Privacy Policy

1. Who we are (data controller)

The controller of your personal data is Tedafunded LLC, a limited liability company registered in Wyoming, United States (Filing ID 2025-001817067), registered address 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801. Spike Funded is a trading name of Tedafunded LLC. Contact: contact@spikefunded.com.

2. Data we collect

• Account data — name, email address, password hash, country, account preferences.
• Billing data — order history, amount, currency, payment method type and the transaction reference returned by our payment providers. We do not store full card numbers.
• Identity verification (KYC) data — government-issued identity document, date of birth, address, and liveness/selfie check, collected only when a performance reward is due.
• Usage data — simulated trading activity, platform interactions, device and browser information, IP address and log data.
• Communications — messages you send us by email or through support channels.

3. Purposes and legal bases

• Providing the evaluation program (account creation, simulated accounts, program rules) — performance of a contract.
• Processing payments and refunds — performance of a contract.
• Identity verification, sanctions screening and AML record keeping — legal obligation and legitimate interest in preventing fraud and financial crime.
• Administering performance rewards under the independent contractor agreement — performance of a contract.
• Security, abuse prevention and enforcement of program rules — legitimate interest.
• Analytics and product improvement — consent (where required) or legitimate interest.
• Marketing communications — consent, withdrawable at any time.

4. Who we share data with

We share personal data with the following categories of recipients, only as needed:

• Payment processors — licensed payment institutions handling card and alternative payment methods through a payment orchestration layer.
• Crypto payment gateway — where you pay in cryptocurrency; the gateway converts to fiat on receipt.
• Payout platform — Rise (RiseWorks), which administers contractor payments after verification.
• Identity verification (KYC) provider — [[TO_CONFIRM: KYC provider name]].
• Hosting and infrastructure providers — for application hosting, databases, logging and email delivery.
• Analytics providers — only where you have consented to non-essential cookies.
• Professional advisers and authorities — where required by law or to establish or defend legal claims.

We do not sell personal data.

5. International transfers

We are established in the United States, and some of our providers process data outside your country of residence. Where personal data of individuals in the European Economic Area or the United Kingdom is transferred, we rely on appropriate safeguards, such as the European Commission's Standard Contractual Clauses (and the UK Addendum where applicable), together with supplementary measures where necessary.

6. Retention

• Account and usage data — for the life of the account and up to [[TO_CONFIRM: retention period after account closure — default: 3 years]] 3 years afterwards.
• Billing records — as required by tax and accounting law.
• KYC and AML records — retained for a minimum of five (5) years after the end of the business relationship.

7. Your rights

Subject to applicable law, you may request access to your personal data, correction, erasure, restriction of processing, portability, and you may object to processing based on legitimate interests. Where processing is based on consent, you may withdraw it at any time without affecting prior processing.

To exercise a right, email contact@spikefunded.com. We may ask you to verify your identity. You also have the right to lodge a complaint with your local data protection authority. Note that we may be unable to erase KYC and AML records before the statutory retention period expires.

8. Additional information for US residents (CCPA/CPRA)

If you are a California resident, you may request disclosure of the categories and specific pieces of personal information we have collected, the purposes of collection and the categories of recipients; request deletion or correction; and you have the right not to receive discriminatory treatment for exercising these rights.

We do not sell your personal information, and we do not share it for cross-context behavioural advertising. Requests may be submitted to contact@spikefunded.com and may be made by an authorised agent.

9. Cookies

We use essential cookies to operate the platform and, with your consent, non-essential cookies for analytics. Non-essential scripts are not loaded until you consent. See our Cookie Policy for details and to change your choice.

10. Children

Our services are intended for adults. We do not knowingly collect personal data from anyone under 18 years of age. If you believe a minor has provided us with personal data, contact us and we will delete it.

11. Changes and contact

We may update this policy; the "Last updated" date above reflects the current version. Questions: contact@spikefunded.com — Tedafunded LLC, 1309 Coffeen Avenue STE 1200, Sheridan, WY 82801, United States.