Privacy Policy

This policy explains what information Scrutin ("we," "us," "our") collects when you visit this site, create an account or scan a wallet, why we collect it, and the choices you have. It applies to scrutinn.com and any related services we launch under the Scrutin name. Scrutin is based in Singapore, and this policy is written to comply with the Personal Data Protection Act 2012 ("PDPA") and its subsidiary regulations.

1. Consent

By creating an account or otherwise providing us personal data, you consent to its collection, use, and disclosure as described in this policy, in accordance with the PDPA. You may withdraw your consent at any time by contacting us below — we'll let you know if withdrawing affects any service we can provide you.

2. Information we collect

We collect information in three ways:

• Information you give us. When you create an account, we collect your email address, an optional name, and your password, which we store only as a salted one-way hash. We record your plan, and the access code if a plan came from one. Payments are handled by Stripe: your card details go to Stripe, never to us, and we keep only your Stripe customer and subscription IDs and your plan's status. If you contact us directly, we collect whatever you include in that message.
• Things you write or set in the app. Journal notes and the moods and ratings you attach to trades, your conversations with the consultant, the trading rules you save, the challenges you start, and the names you give your wallets. These are stored with your account and used only to show them back to you and to run the features they belong to (for example, the tilt check reads your saved rules, and the consultant reads the report you ask about).
• Wallet addresses you submit. Submitting a public Solana wallet address means we retrieve that address's publicly available on-chain transaction history to generate your report, and we keep the report, and a cache of the transactions we read, so later scans are faster. We never request, and have no use for, private keys or seed phrases.
• Information collected automatically. Like most websites, our hosting and analytics tools may log basic technical details — IP address, browser type, device type, and pages visited — to keep the site working and understand aggregate usage.

3. How we use it

We use the information above to:

• Run your account, keep you signed in, and apply your plan.
• Operate, maintain, and improve the site and product.
• Generate the trade analysis and reports the product provides.
• Respond to questions you send us.
• Detect, investigate, and prevent misuse, fraud, or security incidents.
• Meet legal obligations we're subject to.

We don't sell your personal data, and we don't use the wallet data you submit for anything other than generating your own report. We may also use and disclose fully anonymized or aggregated data — which no longer identifies you — for any lawful business purpose, without restriction, since it is no longer personal data under the PDPA.

4. How we share it

We share information only with the service providers who help us run Scrutin — for example, email delivery, hosting, and analytics providers — engaged as our data intermediaries under the PDPA, bound by contract to protect your data to a standard comparable to our own obligations and to use it only to provide services to us. To read a wallet, the address is sent to Solana RPC providers (the public Solana RPC, PublicNode, or an RPC provider such as Helius if we configure one). To price trades, the token addresses involved, not your wallet, are sent to Jupiter and GeckoTerminal. If the AI consultant is enabled, the questions you ask it and a summary of the report you're viewing are sent to Anthropic to generate answers. We may also disclose information if required by law, to protect our legal rights, to enforce our Terms of Service, or in connection with a merger, acquisition, or sale of assets, in which case we'll let affected users know.

5. Cookies and similar technologies

This site may use cookies or local browser storage to remember basic preferences and to understand, in aggregate, how the site is used. These are not used to build advertising profiles. When you log in we set one strictly necessary cookie that keeps you signed in; it holds a random session token and nothing else. The interactive demos on the homepage keep their state only while the page is open. Most browsers let you block or delete cookies in their settings; blocking the session cookie means you can't stay logged in.

6. Data retention

Consistent with the PDPA's retention limitation obligation, we keep personal data only for as long as it's reasonably necessary for the purposes we collected it for. You can delete any report, any journal note, or your whole account (which removes your reports, journal, consultant conversations, rules and challenges with it) yourself, from Settings and the pages those items live on, at any time. Otherwise we retain account and wallet data for as long as your account is active and for a reasonable period afterward to meet legal, accounting, or dispute-resolution needs, after which it's deleted or anonymized.

7. Data security

We use reasonable technical and organizational measures to protect the information we hold. No method of transmission or storage is completely secure, and we can't guarantee absolute security. To the fullest extent permitted by law, we disclaim liability for unauthorized access, use, or disclosure of your information that occurs despite these reasonable measures and is outside our control, including as a result of a service provider's failure, a third-party attack, or your own failure to keep account credentials secure.

8. Your rights under the PDPA

Subject to the PDPA, you have the right to:

• Access the personal data we hold about you.
• Ask us to correct any inaccurate or incomplete personal data.
• Withdraw your consent to our collection, use, or disclosure of your data.
• Ask us to delete personal data we no longer have a legal basis to keep.

You can delete your reports or your account from Settings at any time, and exercise any of these rights by contacting our Data Protection Officer below — we'll respond within a reasonable time. If you're not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission (PDPC) of Singapore.

9. Overseas transfer of data

Some of our service providers (for example, cloud hosting or email delivery) may store or process data outside Singapore. Our hosting, RPC, market-data and AI providers may process data in the United States and other countries where they operate. Where we transfer personal data overseas, we take steps required under the PDPA to ensure it receives a standard of protection comparable to that under the PDPA, including through contractual obligations with those providers.

10. Children's privacy

Scrutin is intended for adults aged 18 and over, not children. We don't knowingly collect personal information from anyone under 18. If you believe a child has provided us information, contact us and we'll delete it.

11. Changes to this policy

We may update this policy as the product evolves. If we make material changes, we'll update the date at the top of this page and, where appropriate, notify you directly. Continued use of the site after a change means you accept the updated policy.

12. Data Protection Officer & contact us

Questions about this policy, or want to exercise any of the rights above? You can reach our Data Protection Officer at scrutinn@gmail.com.