Privacy Policy

Last updated: February 2026

MemDex ("we," "us," or "our") operates the Memdex One Automated Portfolio platform. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our website and services. By accessing or using the Memdex One platform, you agree to the practices described in this policy.

This platform is not directed to users located in jurisdictions where digital asset services are restricted or prohibited.

Information We Collect

We collect information you provide directly, as well as information generated through your use of our platform:

Account Information: When you create an account, we collect your email address and password. We do not collect your name, phone number, or government-issued identification.

Wallet Information: When you connect a NEAR wallet, we receive your public wallet address. We do not have access to your private keys or seed phrases. Your wallet address and on-chain transaction history are publicly visible on the NEAR blockchain by design.

Communication Data: If you subscribe to our newsletter, we collect your email address. If you contact us, we retain the content of your correspondence.

Usage Data: We automatically collect technical information including your IP address, browser type, device information, pages visited, and session duration. This data helps us maintain and improve the platform.

How We Use Your Information

We use your information for the following purposes:

  • Providing, operating, and maintaining the Memdex One platform and your account
  • Authenticating your identity and managing your sessions
  • Displaying portfolio performance data through your dashboard
  • Sending service-related communications (security alerts, system updates)
  • Sending marketing communications where you have opted in (e.g., newsletter)
  • Monitoring for fraud, unauthorized access, and security threats
  • Analyzing usage patterns to improve platform performance and user experience
  • Complying with applicable legal and regulatory obligations

Blockchain Data

MemDex operates on the NEAR Protocol blockchain. Transactions executed by the algorithmic rebalancing engine, including trades and portfolio adjustments, are recorded on-chain. Blockchain data is publicly accessible, immutable, and cannot be deleted or modified by MemDex or any other party. We cannot fulfill deletion requests for data that exists on the blockchain, as this is a fundamental characteristic of distributed ledger technology.

How We Share Your Information

We do not sell your personal information. We may share information in the following circumstances:

Service Providers: We may share data with trusted third-party service providers who assist in operating our platform (e.g., hosting, analytics, email delivery), subject to confidentiality obligations.

Legal Requirements: We may disclose your information if required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, your safety, or the safety of others.

Business Transfers: In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

Data Retention

We retain your account information for as long as your account is active or as needed to provide you services. If you close your account, we will delete or anonymize your personal information within a reasonable timeframe, except where retention is required by law or for legitimate business purposes such as fraud prevention. On-chain data cannot be deleted due to the immutable nature of blockchain technology.

Data Security

We implement industry-standard security measures to protect your personal information, including encryption of data in transit, secure password hashing (Argon2), and access controls. However, no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security.

Cookies and Tracking

We use session cookies to maintain your authenticated state while using the platform. We may also use analytics tools to understand how visitors interact with our website. You can control cookie settings through your browser preferences.

Your Rights

Depending on your jurisdiction, you may have the right to:

  • Access the personal information we hold about you
  • Request correction of inaccurate information
  • Request deletion of your personal information (subject to blockchain limitations)
  • Opt out of marketing communications at any time
  • Object to or restrict certain processing activities
  • Request portability of your data

Data access, correction, or deletion requests may be submitted to privacy@thememdexap.com. Requests will be acknowledged within 5 business days. For all other enquiries, contact us at contact@thememdexap.com.

California Residents (CCPA)

If you are a California resident, you have the right to know what personal information we collect, request its deletion, and opt out of any sale of personal information. MemDex does not sell personal information. To submit a request, contact us at the email address above.

European Residents (GDPR)

If you are located in the European Economic Area, our legal basis for collecting and using your personal information is your consent (for marketing communications), performance of a contract (for providing our services), and our legitimate interests (for security and platform improvement). You have the right to lodge a complaint with your local data protection authority.

Children's Privacy

The Memdex One platform is not intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us and we will take steps to delete such information.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on this page with a revised "Last updated" date. Your continued use of the platform after any changes constitutes acceptance of the updated policy.

Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at contact@thememdexap.com.

© 2026 MEMDEX / MountainTop Foundation. All rights reserved. See also our Terms of Service and Regulatory Information.