Privacy Policy

Effective Date: April 19, 2024

Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website at (the “Site”) and the functionality available through our Site, including any Functionality (as defined in Bullpen’s Terms of Service), and how we use and disclose that information.

By visiting the Site, or using any of the Functionality, you agree that your user data (including your personal data and personally identifiable information (“personal information”) will be handled as described in this Policy. Your use of the Site or the Functionality, and any dispute over privacy, is subject to this Policy (including any applicable changes) and an applicable Terms of Use, including its applicable limitations on damages and provisions for the resolution of disputes.


  • Privacy is core to Bullpen’s mission and values. We take all appropriate steps to preserve user privacy and aim to be as transparent as possible with you regarding the treatment of any data we collect or that you provide to us (including your personal information).
  • Bullpen does not require you to provide personally identifiable information or your personal data such as your name, email address, tax ID or phone number to use the Site or the Functionality.
  • Bullpen does not collect and store your IP address when you use the Site or the Functionality.
  • For even more privacy, users have the option to opt-out of our anonymous analytics.
  • This Policy will be updated whenever there are material changes to Bullpen’s privacy practices or applicable law.

How We Protect Your Privacy

First, please remember that Bullpen will never ask you for any password, bank account or credit card details. If you receive such communications asking you to provide such information, please ignore it and do not respond. You can let us know that you have received such communication via

Because we value your privacy, Bullpen uses industry standard measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of data which is stored in our records. These measures include internal reviews of our data collection, storage and processing practices and standard measures, sensitive information is transmitted via Secure Socket Layer (SSL) technology, making our systems accessible only by those authorized with special access rights to such systems, and are required to keep the information confidential.  

Nonetheless, we cannot guarantee perfect and absolute security of your personal information, as no method of transmission over the Internet and/or electronic storage is perfectly secure or invulnerable. However, should we become aware of a security breach, we will notify any affected user, so that they can take appropriate protective steps. Such notifications shall be issued by Bullpen in accordance with the applicable (local) laws and regulations, as well as Bullpen’s internal policies

The Information We Collect

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Functionality.

Information We Collect Directly From You. You may browse the Site without registering with us or providing personal information, however certain information is collected from you as described below and for the purposes set out below.

   • Publicly available data such as your digital asset wallet address and public blockchain data, which is only used to provide and improve the Functionality and to ensure compliance with applicable laws and regulations.

   • Your contact information as well as other data and information related to your use of the Site and Functionality (to the extent that you provide it to us) in connection with survey responses or customer support queries.

   • While not required to access the Site or Functionality, you may choose to provide us with your email address or Telegram handle in order to participate in certain promotional activities or in order to receive additional information related to upcoming product launches or developments.

   • Your Telegram Handle is required to deploy the Bullpen Bot, and this information is stored on our servers.

   • If you choose to utilize the email recovery method available via Turnkey, this recovery information is stored on Turnkey’s servers.

In addition, if you are providing personal information of third parties to us for specific purposes, you are responsible for ensuring that you have all required permissions and consents (including express consent from such third parties) to provide such personal information to us for such purposes and that our use of such personal information does not violate any applicable law, rule, regulation or order. If the third party withdraws their consent, you agree to notify us immediately.

Information We Collect Automatically

   • Usage data, such as your browser type and operating system, the web pages that you connect your wallet to, the webpage that led you to our Site and country-level location information;

   • Bullpen does not automatically collect or store personally identifying information such as your IP address.

For additional information related to Bullpen’s use of cookies and other tracking technology please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information.

How We Use The Information We Collect

We use the information we collect for the following purposes:

   • Provide our services

We use your information to communicate with you about your use of our Site and the Functionality and to respond to your inquiries, to fulfill your orders, and for other customer support purposes.

   • Provide personalized services

We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site and the Functionality.

   • Improve and develop our services

We use your information to ensure our Site and Services are working as intended, to better understand how users access and use our Site and the Functionality, both on an aggregated and individualized basis, to make improvements, to develop new functionality, and for other research and analytical purposes. Bullpen does not use your IP address for research or analytics purposes.

   • Offer promotions

We may use your information for marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, to conduct contests and sweepstakes, or to otherwise contact you about products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising Bullpen's products on third party websites.

   • Other Uses

We may use your information to enforce any applicable Terms of Use, comply with the law, legal process or legal or regulatory obligations, exercise or defend legal claims, detect, prevent or address fraud, comply with law enforcement, regulatory and tax authority related requests (whether from the United States or from overseas), security or technical issues, or otherwise protect our property, legal rights, or that of others.

How We Share The Information We Collect

We may share the information we collect as follows:

   • Consent. Where you have provided consent, we may share your information, as described at the time of consent.

   • Affiliates & Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.

   • Business Transfers. If we are acquired by or merged with another company, if some or all of our assets are transferred to another company, or as part of a bankruptcy proceeding, or if we are in negotiations for any of these types of transactions, we may transfer the information we have collected from you to counterparties in connection with such transactions.

   • In Response to Legal Process.

   • To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of any applicable Terms of Use or this Policy, or as evidence in litigation or regulatory investigations in which we are involved in any capacity.

   • Aggregate and De-Identified Information. We may share aggregate or de-identified information about users and their use of the Site and Functionality with third parties and publicly for marketing, advertising, research or similar purposes.

   • Please note that except as noted above, we will not sell or share your personal information with any third party for their direct marketing purposes without your consent.

   • Our Use of Cookies and Other Tracking Mechanisms

   • We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site and Functionality. We may combine this information with other information we collect from you (and our third party service providers may do so on our behalf).

   • Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies), but such disabling will impair use of the Site and Functionality.


Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and avail of the Functionality, while others are used to enable a faster log-in process or to allow us to track your activities. There are two types of cookies: session and persistent cookies.

Session Cookies

Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.

Disabling Cookies

Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will not be able to browse certain areas of the Site or use the Functionality.

Third Party Analytics

We use automated devices and applications, such as Google Analytics, to evaluate usage of our Site and the Functionality. We also may use other analytic means to evaluate the Functionality. We use these tools to help us improve the Functionality, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

Third-Party Links

Our Site and the Functionality may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

Personal Information

Security of My Personal Information

We have implemented commercially reasonable precautions to protect the information (including your personal information) we collect from loss, misuse, or unauthorized access, disclosure, alteration, or destruction. Please be aware that despite our efforts, no data security measures can guarantee 100% security.

You should take steps to protect against unauthorized access to your password, and your devices (such as your phone, and computer). We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

What Rights Do I Have Regarding My Personal Information

You may request access, a copy, modification or deletion of personal information that you have submitted to us by contacting us at We will use reasonable efforts to accommodate such requests to the extent required by law, provided that we may be required to retain personal information to comply with legal obligations, accounting requirements, or for other business purposes. We may request additional information to verify the identity of the requesting party before responding to a request. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

What Choices Do I Have Regarding Use of My Personal Informationfor Marketing?

We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving marketing emails about recommendations or other information we think may interest you, we may still send you non-marketing related e-mails.

Location of Information

Our Site and the Functionality are offered from the United States. We store any information we collect in the United States. If you access the Services or Site from outside the United States, you agree to the transfer of your information to the United States, which may provide fewer protections for your personal information than your jurisdiction of residence.

Children Under 13

Our Site and the Functionality are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

Contact Us

If you have questions about our approach to privacy or would like to make a complaint, please contact us at

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time and will post any changes to this Policy on the Site. Your continued use of the Site and the Functionality after the posting of a modified Policy indicates your acceptance of these updated terms.


In addition, under California Civil Code §1798.83, California residents who have provided personal information to Bullpen Technologies, Inc. may obtain information regarding Bullpen Technologies, Inc.’s disclosures, if any, of personal information to third parties for third-party direct marketing purposes. Requests must be submitted to the following address: Within 30 days of receiving such a request, we will provide a California Privacy Disclosure, which will include a list of certain categories of personal information disclosed during the preceding calendar year to third parties for their direct marketing purposes, along with the names and addresses of the third parties. This request may be made no more than once per calendar year.