Privacy Policy

The Candidate, LLC (“Company,” “we,” “us,” or “our”), a Puerto Rico limited liability company, operates The Candidate Protocol (the “Protocol”) and related services. This Privacy Policy describes how we collect, use, disclose, and protect information when you access or use our Protocol, website, and services (collectively, the “Services”).

By using our Services, you agree to the collection and use of information in accordance with this Privacy Policy.

1. Information We Collect

1.1 Blockchain Data

When you interact with the Protocol, certain information is recorded on the Solana blockchain, including:

• Your public wallet address
• Transaction signatures and timestamps
• Purchase amounts and contract details
• Vesting stream information
• Marketplace listing and sales data
• Affiliate referral transactions

Note: Blockchain data is public by nature. We do not control and cannot delete data recorded on the Solana blockchain.

1.2 Identity Verification (KYC) Data

To comply with regulatory requirements, we require Know Your Customer (KYC) verification for certain transactions. KYC verification is performed through the Solana Attestation Service (SAS) using third-party identity verification providers such as Sumsub.

Important: We do NOT store your personal identity documents, Social Security Numbers, or other sensitive personally identifiable information (PII) directly. Our third-party KYC providers handle and secure this data according to their own privacy policies. We only store:

• Verification status (verified/not verified)
• Verification provider reference IDs
• Whether you are a US person (for tax reporting purposes)
• Tax form submission status (W-9/W-8BEN)

1.3 Tax Documentation

If you participate in our affiliate program or sell contracts on our marketplace above certain thresholds, we may collect tax documentation (W-9 or W-8BEN) through third-party services. This information is used solely for tax reporting compliance (1099-MISC for affiliates, 1099-K for marketplace sellers).

1.4 Technical Information

We may automatically collect certain technical information, including:

• IP address (anonymized where possible)
• Browser type and version
• Device information
• Pages visited and interaction patterns
• Referral sources

1.5 Communications

If you provide an email address for notifications or contact us directly, we collect the information you provide in those communications.

2. How We Use Information

We use the information we collect for the following purposes:

• Protocol Operations: Processing vesting contract purchases, marketplace transactions, and affiliate payments
• KYC Compliance: Verifying user identity to comply with applicable laws and regulations
• Tax Reporting: Generating and filing required tax forms (1099-MISC, 1099-K) as required by law
• Transaction Tracking: Maintaining records of purchases, sales, and transfers for your tax reporting needs
• Security: Detecting and preventing fraud, abuse, and security incidents
• Improvements: Analyzing usage patterns to improve our Services
• Communications: Sending transaction confirmations, notifications, and updates about the Protocol
• Legal Compliance: Complying with applicable laws, regulations, and legal processes

3. Third-Party Services

The Protocol integrates with several third-party services. When you use our Services, your information may be processed by:

3.1 Blockchain Infrastructure

• Solana Network: The underlying blockchain where all transactions are recorded
• Streamflow Finance: Manages all vesting contracts and token streams
• Jupiter: Executes CCV buyback transactions via DCA
• Squads Protocol: Provides governance multisig functionality

3.2 Identity & Compliance

• Sumsub: KYC/AML identity verification provider
• Solana Attestation Service (SAS): On-chain attestation for KYC status
• Persona: Tax document collection and verification

3.3 Analytics & Monitoring

• Dune Analytics: Public blockchain data aggregation and dashboards
• Helius: Blockchain monitoring and webhook services

Each of these services has its own privacy policy governing how they handle your data. We encourage you to review their policies.

4. Data Retention

We retain information for as long as necessary to provide our Services and comply with legal obligations:

• Transaction Records: 7 years (IRS requirement)
• Tax Documents (W-9/W-8BEN): 7 years from last payment
• 1099 Forms: 7 years
• Cost Basis Records: 7 years from asset disposal
• Affiliate Earning Records: 7 years
• Audit Logs: 7 years

Blockchain Data: Data recorded on the Solana blockchain is permanent and cannot be deleted.

5. Data Sharing and Disclosure

We may share your information in the following circumstances:

• Service Providers: With third-party service providers who assist in operating our Services (as described in Section 3)
• Tax Authorities: With the IRS or other tax authorities as required by law for 1099 reporting
• Legal Requirements: When required by law, court order, or governmental authority
• Protection of Rights: To protect our rights, privacy, safety, or property, or that of others
• Business Transfers: In connection with any merger, acquisition, or sale of assets

We do not sell your personal information to third parties for marketing purposes.

6. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the Internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

Important: You are responsible for maintaining the security of your wallet and private keys. We will never ask for your private keys or seed phrases.

7. Your Rights

Subject to applicable law, you may have certain rights regarding your information:

• Access: Request access to the personal information we hold about you
• Correction: Request correction of inaccurate information
• Deletion: Request deletion of your information (subject to legal retention requirements)
• Portability: Request a copy of your data in a portable format
• Opt-Out: Opt out of certain communications

Limitations: We cannot delete blockchain data or information we are legally required to retain for tax and compliance purposes.

To exercise your rights, please contact us at legal@thecandidate.com.

8. Cookies and Similar Technologies

We may use cookies and similar technologies to:

• Remember your preferences and settings
• Understand how you use our Services
• Improve performance and functionality
• Analyze traffic and usage patterns

You can control cookies through your browser settings. Disabling cookies may affect the functionality of our Services.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, please contact us immediately.

10. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. By using our Services, you consent to the transfer of your information to these countries.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last Updated” date. Your continued use of our Services after any changes constitutes your acceptance of the updated Privacy Policy.

12. Contact Us

If you have questions about this Privacy Policy or our data practices, please contact us:

13. Governing Law

This Privacy Policy is governed by and construed in accordance with the laws of the Commonwealth of Puerto Rico, without regard to its conflict of law principles.