these cookies do not require your consent;
• Product optimization (Analytical – Optional, Consent Required): evaluating feature usage and user flow to enhance design and functionality; these cookies are only set on our website (all first-party) with your prior consent given via our Cookie Banner.
• Functional (Optional, Consent Required): enabling additional non-essential website features and functionality that go beyond the strictly necessary cookies described above. These cookies are only set on our website (all first-party) with your prior consent given via our Cookie Banner.
• Marketing (Marketing – Optional, Consent Required): supporting marketing communications and promotional content based on anonymized usage behavior; ChainThink does not use these cookies to generate personalised content recommendations, these cookies are only set on our website (all first-party) with your prior consent given via our Cookie Banner.

These technologies typically collect device info, operating system, network type, access time, and click behavior—processed in compliance with applicable data minimization principles.

First-Party Cookies: Our website utilizes ‘first-party cookies’ including login, security, and language settings, set and controlled entirely by ChainThink to remember your login status, manage your display preferences, and maintain session continuity. You have the right to refuse or disable these cookies at any time through your browser settings (such as clearing your cache or adjusting cookie permissions in Chrome, Safari, or Firefox settings), or by selecting your preferences in our Cookie Banner/Preference Centre; however, please note that disabling strictly necessary cookies may restrict your ability to utilize certain core functionalities or maintain a logged-in status on our website.

Third-Party Cookies: Our website utilizes ‘third-party cookies’ including Cookiebot , provided by Usercentrics A/S, which is a consent management platform that displays our Cookie Banner and records your consent choices. It processes only a consent ID, timestamp, your selected cookie categories, and an anonymized IP address — never your email, account, or payment data — and does not use this information for its own advertising or analytics. Cookiebot retains this consent record in its own consent log, as described in Cookiebot's privacy policy (www.cookiebot.com).

Third-Party Content and Social Icons: The ChainThink website may also, purely for user convenience, display technical links or provide integration entry points to independent third-party platforms (such as our official Telegram channel and X account buttons) which are operated and maintained entirely by external entities. In order to interact with these third-party contents or services, you must directly engage with those independent providers and may need to accept their specific terms and conditions, including their respective cookie policies, over which ChainThink exercises no operational control, bears no endorsement, and assumes no legal liability whatsoever.

Management and Control

• In the App: You may manage or restrict specific data collection activities and marketing identifiers via the Privacy Settings menu within the App, or by adjusting your native device settings (e.g., toggling off personalized tracking, limit background activity), which may impact functionality.
• On the Website: You can manage your cookie preferences at any time directly on our website through our Cookie Settings/Banner. You can reopen your preferences at any time via the "Cookie Settings" link in the website footer. This allows you to freely choose which categories of non-essential cookies you wish to accept or decline. Alternatively, you may manage, block, or clear cookies via your browser's native preference settings.

Please note that disabling these technologies may affect the proper operation or smoothness of certain services.

We do not use data collected via cookies or similar technologies for any purposes other than those explicitly outlined in this policy.

5. Sharing, Transfer, and Disclosure of Personal Information

5.1 Information Sharing

We will not share your personal information with any third party except in the following circumstances:

• With your explicit authorization and consent;
• With our affiliates: only for specific, legitimate, necessary, and clearly defined purposes. If an affiliate wishes to change the purpose of processing, they will seek your authorized consent again;
• With partners: for services such as payments, logistics, and content distributions, where necessary information may be provided to service providers;
• Required by law or regulatory authorities: we may disclose necessary information as part of lawful proceedings, legal obligations, or official requests. Where necessary and permitted by applicable law, we may also disclose your information to protect our own business, rights, assets, safety, or services.

Where required by applicable data protection laws, we enter into appropriate contractual clauses with these third parties, requiring them to limit their data collection to the minimum extent necessary and prohibiting them from using your personal data beyond authorized purposes.

5.2 Information Transfer

We will not transfer your personal information to any company, organization, or individual, unless:

• We have obtained your explicit consent in advance;
• A merger, acquisition, or asset restructuring occurs that involves a change in responsibility for personal data. In such cases, we will require the relevant third parties or potential investors to maintain strict confidentiality and ensure that any successor holding your personal information continues to be bound by this Privacy Policy.

5.3 Public Disclosure

We will only publicly disclose your personal information under the following conditions and with appropriate protective measures in place:

• With your explicit consent;
• When disclosure is legally required (such as mandatory legal obligations or court orders).

6. Your Rights and Privacy Controls

We respect your right to control your personal information. Depending on your location and applicable data protection laws (such as the UK GDPR), you may exercise the following rights regarding your personal data:

• Access and Copy: You have the right to request a copy of the personal data we hold about you;
• Correction: You have the right to request that we rectify any inaccurate or incomplete personal data;
• Erasure ("Right to be Forgotten"): You have the right to request the deletion of your personal data under certain conditions;
• Restriction and Objection: You have the right to object to or request that we restrict the processing of your personal data (including managing or revoking device permissions such as notifications or identifiers through your device settings);
• Data Portability: You have the right to request the transfer of your data to another organization or directly to you in a structured, commonly used format.

To submit a request regarding your data privacy rights (including the rights to access, correct, delete, port, restrict, or object to the processing of your data), please contact us via our customer support or may contact our Data Protection Officer: contact@momentumgrowthagency.co.uk. To protect your privacy and security, we will take steps to verify your identity before fulfilling the request. We will respond to all legitimate requests within one (1) month of receipt.

Please note that if your request is manifestly unfounded or excessive, or where permitted by applicable law (e.g., if the deletion of data would conflict with our mandatory statutory obligations, ongoing legal defense, or interfere with the rights and freedoms of others), we may refuse or limit our response, or charge a reasonable fee based on administrative costs.

You also have the right to lodge a formal complaint with a supervisory authority. If you are based in the UK, this is the Information Commissioner’s Office (ICO) (Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, www.ico.org.uk). If you reside in the EEA, you may complain to your local Member State data protection authority. In accordance with UK GDPR, you also retain the right to seek a judicial remedy through the courts if you believe your privacy rights have been infringed as a result of non-compliant processing of your personal data.

7. Information Storage and Security Measures

7.1 Storage Location and Retention Period

The personal information we collect is primarily stored and processed on secure servers located within the United Kingdom (UK). If we transfer this data outside the UK or EEA, we ensure that we implement appropriate safeguards, such as Standard Contractual Clauses (SCCs) or other legally recognized transfer mechanisms, to maintain an equivalent level of data protection.

We retain your personal information only for the period necessary to fulfill the purposes outlined in this Privacy Policy, or as required by applicable legal, regulatory, tax, or accounting obligations. Once the retention period expires or upon a valid deletion request, your information will be securely deleted or permanently anonymized so that it can no longer be associated with you.

7.2 Security Safeguards

We implement appropriate technical and organizational measures (TOMs) to safeguard your personal information against unauthorized access, accidental loss, alteration, or disclosure. These measures include, but are not limited to:

• Encryption: Use of industry-standard HTTPS/TLS encryption for data in transit, and robust encryption protocols for data at rest and backups;
• Access Control: Implementation of strict access control policies based on the principle of least privilege, ensuring only authorized employees and contractors under confidentiality obligations can access your data;
• System Hardening: Continuous security audits, routine vulnerability scanning, and timely system patching to mitigate cybersecurity risks.

In the event of a personal data breach, we will initiate our emergency response plan and, where legally required, notify the relevant supervisory authority (such as the UK Information Commissioner's Office) and affected individuals within seventy-two (72) hours of becoming aware of the breach, outlining the nature of the breach and mitigation steps.

8. Integration and Use of Third-Party Services

To enable specific functionalities and improve service quality, ChainThink's App and website may integrate third-party software development kits (SDKs), plug-ins, or link-based services. These third-party services may, as necessary, collect certain device or behavioral information to ensure stable core functions or provide personalized services.

We will only integrate reviewed and approved third-party services and evaluate their legal compliance. Common third parties may include, but are not limited to:

• Third-party login providers (e.g., Google account);
• Data analytics and statistics service providers;
• Payment service gateways (which processes payment and billing data in accordance with its own privacy policy and applicable data protection laws);
• Consent management platform providers (namely Cookiebot, provided by Usercentrics A/S), used solely to display our Cookie Banner and record your cookie consent choices, as described in Section 4 above;
• Content distribution and push notification platforms.

Where required by applicable data protection laws, we enter into Data Processing Agreements (DPAs) or appropriate contractual clauses with these third parties, requiring them to limit their data collection to the minimum extent necessary and prohibiting them from using your personal data beyond authorized purposes.

9. Protection of Minors' Personal Information

The Services, including but not limited to our financial indicators, on-chain telemetry, and cryptocurrency media services, are not designed, directed, or targeted towards individuals under the age of 18, and such individuals are strictly prohibited from utilizing the Services, registering an account, or submitting any personal data to us. By accessing, registering, or using the Services, you represent and warrant that you are at least 18 years old and possess the full legal capacity to enter into this Agreement.

If we become aware that we have inadvertently collected personal information from a child under the legal age of digital consent without verifiable parental confirmation, we will take immediate steps to delete such data and limit or terminate the associated account as required by law. Parents or legal guardians who believe that we have collected their child's data may contact us directly to request access, restriction, or erasure of such information.

10. Changes to This Policy and Scope of Application

This Privacy Policy applies to all products and services provided by ChainThink, including our App, official website, and associated digital services. This policy should be read in conjunction with the ChainThink User Agreement.

We reserve the right to update or revise this Privacy Policy from time to time to reflect changes in our business operations, technical updates, or applicable legal and regulatory requirements. When we make changes, we will update the ‘Last Updated’ date at the top of this document.

For any material changes that significantly affect your rights or how we process your personal data, we will provide you with prominent notice as appropriate under the circumstances (such as via an in-app pop-up, a prominent announcement on our website, or a direct email notification). Your continued use of ChainThink services after such notifications will constitute your acknowledgment of the updated Privacy Policy. If you do not agree with the revised content, you should discontinue using our services.

Specific services or optional premium features (such as paid membership subscriptions) may be subject to supplementary privacy notices. In the event of any direct conflict between a supplementary notice and this Privacy Policy, the specific supplementary notice shall prevail for that specific service.

11. Contact Us

If you have any questions, suggestions, comments, or wish to exercise your data protection rights regarding this Privacy Policy, please contact us through our dedicated privacy channels below. We aim to acknowledge all privacy-related inquiries promptly and will provide a substantive response within one (1) month of receipt:

• Email: contact@momentumgrowthagency.co.uk
• Telegram Support: https://t.me/Chainthink
• Company Name: Momentum Growth Agency LTD (trading as “ChainThink”), a company registered in England and Wales
• Address: Unit 1e Bromsgrove House, 88 Bromsgrove Street, Birmingham, Uk, United Kingdom, B5 6AJ
• Company Number: 16929107
• ICO Registration Number: ZC171801

We encourage you to contact us first, and we will make every effort to address and resolve your concerns as soon as possible.

Thank you for taking the time to read our Privacy Policy!