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Privacy Policy

Last updated March 13, 2023

This Privacy Policy of Butterfly Hedge, LLC “Provider,” “us,” “we,” and “our”) describes the information we collect about you when you access our website, enter into agreements with us, use our services and products, send us communications, or otherwise engage with us, and what we do with such information. Any references to Provider in this Privacy Policy also refers to Provider’s wholly owned subsidiaries. This Privacy Policy covers the game Decision Pigeons and any web site associated therewith provided by Provider (“Products”).


By opening an account with us and utilizing Products, you agree to the terms of our Privacy Policy. If you do not agree to the terms of our Privacy Policy, you cannot use our Products and should not access our Products.


We understand that privacy is an important issue to you and we respect the privacy of all of our customers and aim to protect the security and confidentiality of non-public personal information about you that we acquire.


Under the law you have the right to limit some, but not all, sharing of your personal information. The law also requires us to disclose to you how we collect, share and protect your personal information.


Personal Information Collected


We collect information about you when you provide it to us and when you use our Products, open an account with us, request information or otherwise interact with our Products. We also receive information about you from third-parties who you have authorized to disclose information about you that we need for the account opening process, to satisfy our know-your-customer, other regulatory obligations, and for effecting transactions for your account.


The personal information we may collect includes:

  • your name, address, telephone and mobile phone numbers, user name, date of birth, government issued identification, social security number, tax identification number, bank account details;

  • information relating to your transactions;

  • information that may be received from consumer reporting agencies, such as credit bureau reports; information in any emails, chat messages, phone conversations, or other communications you send to us;

  • information which may be received from other sources with your consent.

Non-public information that is associated only with you and identifies you as an individual is called Personally Identifiable Information (“PII”). PII does not include anonymized data as it cannot be used to identify you.


Other Information Collected

We also collect other information that does not uniquely identify you as an individual. This information is referred to as “Non-Personally Identifiable Information (“Non-PII”). We collect Non-PII when you interact with us and use our services and products. Examples of Non-PII that we collect includes: User Content submitted by you via the Products, information on the links that you click, the features of our Products that you use, what types of information you upload, information about your hardware, including your computer, phone, tablet or other devices you use to access our Products, and about your software, including your operating system, browser type, Internet protocol, your connection type and your settings and related information. We may share Non-PII with our advertising and marketing agents to evaluate the effectiveness of our marketing programs. We may use Non-PII to analyze your usage of our Products and for other research that help us improve the Products and/or other offerings we provide.


Information From Third Party Sources

From time to time, we may obtain information about you from third party sources as required or permitted by applicable law, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.


We also receive information about you when you link a third-party service to our services. Such linkage may include interactions with our social media sites. Third-party sites are governed by their own privacy policies, and you should review those privacy policies before using those sites.


Use of Your Personal Information

We use your personal information in connection with our provision of services and products to you in order to meet our contractual obligations to you. We will also process your PII to meet our legitimate interests, for example to verify your background, open your account, send you notices regarding your money transfers to and from Provider, send confirmations and other information on your transactions, to create your account statements, to maintain records on your transactions and to support your account generally. We may use your personal information and information about how you use our services to send promotional and other information to you. We also may use your personal information to conduct analysis regarding your usage of our services and products and the effectiveness of our marketing initiatives.


We will not use your personal information for purposes other than those purposes we have disclosed to you, without your permission. From time to time we may request your permission to allow us to share your personal information with third parties. You may opt out of having your personal information shared with third parties, or from allowing us to use your personal information for any purpose that is incompatible with the purposes for which we originally collected it or subsequently obtained your authorization. If you choose to so limit the use of your personal information, certain features or services of the Products may not be available to you.


Sharing of Your Personal Information

Provider does not disclose nonpublic personal information relating to current or former customers to any third-parties, except to those who require access to the data in order to perform their tasks and duties for supporting provision of the Products, and to share with third parties who have a legitimate purpose for accessing it. This may include but is not limited to, any obligations of Provider under the USA PATRIOT Act, and in order to facilitate the execution of our customers’ transactions in the ordinary course of business.


Provider has multiple affiliates and relationships with third-party companies. Examples of these companies include financial and non‐financial companies that perform services such as data processing, administrative services, regulatory support, legal services, liquidity providers, banks, cloud storage, Google in connection with its Google Analytic services, companies that host our wallets, auditors, accountants, and other service providers we engage from time to time that enable us to provide our services to you. We may share PII with such service providers to facilitate provision of the Products. We may share information among our affiliates, as permitted by law.


We do not sell, license, lease or otherwise disclose your personal information to any third-party for any reason other than the purposes described below:


We may disclose personal information to qualified third-parties in order to administer or process a transaction, product or service you have authorized or requested, or in the context of facilitating the execution of a transaction.


  • We are required to validate our customers’ identities by applicable laws and regulatory requirements and rely on qualified third-party services to perform these validations. PII that you provide to us is passed to these services at account opening and on an ongoing basis thereafter.

  • We provide PII, as required by applicable laws and regulatory requirements, to carry out or aid in certain functions, such as, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination.

  • We share your information with financial institutions with which we partner to process payments which you have authorized.

  • We may share analyses based on anonymous customer information or behavior with our affiliate companies in order to operate and improve products and services.

  • We may disclose or transfer information we collect to a purchaser of our business.

  • We may disclose or transfer information we collect upon account closing where you have a deficient balance, or upon excessive instances where you do not have sufficient funds in your account.

  • We may disclose personal information should you decide to participate in certain promotions and special offers when the nature of the promotion or special offer requires us to gather and share your personal information (such as your mailing address) with a third-party for delivery of goods or services. Should you choose to purchase a product or service offered by another company by way of a promotion or special offer, any personal information you share with that company would no longer be governed by our Privacy Policy.

  • We may disclose personal information to qualified third-parties and/or affiliate companies who provide services, such as, but not limited to, consulting, sales, customer support operations, payment processing, authentication services, and technical support or services.

  • We may share your information with law enforcement, and officials, or other third-parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our terms and conditions or any other applicable policies.

  • We may disclose information to third-parties about your account or the transactions you make if you give us your written permission.


If an affiliate company or qualified third-party needs access to certain personal or customer information in order to carry out certain functions on our behalf, they do so under our instructions. All affiliate companies and qualified third-parties with whom we share personal or other customer information have their own privacy policies, however, they are expected to protect your information in a manner that aligns with the protocols described in our Privacy Policy. We do not share your personal information with affiliates for their own benefit, unless you have given us your consent. We do not share your personal information with non-affiliates for their benefit.


Other circumstances under which we may disclose your personal information in order to:


  • Comply, as necessary, with applicable laws and regulatory requirements, as well as legal process;

  • Respond to mandatory legal or governmental requests or demands for information;

  • Meet national security requirements;

  • Enforce our agreements, policies, procedures and terms of use;

  • Protect ourselves, our affiliates, our customers or the general public from illegal activities; and

  • Respond to an emergency that requires disclosure of specified


Third-Party Websites

We may have links to third-party websites on our website. Third-party websites have their own privacy policies. We have no involvement with their policies. You are encouraged to review the privacy policies of all third-party websites you visit.


Use of Cookies

Provider uses cookies in order to provide better service, to facilitate our customers’ use of our Products, to track usage of the Products, to collect data and to address certain security issues. When you access our Products, we send the cookies to your computer or phone. Your computer or phone stores the cookie in a file located inside your web browser. The cookies help us keep track of your visits to our Products and your activity on our Products, to understand how you interact with us, and to provide Product functionality.


We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein. Similarly, the third parties who serve cookies on our site may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.


You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. If you want to learn more about cookies, or how to control, disable or delete them, please visit for detailed guidance. In addition, certain third-party advertising networks, including Google, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, visit .


Provider also uses Google Analytics. The following link explains how Google uses data when you use its partners’ websites and applications: Your use of the Products is evidence of your consent to Provider storing and accessing cookies and other information on your computer or phone and Provider’s use of Google Analytics in connection with such activities. Please read the information at the link provided so you understand what you are consenting to.



Provider strives to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public personal information that is provided to us by third-parties and by you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. Provider endeavors to engage third-party service providers that have security and confidentiality policies, if such third-party service providers have access to our customer’s PII. We instruct our employees to use strict standards of care in handling the personal financial information of customers. As a general policy our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers or as required by applicable law and regulatory requirements law or pursuant to regulatory request and/or authority.


Despite our efforts to protect the security of your information, no security system is always effective and we cannot guarantee that our systems will be completely secure.


How You Can Request to Access, Change, or Erase Your Information

You are entitled to make requests regarding the processing and storage of your PII. Specifically, you may submit a request to us to take the following actions in relation to your personal information that we hold:


  • Opt-out. You may request that we stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you service-related and other non-marketing communications.

  • Access. You may request we provide you with information about our processing of your personal information and give you access to your personal information.

  • Rectify. You may request we update or correct inaccuracies in your personal information.

  • Erase. You may request we erase your personal information.

  • Export. You may request we transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • Restrict. You may request we restrict the processing of your personal information.

  • Object. You may object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.


You may do this at any time by logging in to your account and clicking the Profile or My Account tab or by emailing Note that we may refuse to grant your requests in whole or in part as permitted by applicable law.


If you close your account, we will mark your account in our database as “Closed,” but will keep your account information in our database for a period of time described below. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personal information will not be used by us for any further purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.


Retention of Personal Information


We are required under applicable laws and regulatory requirements to retain certain information, including personal information of customers, customer profiles, identification verification materials, information we used to satisfy our know-your-customer and anti-money laundering obligations, account information, account agreements, trade orders, trade confirmations and other agreements between us, account statements, and other records.


Such records are generally retained as required by law, rule or regulation or for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under Provider’s data retention policies.


However, even after you deactivate your account, we can retain copies of information about you and any transactions or services in which you may have participated for a period of time that is consistent with applicable law, applicable statute of limitations or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services, to assist with investigations, to enforce any of our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law. 


Location of Personal Data

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data. Currently, we primarily use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps with the intent of processing and protecting as described in this privacy policy wherever the data are located.


Location of Processing European Personal Data. We transfer personal information from the European Economic Area (EEA), United Kingdom (UK), and Switzerland to other countries, some of which have not been determined by the European Commission to have an adequate level of data protection. When we do so, we use legal mechanisms, including contracts, to help ensure your rights and protections. 

“Do Not Track” Policy


California law requires us to inform you how we respond to web browser Do Not Track (“DNT”) signals. Because no industry or legal standard exists for recognizing or honoring DNT signals, we do not respond to them at this time. This policy is subject to change as the privacy community and industry develop best practices for responding to DNT signals.



If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that data: 

  • If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;

  • If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing; 

  • You can object to, or obtain a restriction of, the processing of personal information under certain circumstances; and

To make such requests  please use the contact information at the bottom of this statement, or  When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party.  You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.


We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfil other legitimate interests.






When Do We Store, Transfer or Process PII Internationally?

Provider has committed to meeting the requirements of local data protection laws to the extent required. Please be aware that your PII will be transferred to, processed, and stored in our data servers located within the United States. You consent to the transfer of your information, including PII, to the U.S. as set forth in this Privacy Policy by visiting our site or using our service.Changes to Privacy Policy

Provider reserves the right to make changes to this Privacy Policy. You should review this Privacy Policy frequently. Our Privacy Policy is available on our website, If we make material changes to our Privacy Policy, our revised Privacy Policy will be posted on our website, and it will either be noted on our website that material changes have been made or we will notify our customers by email. The date of the most recent update to our Privacy Policy will be set forth at the end of the Privacy Policy.


How to Get in Touch with Provider about this Privacy Policy


This Privacy Policy is available on our website at If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us either by emailing us at or by writing to us at Decision Pigeons 2633 Eastlake Ave E Suite: 202, Seattle, WA 98102, or by calling us at (425) 954-3312.


 Our data protection representative for the European Economic Area and Switzerland is the same as in the United States. We do not use a European Subsidiary. 

If you would like to submit a complaint about our use of your PII or response to your requests regarding your PII, you may contact us at or submit a complaint to the data protection regulator in your jurisdiction.

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