Privacy Policy

Foundation Labs, Inc. Operating the Aura Platform

Last Updated: December 1, 2025

1. Introduction

Foundation Labs, Inc. (“Foundation Labs,” “we,” “our,” or “us”) operates Aura, a social prediction market platform focused on pop culture, entertainment, and campus life. Because we ask users to share predictions, engage with content, and interact with others, protecting your privacy is fundamental to our mission.

Aura is a social, play-money prediction platform. Certain activities you choose to perform on Aura - including your predictions, market positions, and public profile information - may be visible to other users.

This Privacy Policy explains what information we collect, how we use it, the choices you have, and the rights you can exercise. By using Aura—whether through our website, mobile apps, or any other services we provide (collectively, the “Services” or “Aura”)—you agree to the terms of this Privacy Policy. If you do not agree, please do not use our Services.

2. Scope

This Privacy Policy applies to personal information processed in connection with the Services. It does not apply to third-party websites or services that we do not control, even if they link to, or are accessible from, Aura.

Accessibility: This Privacy Policy is available at playaura.xyz/privacy and can be accessed directly from within the Aura mobile app through Settings > Privacy Policy, as required by Apple App Store guidelines.

3. Information We Collect

3.1 Information You Provide to Us

Account Information

Content and Activity

Communications

3.2 Information We Collect Automatically

Usage Data

Device and Connection Information

Cookies and Similar Technologies

3.3 Prediction Activity Data

4. How We Use Information

We process your information to:

Provide Core Services

Personalize Your Experience

Improve and Develop Our Services

Detecting and Preventing Manipulation

Personalization and Recommendations

Communicate with You

Ensure Safety and Security

Comply with Legal Obligations

If you are in the European Economic Area or United Kingdom, we process your personal data based on:

6. How We Share Information

6.1 Public Information

The following information is public by default:

Private messages, reports, and account settings are never public.

6.2 With Service Providers

We share information with trusted third parties who help us operate:

Important: All service providers are bound by confidentiality agreements and are required to provide the same or equal protection of user data as stated in this Privacy Policy. They can only use your data to provide services to us and must delete or return all personal data upon completion of their services. We regularly audit our service providers to ensure compliance with these requirements, as mandated by Apple App Store guidelines. Service providers may store or process data in the United States or other countries where they operate, subject to appropriate safeguards.

We do not allow service providers to use your personal information to train machine learning models for their own purposes.

We may disclose information when we believe it’s necessary to:

6.4 Business Transfers

If Foundation Labs or the Aura platform is involved in a merger, acquisition, bankruptcy, or sale of assets, your information may be transferred. We will notify you via email and/or prominent notice in our Services before your information is transferred and becomes subject to a different privacy policy.

We may share information for other purposes with your explicit consent.

We never sell your personal information for money.

7. Your Choices and Rights

7.1 Account Controls

You can:

Account Deletion (Required by Apple App Store): You can delete your account at any time directly from within the Aura iOS app by going to Settings > Account > Delete Account, or by contacting us at support@playaura.xyz. When you delete your account:

Because Aura does not collect precise location data, no location-based information is stored or deleted as part of account deletion.

7.2 Privacy Rights

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

To exercise these rights, contact us at support@playaura.xyz.

7.3 Communication Preferences

Disabling marketing push notifications does not affect necessary transactional notifications, which may still be sent for account or platform functionality.

7.4 Do Not Track

We do not currently respond to Do Not Track browser signals.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

Essential Cookies

Functional Cookies

Analytics Cookies

8.2 Managing Cookies

You can control cookies through:

Note: Disabling certain cookies may limit functionality of our Services.

8.3 App Tracking Transparency (iOS)

If we implement features that track you across other companies’ apps or websites, we will request your permission through Apple’s App Tracking Transparency framework. You can change your tracking preferences at any time in your iOS Settings > Privacy > Tracking.

Currently, Aura does not track users across other companies’ apps or websites for advertising or advertising measurement purposes.

9. Data Retention

We retain your personal data only as long as necessary for the purposes outlined in this Policy, unless longer retention is required by law.

Active Accounts: We keep your data while your account is active and you use our Services.

After Account Deletion: We typically delete or anonymize personal data within 30 days, except:

Prediction activity associated with your identity (such as past predictions, accuracy metrics, and Aura transactions) will be deleted or anonymized within the same 30-day window following account deletion.

10. Security

We implement industry-standard safeguards to protect your information:

We use industry-standard encryption to protect data in transit and at rest. While we strive to protect your data, no system is 100% secure. Please use strong passwords and protect your account credentials.

11. International Data Transfers

Foundation Labs is based in the United States. When you use our Services, your information may be transferred to and processed in countries other than your own. These countries may have different data protection laws.

For transfers from the EEA/UK, we rely on:

When transferring data internationally, we ensure an adequate level of protection consistent with the standards of your jurisdiction.

Aura does not engage in automated decision-making that produces legal or similarly significant effects under EEA/UK law.

12. Children’s Privacy

Users under 18 are strictly prohibited from creating an account or using any part of the Aura platform.]. We do not knowingly collect personal information from anyone under 18 years of age. If we learn that we have collected information from someone under 18, we will delete it promptly. If you believe we have information from or about anyone under 18, please contact us at support@playaura.xyz.

13. California Privacy Rights

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Right to Know: You can request information about:

Right to Delete: Request deletion of your personal information, subject to certain exceptions.

Right to Opt-Out: We do not sell personal information, but you can opt out of certain sharing.

Non-Discrimination: We will not discriminate against you for exercising your privacy rights.

To exercise these rights, contact us at support@playaura.xyz or visit our Privacy Center. We do not sell or share personal information for cross-context behavioral advertising as defined under California law.

Aura does not ‘share’ personal information for cross-context behavioral advertising as defined under California law.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you by:

The “Last Updated” date at the top shows when this Policy was last revised. Continued use of our Services after changes means you accept the updated Policy.

If changes materially reduce your privacy rights, we will notify you before the updated policy takes effect.

15. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us: support@playaura.xyz

For privacy-specific inquiries, you may also email: privacy@playaura.xyz

If we appoint a Data Protection Officer (DPO) in the future, we will update this Policy with their contact information.

Your Privacy Matters

At Aura, we believe that prediction markets should be fun, social, and safe. We’re committed to protecting your privacy while creating the best possible experience for our community. Thank you for trusting us with your information.