Privacy Policy
1. About this policy
This Privacy Policy explains how Sharpe GG (“we”, “us” or “our”) collects, uses, discloses and protects personal information in connection with the website at sharpe.gg and the services provided through it (together, “Sharpe”).
In this policy, “personal information” means information or an opinion about an identified individual, or an individual who is reasonably identifiable. It includes “personal data” as that term is used in the European Union and United Kingdom General Data Protection Regulations (the “GDPR”).
We are responsible for the personal information described in this policy and, where the GDPR applies, we are its controller. This policy applies to members and to visitors who use Sharpe without an account.
2. Personal information we collect
The personal information we collect depends on how you use Sharpe. It may include:
- Account information: your email address, your username, the method you use to sign in and the date you accepted our Terms of Service and this policy. Passwords are stored by our authentication provider in hashed form. If you sign in with Google, we receive your Google account’s email address, name and profile picture. If you sign in with a wallet or a passkey, we receive the wallet address or the passkey’s public key. If you enable two-factor authentication, we store the information needed to verify your codes.
- Profile information: information you choose to add to your profile, such as a profile picture, banner, biography, links and display preferences, and whether your profile is public or private.
- Trading information: if you connect an exchange account, the API key and secret you provide and the information they allow us to read, such as your trades, balances, deposits and withdrawals. If you connect a wallet, its address, the signature that proves you control it, and its public transaction history.
- Wallet lookups: when any person enters a public wallet address on Sharpe, we read that wallet’s public blockchain history and keep both what we read and the measurement we produce. To price tokens, we also keep the public trades in them that we read, which include the addresses of the wallets that made them. To prevent abuse, we also keep limited technical information about each lookup, in pseudonymised form.
- Device and usage information: information about the devices and sessions used to access your account, such as IP addresses and browser type, and technical logs of requests made to Sharpe.
- Payment information: if you subscribe to Sharpe Pro, Stripe sells it to you through its Link service and collects your payment details, billing address and email address for that purchase, under its own privacy policy. We receive information about your subscription, such as its status, plan and billing history, and your card's brand, last four digits and expiry date, but not your full card number.
- Communications: information you provide when you contact us, suggest a feature or report a profile. A feature suggestion is linked to your account if you are signed in when you send it.
We do not ask for government identifiers or sensitive information. Please do not include sensitive information, such as health information, in your profile.
3. How we collect personal information
We collect personal information:
- directly from you, for example when you create an account, complete your profile, connect an account, suggest a feature or contact us;
- from the exchanges you connect, using the read-only access you authorise;
- from public blockchains, for wallets that are connected to Sharpe or looked up on it;
- from sign-in providers you choose to use, such as Google; and
- automatically when you use Sharpe, through sign-in sessions, security checks and request logs.
Signing in with Google. If you choose to sign in with Google, Google shares your email address, name and profile picture with our authentication provider. We use your email address to create your account, sign you in and keep it secure; your Google name and picture are kept only as part of that sign-in record and are not shown on Sharpe. We do not use information from Google for advertising, we do not sell it, and we share it only with the service providers described in this policy. You can remove Sharpe’s access at any time in your Google Account settings.
4. How we use personal information
We use personal information for the following purposes. Where the GDPR applies, the legal basis for each purpose is given in brackets.
- To provide Sharpe: to create and manage your account, authenticate you, measure your trading, calculate your score and rank, and display your profile (performance of our contract with you).
- To publish rankings and profiles: to display public profiles, and to publish measurements of public wallets that have been looked up (performance of our contract with members; for wallets not connected to an account, our legitimate interest in providing an open record of public trading activity, balanced by the options described in “Information that is public”).
- To keep Sharpe secure: to detect and prevent bots, abuse, fraud and attempts to manipulate rankings, to enforce usage limits, and to keep security logs (our legitimate interest in operating a secure service).
- To moderate content: to review profile pictures, biographies and feature suggestions for prohibited content and to handle reports (our legitimate interests, and compliance with legal obligations).
- To communicate with you: to send sign-in codes, confirmations and important notices about your account or our policies (performance of our contract with you). We do not send marketing emails.
- To tell you about your results: to email you when your first score is ready and when you move up a tier, and to send a weekly summary if you choose to receive one. You may turn off any of these emails in your account settings or from the email itself (our legitimate interest in keeping members informed of their results and, for the weekly summary, your consent).
- To process payments and keep records: to provide Sharpe Pro and to keep financial records (performance of our contract with you, and compliance with legal obligations).
- To maintain and improve Sharpe: to diagnose faults, including through an error-monitoring service that receives technical details of a fault, such as the page, the browser and the error, with identifying details removed, and to understand how Sharpe performs and how people find and use it, using our own records rather than third-party analytics (our legitimate interest in improving our services). These records include anonymous daily counts of visits and of the main steps people take, and where visits came from. No cookie is set for them and nothing in them identifies you. To prevent abuse, we briefly keep limited technical information about the requests that add to them, in pseudonymised form.
We do not sell or rent personal information, and we do not use it for advertising.
5. Information that is public
Profiles. Member profiles are public by default. A public profile displays your username, profile picture, banner, biography, links, score, rank and the trading record that Sharpe measures, and appears on the Members board. You may make your profile private at any time in your account settings. A private profile is not shown to other people and is not included on the Members board.
Wallets. Blockchain records are public. Any person may enter a public wallet address on Sharpe, and a wallet that has been looked up may appear on the Wallets board, identified by its address, together with its measurement. If you control a wallet and want it removed from the Wallets board, you may connect it to a Sharpe account to prove that you control it. Until the Members board opens, a connected wallet stays on the Wallets board unless your profile is private; once it opens, a connected wallet is removed from the Wallets board and shown on your profile instead. If your profile is private, it is shown on neither board. If you later remove the wallet from your account, or delete your account, it is treated as any other public wallet and may appear on the Wallets board again once it is looked up.
Information that you make public may be viewed, copied or shared by others, and public profiles may be indexed by search engines.
6. Automated decisions
Your score, tier and position on the boards are calculated automatically by our software, using your trading data and market prices. They compare the performance of your trading with holding Bitcoin over the same period. Our methodology is published on Sharpe.
To protect the rankings, a result at the top of the ladder, and a wallet at the top of the P&L board, are also checked automatically for signs of trading with yourself, using the trades and transfers of the account or wallet and the market activity around them. While a result shows these signs, it is not ranked above Diamond, and a wallet is left off the P&L board. You may ask for either to be reviewed by a person.
These results are measurements and do not produce legal effects for you. If you believe a result is incorrect, you may ask for it to be reviewed by a person by contacting support@sharpe.gg.
7. Disclosure of personal information
We disclose personal information to service providers that help us operate Sharpe, and only to the extent needed for the services they provide to us. These include providers of:
- cloud hosting, database and file storage services;
- email delivery;
- security and bot protection;
- error monitoring, which receives technical details of faults;
- blockchain data services, which receive the wallet addresses we look up;
- sign-in services you choose to use, such as Google;
- payment processing for Sharpe Pro, such as Stripe; and
- content moderation.
Our service providers may use personal information only to provide services to us, and are bound by obligations of confidentiality and security. A current list of our service providers is available on request.
When you connect an exchange account, we send the exchange requests authorised by your API key to read your data. The exchange already holds that data, and its own privacy policy applies to it.
We may also disclose personal information to our professional advisers; where required or authorised by law, for example in response to a court order; where necessary to prevent fraud or to protect the safety of any person; or to a successor in connection with a sale or restructure of our business. In the case of a sale, we will notify you before your personal information becomes subject to a different privacy policy.
8. Overseas disclosure
Some of the personal information we collect is stored or processed outside Australia, including in India, the United States and Ireland. Some of our service providers operate global networks that may process data in other countries.
We take reasonable steps to ensure that overseas recipients handle personal information in a manner consistent with the Australian Privacy Principles. Where the GDPR applies, we rely on recognised safeguards for international transfers, such as the European Commission’s standard contractual clauses.
9. Retention
We keep personal information only for as long as we need it for the purposes described in this policy, or as required by law.
- Your account information and the data associated with your account are kept until you delete your account. When you delete your account, we delete your account, profile, connections, API keys, trading data, results and uploaded images from our systems.
- If you remove a connection more than a day after adding it, its trades and API key are deleted, and the daily results it already contributed to stay part of your record as they were. Removed within a day of being added, it is removed from your record entirely.
- Copies held in backups are deleted when those backups expire, after a limited period.
- If you sign up with an email address and never confirm it, the account and its username are deleted after 7 days.
- Records of moderation actions are kept without a link to your account.
- Feature suggestions are kept for as long as they are useful in improving Sharpe. If you delete your account, a suggestion you sent is kept without a link to it.
- Payment records are kept for as long as the law requires, generally five years.
- Technical information about wallet lookups, and about the requests that add to our daily visit counts, is kept for a short period and then deleted automatically.
- Public blockchain records we have read, and the measurements we produce from them, are kept for as long as they are useful for measuring wallets and pricing tokens.
10. Security
We take reasonable steps to protect personal information from misuse, interference and loss, and from unauthorised access, modification or disclosure. These steps include encryption of data in transit, encryption of exchange API keys at rest, access controls that limit each member to their own private data, optional passkeys and two-factor authentication, bot protection on sign-up and sign-in, and restricted staff access.
We request read-only access to exchange accounts, and we refuse API keys that permit trading or withdrawals where the exchange reports a key’s permissions.
No method of transmission or storage is completely secure. If a data breach is likely to result in serious harm to you, we will notify you and the relevant regulator as required by law.
11. Your rights and choices
Subject to applicable law, you may:
- access your personal information, including by downloading a copy of your data in your account settings;
- correct your personal information, including by editing your profile and account;
- delete your account and its associated personal information in your account settings;
- make your profile private;
- remove a connected exchange account or wallet in your account settings (we also recommend revoking the API key with the exchange);
- turn off emails about your results in your account settings or from any of those emails; and
- object to, or ask us to restrict, our use of your personal information, including the publication of a wallet you control.
To make a request you cannot complete in your account settings, contact privacy@sharpe.gg. We may need to verify your identity before acting on a request; for a wallet, this may require a signature from that wallet. We will respond within 30 days, and we do not charge for requests.
13. Children
Sharpe is intended for people aged 18 and over. We do not knowingly collect personal information from anyone under 18. If we become aware that an account belongs to a person under 18, we will delete it.
14. Changes to this policy
We may update this policy from time to time. We will publish the updated policy on this page with a new date. If a change materially affects how we handle your personal information, we will notify members by email before the change takes effect.
15. Contact us and complaints
If you have a question, request or complaint about privacy, contact us at privacy@sharpe.gg. We will acknowledge a complaint within 7 days and aim to resolve it within 30 days.
If you are not satisfied with our response, you may complain to the Office of the Australian Information Commissioner at oaic.gov.au. If you are located in the European Union or the United Kingdom, you may also lodge a complaint with your local data protection authority.