Trium Labs, Inc.

Privacy Policy

Last Updated: September 18, 2026

This Privacy Policy describes how Trium Labs, Inc. (“The Syndicate,” “we,” “our,” or “us”) may collect, use, and disclose personal information about you. This Privacy Policy applies to information collected when you interact with the services we offer, including our website located at https://thesyndicate.games, our Telegram bot (currently @syndicategamebot), the blockchain-based game commonly known as The Syndicate, and all related services, applications, software, products, and features offered by us from time to time (collectively, the “Services”).

Please read this Privacy Policy carefully so that you understand our policies and practices regarding your information. If you do not agree with our policies and practices, then 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 often so you stay informed about our practices and the choices available to you.

Information We Collect

Depending on how you interact with the Services, we may collect information about you, including the following categories:

• Information You Provide. Information you provide when you create a Player Account, communicate with us, post in our community channels, or otherwise interact with the Services. This may include your display name, profile bio, contents of in-game text chat messages, and other content or information you submit through the Services.
• Information from Identity Providers. When you sign in to the Services using a supported third-party identity provider (currently including Google and Apple), the identity provider transmits to us your email address, the provider’s unique user identifier, your display name, and, where the provider supplies them, your first and/or last name and profile picture URL. When you sign in through our Telegram bot via a magic link or one-time code, we receive the identifier and contact information associated with that flow.
• Commercial Information. Records of in-game purchases, amounts, currencies, timestamps, and order history tied to your Player Account.
• Internet and Electronic Network Activity. Gameplay events, in-game actions, session activity, page views, feature usage, click patterns, and similar interaction data we collect through first-party logging and through our analytics providers.
• Device and Log Data. Device type, software and hardware details, browser type and version, operating system, IP address, language preference, unique device identifiers, and similar technical information automatically collected when you access the Services.
• Communication Information. Information about communications you submit to us, including support requests sent by email or through our linked Discord server or Telegram channels, and the contents of those communications.
• Blockchain Data. Publicly available blockchain data associated with the Digital Asset Wallet provisioned for you (or, where applicable, that you have linked to your Player Account), including wallet address, balance, transaction history, transaction amounts, and transaction identifiers. This information is public and resides on the Solana blockchain.
• Information Collected Through Tracking Technologies. Information collected through cookies, local storage, web beacons, pixels, and similar technologies. See the Cookies and Similar Technologies section below.
• Other Information. Any other information that you choose to provide or that we request, including in connection with promotions, prize-pool competitions, or skill-based leagues we may from time to time make available.

We may aggregate or de-identify information so that it can no longer reasonably identify you, as defined under applicable laws. We may use and/or disclose aggregated or de-identified information for any purpose unless an applicable law says otherwise.

We do not knowingly collect biometric identifiers (such as fingerprints, faceprints, voiceprints, or iris scans), genetic information, government-issued identification numbers, social security numbers, or other categories of “sensitive” personal information from users of the Services. We also do not collect precise geolocation data. Coarse country or region may be inferred from your IP address by our analytics providers.

How We Use Your Information

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

• Operate and Provide the Services. Authenticate you, create and maintain your Player Account, provision and operate your embedded Digital Asset Wallet (through Privy), persist your gameplay state and progress, power in-game chat, social features, and player profiles, process purchases, and provide customer support and respond to your inquiries.
• Monitor and Improve the Services. Analyze the effectiveness of the Services, review usage of the Services, conduct A/B tests, fix bugs, and improve and develop new features and products.
• Conduct Research. Conduct research, product testing, and troubleshooting to help us operate and improve the Services.
• Communicate with You. Communicate with you about the Services, including sending transactional messages (such as technical notices, security alerts, and support responses), and, where you have opted in, sending marketing emails, newsletters, and product updates about new features, content, and related products.
• Foster Safety and Security. Provide for the safety and security of our users and the Services, including detecting, preventing, investigating, and responding to fraud, cheating, abuse, account compromise, Terms of Service violations, and other unlawful or unauthorized activity; moderate user-generated content (including in-game text chat messages and community posts) for compliance with our Terms of Service; secure accounts and player data; and maintain the integrity and availability of the Services.
• Comply with Legal Obligations. Comply with applicable legal, tax, accounting, anti-money laundering, anti-fraud, sanctions, and other regulatory obligations; respond to lawful requests from government authorities; and enforce our Terms of Service and other agreements.
• Facilitate a Corporate Transaction. Use information during negotiations or in connection with the sale of part or all of our assets, the acquisition of part or all of another business or its assets, a financing or bankruptcy, or any similar corporate transaction.

Sharing Information

You should know the ways that we share your information and why we share your information. In connection with our Everyday Business Activities, we may share information collected from or about you in the circumstances described below.

• Service Providers. We may share your information with service providers that perform functions or provide services on our behalf, including, but not limited to: Amazon Web Services (hosting, storage, database, backups); Privy (embedded wallet provisioning and key management); Google (OAuth identity and Google Analytics); Apple (OAuth identity); Stripe (payment processing); PostHog (product analytics); Discord and Telegram (community and messaging platforms); and our email-delivery service provider (transactional and opted-in marketing email). Each is engaged solely to provide services to us under written agreements that require appropriate confidentiality and data-protection commitments.
• 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, including authorities outside your country of residence; 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 the damages that we may sustain.
• Investors and Acquirers. We may transfer your information to advisors, investors, potential transactional partners, or other third parties in connection with the initial actions or engagement of a merger, acquisition, sale of some or all of our stock or assets, change in control, financing, bankruptcy, or similar transaction.
• Other Users and the Public. Certain information you provide, such as your display name, profile bio, profile picture, in-game activity visible to other players, leaderboard standing, and contents of public chat, may be visible to other users of the Services. On-chain transactions and Digital Assets associated with your Digital Asset Wallet are public on the Solana blockchain.
• With Other Third Parties. There are situations when we may disclose your information to third parties beyond our service providers. While we try to control the behavior of vendors that we understand to be service providers, some of those vendors 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 of your information.

The Syndicate does not sell your personal information. We do not exchange personal information for monetary or other valuable consideration. However, with your consent, we may share personal information with Meta and X through their advertising pixels as described in the Analytics section, which may constitute cross-context behavioral advertising or targeted advertising under applicable law.

Cookies and Similar Technologies

Like most other online services, we use cookies and similar technologies to collect some of the data described in this Privacy Policy. These technologies help us provide certain features to you and analyze usage information. The Your Choices section below provides additional information about our use of cookies and similar technologies and your ability to manage cookies.

Our use of cookies and similar technologies falls into the following general categories:

• Essential. We may use cookies, local storage, or other similar technologies that are necessary to provide the Services. This includes technologies that allow you to access the Services, maintain your authenticated session, identify irregular site behavior, and improve security.
• Performance. We may use cookies, web beacons, or other similar technologies to assess the performance of the Services, including as part of our analytics practices to help us understand how visitors use the Services, whether you have interacted with our messaging, whether you have viewed an item or link, and to improve our content, applications, or services.
• Functionality. We may use cookies, local storage, or other similar technologies that allow us to offer enhanced functionality when you access or use the Services, including delivering error messages, persisting gameplay/UI preferences, and enhancing the presentation of content on the Services.

Analytics

We may engage others to provide analytics services that help us understand how the Services are used and how to improve them. These entities may use cookies and similar technologies to collect information about your use of the Services, which they may associate with persistent identifiers. The analytics providers we currently use include the following:

• Google Analytics. Google Analytics is provided by Google LLC. Google Analytics uses cookies, JavaScript tags, and similar technologies to collect information about how visitors use the Services. You can learn more about Google Analytics at https://www.google.com/policies/privacy/partners/. You can opt out of Google Analytics by installing Google’s opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• PostHog. PostHog is a product-analytics service provided by PostHog, Inc. We use PostHog to track product events, feature engagement, and aggregate usage patterns. You can learn more about PostHog’s practices at https://posthog.com/privacy.
• Stripe. When you make a fiat-currency purchase through the Services, Stripe.js is loaded on the payment page for secure payment processing. Stripe may collect information about your device and transaction in connection with the payment. See Stripe’s Privacy Policy at https://stripe.com/privacy.
• Meta Pixel. With your consent, we use the Meta Pixel, provided by Meta Platforms, Inc. and Meta Platforms Ireland Limited, to measure and attribute advertising, create audiences, optimize campaigns, and support personalized advertising. Meta may use cookies and similar technologies to collect or receive information about your device and browser, IP address, pages visited and referring URLs, Meta cookie or click identifiers, and actions taken through the Services, such as registration, checkout, and purchase. You may withdraw your consent at any time through our Cookie Settings. You can learn more about Meta’s practices at https://www.facebook.com/privacy/policy/.
• X Pixel. With your marketing consent, we use the X Pixel to measure website visits and completed registrations, attribute advertising results, and build advertising audiences. X may receive information about your device and browser, IP address, pages visited, cookie or click identifiers, and a registration reference used to avoid counting the same registration twice. You may withdraw your consent at any time through our Cookie Settings. Learn more in the X Privacy Policy and manage personalized advertising through X’s advertising privacy controls.

Except for our consent-based use of the Meta and X pixels described above, we do not currently engage in cross-context behavioral advertising or targeted advertising or share personal information with advertising networks for those purposes.

Your Choices

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

• Opt out of Marketing Communications. You may opt out of receiving marketing communications from us by following the unsubscribe instructions in those communications or by submitting a request to help@thesyndicate.games. If you opt out, we may still send you non-promotional communications, such as transactional messages about your Player Account, purchases, security, or our ongoing business relationship.
• 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 using browsers with privacy features or installing browser plug-ins that block third-party cookies or trackers.
• Do Not Track. Please note that while we provide tools to manage your privacy as described in this Privacy Policy, we do not currently respond to “Do Not Track” browser signals.
• Access, Correction, Deletion, and Other Rights. You may request that we provide you with a copy of the personal information we hold about you, correct inaccurate personal information, delete your personal information, or restrict or object to certain processing of your personal information. You may exercise these rights, where available under applicable law, by emailing help@thesyndicate.games. We may ask you to provide information necessary to reasonably verify your identity before responding. We respond to verifiable consumer rights requests within the timeframes required by applicable law.
• Withdraw Consent. Where our processing of your personal information is based on your consent, you may withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of processing carried out before the withdrawal.
• Mobile Notifications. With your consent, we may send promotional and non-promotional push notifications or messages to your device. You can deactivate these messages at any time by changing the notification settings on your device.

You may also delete your Player Account at any time by emailing help@thesyndicate.games or, where available, through in-product account-deletion controls. Upon a valid deletion request, we will delete or de-identify your personal information from our production systems within thirty (30) days, except where a longer retention period is required by applicable law (for example, for tax, accounting, audit, anti-fraud, or legal-hold obligations) or is necessary to resolve disputes or enforce our agreements. Personal information stored in encrypted backups is retained on a rolling basis and overwritten in the ordinary course (typically within thirty (30) days). Information that has been aggregated or de-identified such that it no longer reasonably identifies you may be retained indefinitely. Personal information stored on a public blockchain network (such as Solana), including transaction data associated with your Digital Asset Wallet, cannot be deleted by us due to the immutable nature of blockchain technology.

Data Protection Rights

Where required by applicable law and depending on your jurisdiction, you may have access to certain rights. For example, 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 (without affecting the lawfulness of processing based on consent before its withdrawal).

If you are unable to exercise your rights using the mechanisms in the Your Choices section above, you may email us at help@thesyndicate.games. We may ask you to provide us with information, such as your name and email address, necessary to reasonably verify your identity before responding to your request. If we can’t verify your identity, we will not be able to fulfill your request.

Special Disclosures for European Users

Under the European General Data Protection Act, every European user is entitled to the following:

• The right to access – You have the right to request copies of your personal data from us. We may charge you a small fee for this service.
• The right to rectification – You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete any information you believe is incomplete.
• The right to erasure – You have the right to request that we erase your personal data, under certain conditions.
• The right to restrict processing – You have the right to request that we restrict the processing of your personal data, under certain conditions.
• The right to object to processing – You have the right to object to our processing of your personal data, under certain conditions.
• The right to data portability – You have the right to request we transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us help@thesyndicate.games.

We are active across the world. This means that we may transfer your personal data abroad if required to do so for the business and commercial purposes described in the Section above entitled “How We Use Your Information.” In certain cases, this may include transferring data to countries which do not offer the same level of protection as the laws of your country (such as for example the data protection legislation of the EU/EEA).

When making such transfers, we will ensure that they are subject to appropriate safeguards in accordance with the General Data Protection Regulation (Regulation 2016/679) or other relevant data protection legislation.

Additional Notice to California Residents (“CCPA Notice”)

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act, as amended (“CCPA”).

For more details about the personal information we collect from you and the types of third-party cookies, if any, that we use, please see the Section above entitled “Information We Collect.” We collect this information for the business and commercial purposes described in the Section above entitled “How We Use Your Information.” We share this information with the categories of third parties described in the Section above entitled “Sharing Information.” We do not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of the “sale or sharing” of their personal information, and to not be discriminated against for exercising these rights. You may opt out of the sale or sharing of your personal information through our Cookie Settings.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at help@thesyndicate.games. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

International Transfers

Your personal information may be transferred to, processed, and/or stored in countries other than the country in which you are a resident. Our primary production systems and those of our principal service providers are operated in the United States. If we transfer your personal information out of the European Economic Area (the EEA), the United Kingdom, or Switzerland, we implement at least one of the following safeguards:

• we transfer your information to countries that have been recognized as providing an adequate level of data protection;
• 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, the UK Extension to the EU-U.S. Data Privacy Framework, and/or the Swiss-U.S. Data Privacy Framework, as applicable; and/or
• we take steps to ensure that the recipient is bound by contractual obligations, including the EU Standard Contractual Clauses together with addenda or language to cover the United Kingdom and/or Switzerland, as applicable, and additional safeguards to protect your personal information.

What is Our Legal Basis?

In some jurisdictions, including the European Union, the EEA, and the United Kingdom, we only collect, use, or share information about you when we have a valid reason. This is called a “lawful basis.” Specifically, our lawful bases are one or more 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, including our Terms of Service;
• our compliance with a legal obligation to which we are subject; or
• the legitimate interests of The Syndicate or a third party.

The term 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. The term also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.

We have a legitimate interest in gathering and processing personal information, for example to: (a) ensure that our networks, the Services, and our information are secure; (b) administer and generally conduct business within The Syndicate; (c) detect, prevent, and respond to fraud, cheating, abuse, and other Terms of Service violations; and (d) conduct our marketing and product-improvement activities.

Privacy and Blockchains

A key feature of many blockchain technologies, including the Solana blockchain network on which the Services rely, is the transparency and public accessibility of on-chain transactions. This includes, but is in no way limited to, your public sending address (public key) and any other information that you choose to include in an on-chain transaction. Additionally, information stored on-chain is public, immutable, and not easily removed or deleted and, in many cases, cannot be deleted. Your public keys may reveal information about you, and this information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. If you are unfamiliar with blockchain technology and its transparent and public nature, we strongly encourage you to conduct your own research into blockchain before electing to use the Services.

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 or 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 private cryptographic key with anyone. We may provide you with additional security features like multifactor authentication, and we strongly recommend that you utilize these features.

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. The retention periods for your information are determined on a case-by-case basis depending on the nature of the information, the purposes for which it was collected, and the applicable legal reasons for its retention. We may also keep certain information when necessary to protect the safety and security of the Services. Rather than delete your data, we may de-identify it by removing identifying information.

We retain player personal information for as long as your Player Account is active. You may request deletion of your personal information at any time as described in the Your Choices section above. Encrypted backups containing personal information are retained on a rolling basis (typically thirty (30) days) before being overwritten and permanently destroyed in the ordinary course. Aggregated, de-identified analytics events that no longer reasonably permit re-identification may be retained indefinitely. Personal information stored on a public blockchain network cannot be deleted by us.

Age Restrictions

The Services are not intended for anyone under the age of 18. We do not knowingly collect or solicit personal information from individuals under 18 (and, for jurisdictions where the age threshold is lower, we do not knowingly collect personal information from anyone under 16). In the event that we encounter information from an individual under the applicable age threshold, we will promptly take steps to delete such information. If you believe a child under 18 has uploaded information in connection with the Services, please contact us using the information in the Contact Us section below.

Changes to this Privacy Policy

We are always improving the 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 any 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.

Third Party Links and Features

The Services may contain links, banners, and/or widgets to third-party sites, applications, or services, including the Solana blockchain, the wallet service provided by Privy, third-party Solana marketplaces (such as those powered by Tensor Foundation), our linked Discord and Telegram community channels, and third-party fiat-to-crypto on-ramps you may independently choose to use. 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 by us of the information provided through these third-party links and features, nor any association with their operators. We are 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 by this Privacy Policy. We urge you to read the privacy and security policies of these third parties.

Contact Us

If you have any questions about this Privacy Policy or our privacy practices, please email us at Help@thesyndicate.games.