Privacy Policy

Last Updated: 25 September 2026

This "Privacy Notice" describes the privacy practices of the Pump Entities and their affiliates (collectively, "Pump", "our", "us" or "we") in connection with the Sites, the Pump Platform and the Pump Services (collectively, the "Services"). The "Sites" are www.pump.fun, the pump.fun mobile applications and any other website, application or online interface operated by Pump. Capitalised terms used but not defined in this Privacy Notice (including Pump Entities, Pump Platform, Pump Services, Wallet, Digital Assets, Audio Content and Voice Chat Feature) have the meanings given in our Terms of Use at https://pump.fun/docs/terms-and-conditions (the "Terms"). This Privacy Notice also explains the rights and choices available to individuals with respect to their information.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, please do not use the Pump Platform. By accessing or using the Pump Platform, you acknowledge and agree to the terms of this Privacy Notice.

We may update this Privacy Notice based upon evolving laws, regulations and industry standards, or as we may make changes to the Services. The date of the most recent revision appears at the top of this Privacy Notice. If we make changes that materially alter your privacy rights, we will take appropriate measures to inform you, consistent with the significance of the changes we make. If you disagree with the changes to this Privacy Notice, you should discontinue your access and use of the Pump Platform.

Our Site and the Pump Platform are not directed to, and we do not knowingly collect Personal Data from, anyone under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information, they should contact us. We will delete such information from our files as soon as reasonably practicable.

Personal Data Controller

The term "Personal Data" as used in this policy, describes information that can be associated with a specific person and can identify that person. Personal Data does not include information that has been aggregated or anonymized so that a specific person can no longer be identified. Any reference to "Personal Data" in this Privacy Notice includes without limitation "personal data" as defined by the UK General Data Protection Regulation and the Data Protection Act 2018, the EU General Data Protection Regulation (Regulation (EU) 2016/679) and any other data protection law that applies to our processing of your Personal Data (together, "Data Protection Law").

A Personal Data controller is a person or organisation who controls the collection, holding, processing or use of Personal Data, including a person or organisation who instructs another person or organisation to collect, hold, process, use, transfer or disclose Personal Data on his or her behalf.

For the purposes of Data Protection Law, the controller of Personal Data processed in connection with the Services is Baton Corporation, Ltd., 82a James Carter Road, Mildenhall, Bury St. Edmunds, England, IP28 7DE, acting for itself and on behalf of the other Pump Entities. In respect of Personal Data processed through the pump.fun mobile applications, the controller is Maius Imperium, Ltd., No. 1 Charlotte Quay, Suite 2A, Limerick, Ireland, which also publishes the applications on the Apple App Store and Google Play. You can contact us about this Privacy Notice, or to exercise any of your rights, by email at [email protected] (the "Privacy Contact"). Our representative in the European Union for the purposes of Article 27 of the EU General Data Protection Regulation, in respect of processing by Baton Corporation, Ltd., is Maius Imperium, Ltd., No. 1 Charlotte Quay, Suite 2A, Limerick, Ireland, which may be contacted at [email protected].

Types of Personal Data Collected

The types of Personal Data that we may collect from you or through third parties will depend on our interactions with you and may include:

Wallet and authentication information such as your Wallet address(es), the email address, social-login identifier or other credential you use to sign in (including through Privy.io or another wallet or authentication provider), and related session data;
Transaction information such as the wallet addresses of senders and recipients of Digital Assets, activities on the Pump Platform, your inquiries and our responses;
Usage Data which can include your IP address, your country of origin, the features of the browser or operating system utilised by you, how you use the Pump Platform, among other identifiers;
Communications you send to us or that we send to you, including through our support channels, Telegram, X or other messaging platforms;
Audio and communications data where you use the Voice Chat Feature or livestream features, including voice recordings, transcripts, metadata and moderation records (see "Voice Chat, Livestreams and Audio Data" below);
Programme and product data where you register for a Hackathon or use a product-specific Pump Service such as Go.fun, Charity Coins or the Tokenized Agent, including registration details, submissions and any information we are required to collect for that programme;
Other personal data or commercial and/or identification information that we may reasonably require to comply with applicable anti-money laundering, sanctions and similar laws and regulations, including identity verification information where a particular Pump Service requires it.

We may also collect Personal Data about you from third parties and other sources such as publicly available sources of information.

We collect this information from you when you freely provide it on the Pump Platform or when you use the Pump Platform. We may also collect your Personal Data from third parties or publicly available sources as noted above.

Unless specified otherwise, all Personal Data requested by us is mandatory and failure to provide this Personal Data may make it impossible for you to access or use the Pump Platform. In cases where the Pump Platform specifically states that some Personal Data is not mandatory, users are free not to communicate this Personal Data without consequences to the availability or the functioning of the Pump Platform. Users who are uncertain about which Personal Data is mandatory may contact us for clarification.

Information We Automatically Collect

When you visit the Pump Platform, we may automatically collect certain information about your device, including information about your web browser, IP address and/or domain name, IMEI or other device information, your login information, browser type and version, timezone setting, browser plug-in types and versions, operating systems and platforms, location information, and some of the cookies that are installed on your device using cookies and similar technologies. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site.

Cookies & Similar Technologies

We use cookies (small, often encrypted, text files that are stored on your computer or mobile device) and similar technologies ("Cookies") to provide you with certain functions on our Site and help collect data. This section explains how we use Cookies to collect information about the way you use our Site and how you can control them.

How We Use Cookies

We use Cookies to track how you use the Pump Platform by providing usage statistics. Cookies are also used to deliver our information (including updates) and allow account authentication to you based upon your browsing history and previous visits to the Site.

For the avoidance of doubt, we do not combine or link data or information gathered from Cookies with third party data for targeted advertising or advertising measurement purposes or sharing data collected about a particular end-user or device with a data broker.

Types of Cookies

We use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our Site can be grouped into the following categories:

Strictly Necessary: These Cookies are necessary for the Site to work properly. They include any essential authentication and authorisation Cookies for our Site.

Functionality: These Cookies enable technical performance and allow us to remember the choices you make while browsing our Site, including any preferences you set. They also include sign-in and authentication Cookies and IDs that enable you to return without additional sign-in.

Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the Site and services running on your device. They help us understand which areas you use and what we can do to improve them.

Attribution: These Cookies allow us to measure, on an aggregated device-level basis (not tied to a named or otherwise identifiable person), which referral sources bring visitors to our Site. We do not use Cookies to serve targeted advertising to you, and we do not share information collected through Cookies with data brokers.

How to Control and Delete Cookies

Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your Cookie preferences across these environments.

If you are using a mobile device to access the Site, you will need to refer to your instruction manual or other help/settings resource to find out how you can control Cookies on your device. For more information about cookies, and how to disable cookies, visit https://www.allaboutcookies.org.

Please note that if you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the Site may not operate properly, and you may not have access to our services available through the Site. We are not responsible for your inability to use our Site or any degraded function you may experience that may be caused by your settings and choices regarding Cookies.

Google Analytics

We may use Google Analytics to help analyze how you use our Site. Google Analytics generates statistical and other information about website use by means of cookies, which are stored on users' computers. The information generated is used to create reports about the use of our Site. Google will store this information.

If you do not want your Site visit data reported by Google Analytics, you can install the Google Analytics opt-out browser add-on. For more details on installing and uninstalling the add-on, please visit https://tools.google.com/dlpage/gaoptout.

Mobile Applications

When you use the pump.fun mobile applications we may collect device identifiers, push-notification tokens, app version, operating system and crash and diagnostic data, in addition to the information described elsewhere in this Privacy Notice. The applications may request permission to use your device's microphone (for the Voice Chat Feature and livestreams), camera and photo library (for uploading images and User Materials) and notifications (for alerts about your Transactions and the Services). You can grant, refuse or withdraw these permissions at any time in your device settings, although some features will not work without them. The permission purposes shown in the applications, the "App Privacy" details published on the Apple App Store and the "Data safety" disclosures published on Google Play are derived from, and should be read together with, this Privacy Notice.

Attribution and in-app marketing. The applications include the AppsFlyer software development kit, which we use to attribute app installs and in-app activity to the marketing campaigns and channels that led to them, to measure the performance of our marketing across other companies' apps and websites, and to deliver in-app marketing messages. For these purposes AppsFlyer collects device identifiers (including, where you permit it, the Apple Identifier for Advertisers or the Google Advertising ID), IP address, device and app information and in-app events, and may link that information with information received from advertising networks and other third parties. This is "tracking" as Apple defines it. On iOS we will ask for your permission through the App Tracking Transparency prompt before accessing the Identifier for Advertisers, and if you decline we will not use it (you can change this at any time in Settings > Privacy & Security > Tracking). On Android you can reset or delete your Advertising ID, or opt out of ads personalisation, in your device's Google settings. Where Data Protection Law or applicable e-privacy law requires your consent for this processing, we rely on your consent, which you may withdraw as described above. AppsFlyer's own privacy policy is available at https://www.appsflyer.com/legal/privacy-policy/. We do not sell your Personal Data or share it with data brokers.

Method and Basis of Processing Data

Methods of processing

We take appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of Personal Data.

The Personal Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. Data may be accessible to you and in some cases, to certain types of persons in charge, involved with the operation of the Pump Platform (administration, legal, system administration) or external parties (such as third-party technical service providers, hosting providers, IT companies) appointed, if necessary, as processors by us. You may request a list of these parties at any time.

Legal basis of processing

We may process Personal Data relating to you if one of the following applies:

You have given your consent for one or more specific purposes. Note: Under some legislation we may be allowed to process Personal Data until you object to such processing ("opt-out"), without having to rely on consent or any other of the following legal bases:

Provision of Personal Data is necessary for the performance of an agreement with you and/or for any pre-contractual obligations thereof;
Processing is necessary for compliance with a legal obligation to which we are subject;
Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;
Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

For marketing communications sent by electronic means (such as email, in-app messages or push notifications), we rely on your consent, which you may withdraw at any time as described under "Marketing Communications and Your Choices" below. We will not send you marketing communications unless you have consented to receive them.

How We Use Personal Data

Data we collect about you is collected to:

Provide the Site and Pump Platform and customer support you request;
Process transactions and send notices about your transactions on the Pump Platform;
Detect, investigate and prevent malicious, fraudulent or manipulative activity, including market manipulation and the misuse of the Voice Chat Feature or livestream features;
Moderate content and communications, including Audio Content and livestreams, and enforce the Terms and our published policies;
Screen users and Wallets against sanctions lists and comply with anti-money laundering and similar obligations;
Enable us to monitor and analyse your behaviour ("Analytics");
Beta test certain features or the Pump Platform;
Contact you;
Display content from external platforms;
Handle productivity related activities;
Provide social features;
Optimise traffic and performance of the Pump Platform;
Send you, where you have consented, marketing communications about the Pump Services, new features, programmes and events, subject to your right to withdraw consent at any time;
Measure the effectiveness of our marketing and attribute installations of the mobile applications and in-app activity to the campaigns and channels that led to them, including across other companies' apps and websites, as described under "Mobile Applications";
Allow us to register you as a user of the Pump Platform and authenticate your credentials;
Comply with legal obligations, respond to requests from courts, regulators and law enforcement, and preserve records where reasonably necessary for legal process;
Protect the rights and interests of Pump and Pump Affiliates (or those of our users and third parties);
Infrastructure monitoring;
Interaction with external social networks and platforms;
Location-based interactions;
Tag management (tags are pieces of code that allow us to better analyse and track activities on the Pump Platform);
Engage in traffic optimisation and distribution.

Marketing Communications and Your Choices

Every marketing email we send will include an unsubscribe link, and you may also withdraw your consent to marketing communications at any time by contacting the Privacy Contact. We will honour your opt-out within ten (10) business days. We do not send marketing communications that promote trading, token launches or specific Digital Assets to recipients we know to be located in the United Kingdom or a Prohibited Jurisdiction (as defined in the Terms). Opting out of marketing does not stop us from sending you transactional, security, service or legal notices relating to your use of the Services, including the notices described in Sections 14, 28.2 and 29.2 of the Terms.

How We Share Personal Data

We may share your Personal Data with our service providers and vendors to assist us in providing you with the Pump Platform. We do not share your Personal Data with third parties without your consent, except as described in this Privacy Notice or as otherwise required or permitted by applicable law. We may share your Personal Data within our group, and with affiliates, for purposes consistent with this Privacy Notice.

We may share your Personal Data with third party companies and individuals that provide services on our behalf or help us operate the Site or our business, including wallet infrastructure and authentication providers (such as Privy.io), hosting, analytics and communications providers, email and marketing communications providers, mobile attribution and in-app marketing providers (AppsFlyer), livestream and voice-chat infrastructure providers, and fraud-prevention and sanctions-screening providers. These third parties may use your Personal Data only as directed or authorised by us and in a manner consistent with this Privacy Notice, and are prohibited from using or disclosing your information for any other purpose. We may also share your Personal Data for compliance purposes.

We may sell, transfer or otherwise share some or all of our business or assets, including your Personal Data, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganisation or sale of assets, or in the event of bankruptcy or dissolution.

Where a Pump Service is provided together with, or depends on, a third party's own service (for example a Wallet provider, a Pair Asset Issuer or a blockchain network), that third party may receive Personal Data directly from you or from your on-chain activity and will process it under its own privacy terms, which we encourage you to read.

Product-Specific Services. Certain Pump Services, including Go.fun, Charity Coins, the Tokenized Agent and any Hackathon, are subject to Product-Specific Terms under the Terms. Where those Product-Specific Terms describe additional collection or use of Personal Data, they supplement this Privacy Notice for that service. The Padre trading terminal (padre.gg) is operated by a separate entity and is governed by its own terms of service and privacy policy.

Retention of Personal Data

We will retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. We determine data retention based on the amount, nature, and sensitivity of the Personal Data, the potential risk of harm from an unauthorised user, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal requirements.

Personal Data collected for purposes related to the performance of a contract between you and us will be retained until such contract has been fully performed. Personal Data collected for our legitimate interests will be retained as long as needed to fulfil such purposes.

We may be allowed to retain Personal Data for a longer period whenever you have given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data will be deleted (or, where permitted under applicable law, may be de-identified instead). Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability (where relevant under applicable law) cannot be enforced after expiration of the retention period.

However not all your Personal Data may be able to be deleted or de-identified; see the section of this Privacy Notice on "Blockchain transactions", below.

Privacy Technology Practices

Links to Third-Party Sites

The Pump Platform may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of your Personal Data. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.

Data Security

The security of your Personal Data is important to us. We employ a number of administrative, technical, and physical safeguards designed to protect the Personal Data we collect. The safety and security of your information also depends on you. We ask you not to share any of your personal security information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Pump Platform. Any transmission of Personal Data is at your own risk.

Voice Chat, Livestreams and Audio Data

Where you use the Voice Chat Feature or livestream features, we and our service providers may transmit, process and temporarily store your Audio Content and livestream content, and may monitor, record, transcribe or analyse it (including by automated means) for safety, moderation, fraud and market-manipulation prevention, compliance and service-improvement purposes, as described in Section 13.3 and Section 31 of the Terms.

Voice recordings may be treated as biometric data in some jurisdictions. We do not use Audio Content to create a voiceprint or otherwise to identify you biometrically. Where Data Protection Law requires a specific lawful basis or your explicit consent for such processing, we will rely on it and will tell you at the point of collection.

We retain Audio Content, transcripts and related moderation records for thirty (30) days from the date of the communication, unless a longer period is required for an ongoing investigation, legal process, a request from a Regulatory Authority or the enforcement of the Terms, in which case we retain them for as long as that purpose requires.

If you record other participants, you are responsible for obtaining any consent that Applicable Law requires from them.

Blockchain Transactions

Your use of Digital Assets may be recorded on a public blockchain (including the Solana blockchain and any EVM Blockchain we support, such as Robinhood Chain), in particular the settlement of your Transactions in Digital Assets. Public blockchains are distributed ledgers, intended to immutably record transactions across wide networks of computer systems. Many blockchains are open to forensic analysis which can lead to re-identification of transacting individuals and the revelation of personal data, especially when blockchain data is combined with other data.

As blockchains are decentralised or third-party networks which are not controlled or operated by us, we are not able to erase, modify, or alter personal data on such networks.

Overseas Disclosure and Your Privacy Rights

Pump has operations throughout the world. As a result, Personal Data may be transferred outside the country in which you reside for the purposes identified. Where we transfer Personal Data from the United Kingdom or the European Economic Area to a country that has not been recognised as providing an adequate level of protection, we rely on an appropriate transfer mechanism under Data Protection Law, such as the UK International Data Transfer Agreement or Addendum, the European Commission's Standard Contractual Clauses, or another lawful mechanism, together with supplementary measures where required. You may request a copy of the relevant safeguards by contacting the Privacy Contact. By using the Pump Platform you understand that your Personal Data may be processed in the United States and outside of the EEA and the UK.

Residents of the EEA and the UK are granted certain rights over their Personal Data, which include:

The right to obtain confirmation of the Personal Data we process.
The right to rectify inaccurate Personal Data that we process.
The right to request erasure of your Personal Data, subject to exceptions provided under the law.
The right to restrict certain processing of your Personal Data, so long as the processing is not necessary for the performance of or in relation to a contract or service to which you are a party.
The right to receive your Personal Data in a structured, commonly used and machine readable format
The right to object to the processing of your Personal Data, including the right to object to automated decision-making and profiling.
The right to withdraw your consent where you have previously given it for the processing of your Personal Data; and
The right to lodge a complaint with a supervisory authority, including the UK Information Commissioner's Office, the Irish Data Protection Commission (the lead supervisory authority for Maius Imperium, Ltd.) or the data protection authority of the EEA country in which you live or work.

You are generally entitled to access Personal Data that we hold about you. If you request access to your Personal Data, in ordinary circumstances we will give you full access to your Personal Data. Depending on the nature of the request, we may charge for providing access to this information, however such charge will not be excessive. However, there may be some legal or administrative reasons to deny access. If we refuse your request to access your Personal Data, we will provide you with reasons for the refusal where we are required by law to give those reasons.

Complaints: If you feel that we have not respected your privacy or that we have conducted ourselves inconsistently with this Privacy Notice, please contact the Privacy Contact and advise us as soon as possible. We will investigate your queries and privacy complaints within a reasonable period of time depending on the complexity of the complaint. We will notify you of the outcome of our investigation. We will respond to requests to exercise your rights within the period required by Data Protection Law (generally one month, extendable where permitted).

General

If you would like to exercise any of the rights listed above, or if you would like to contact us about any questions you may have regarding your Personal Data, please contact the Privacy Contact and provide (i) enough information to identify you and (ii) a description of what right you want to exercise and the information to which your request relates. Any Personal Data we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

Account and data deletion. You may delete your account and request deletion of your Personal Data at any time from within the pump.fun mobile application or by contacting the Privacy Contact. A web-accessible deletion request page is available at https://pump.fun. Deletion is subject to the exceptions described under "Retention of Personal Data" (information we must keep to meet legal, regulatory, accounting or reporting obligations) and "Blockchain Transactions" (information recorded on public blockchains, which we cannot erase).

If you are concerned that we have not complied with your legal rights or applicable privacy laws, you may contact us or your local data protection authority.