About

Transaction fee

Cartel Family charges a 0.8% transaction fee on every buy and every sell, each calculated on the amount of that individual swap — not on the trade's profit. So a full round-trip (buy + sell) pays 0.8% twice, 1.6% total.

The amount you enter is the most that leaves your wallet. The fee, the network fee and the slippage reserve all come out of it, and what remains is what buys the token — so the figure on the buy panel is what you spend, not a figure other costs are added to. The breakdown on that panel shows each of those lines before you confirm.

The sell-side fee applies whether that trade closes at a profit, a loss, or break-even. Open (not-yet-closed) positions only pay the buy-side fee until they're closed.

The smallest buy is $2 on every chain except Ethereum ($25, because its network gas can eat a smaller order). The trade sheet says so under the amount and refuses a smaller buy rather than losing most of it to gas. Sells have no floor: you can always close a position, however small.

Network fees

Every on-chain trade also pays the network and swap-routing fees of the chain it happens on, set by that network and that route, not by Cartel Family. They apply on every trade, profitable or not, and they differ per chain — a Base trade costs cents, a BNB Chain trade a little more.

You never have to hold a chain's own gas token to trade on it. Cartel Family puts up the native token needed for the transaction and recovers it from that trade's own quote, where you can see it as a line before you confirm. It is charged to you, not subsidised — what Cartel Family provides is the token, not the money.

Your wallet & keys

Cartel Family never has access to your seed phrase — that stays in your own Phantom/Solflare wallet app. The bot instead trades through a separate, server-generated trading wallet. That trading wallet's private key is encrypted twice before it's ever stored: once with a server-held encryption key, and again with a second key derived from your own wallet address. Both layers are required to recover a usable key, so a database leak alone is not enough to expose it. The key is only decrypted momentarily, in memory, at the exact moment a trade is signed.

Session security

Wallet connections use Sign-In With Solana, with a fresh, server-issued, single-use nonce for every login — nothing about your session can be replayed. A remembered device session lets you return without reconnecting your wallet after every app restart.

Trade safety checks

Before entering a position, the bot validates a token's mint and freeze authority and runs a rug-pull risk check (liquidity, volume, and known scam patterns). These checks reduce exposure to obviously unsafe tokens, but no automated check can eliminate risk entirely — always trade with funds you can afford to lose.

What this doesn't protect against

Security here is about protecting your keys and session — it can't protect you from a token itself losing value, from market volatility, or from a signed transaction you approved yourself. Only fund your trading wallet with what you're willing to actively trade with.

Cartel Family is a social trading platform for meme coins across Solana, BNB Chain, Base, Arbitrum, Polygon, Robinhood Chain, Ethereum, Monad and HyperEVM. Connect a dedicated wallet, follow traders you trust, and let a rules-based bot execute your strategy automatically — or trade manually whenever you want full control.

To fund the bot, send SOL (or your chain's own coin) — the bot trades with it. The Auto Bot page works out how much to send and shows the address. USDC works too: a buy pays with USDC when it covers the trade and with your SOL when it does not. Moving funds to whichever chain a trade needs is handled for you.

How it works

1. Join. One screen: sign in with Telegram, X or Google (each offered only where this deployment can complete it), or connect a wallet — Phantom or Solflare on Solana, MetaMask or any EVM wallet, a passkey, or a trading wallet generated in your own browser. Cartel Family then generates a separate, dedicated trading wallet for your bot and manual trades — this is not the same wallet you sign in with, and your seed phrase never leaves your own wallet app. The same account signs you into the developer dashboard, handed over by a one-time code.
2. Set your rules. Choose a breakout trigger, take profit, stop loss, and how many positions the bot can hold at once.
3. The bot scans the market. It continuously checks live tokens on every supported chain against your rules, runs basic safety checks (mint/freeze authority, rug-pull signals) before entering, and exits automatically when your take-profit or stop-loss is hit.
4. Follow the social layer. See a live feed of trades and posts from traders you follow, message them directly, and optionally copy their trades at your own position size.

What you can do

• Automate entries and exits with your own breakout / TP / SL rules
• Trade manually in Live Market using the same live token data the bot sees. The smallest buy is $2 (Ethereum $25); sells are never floored
• Trade tokens still on four.meme, Flap or Pons bonding curves (BNB Chain and Robinhood Chain) right here, in the same sheet: the buy pays in the chain's own coin, the sheet shows the launchpad's fee and Cartel Family's separately, and our fee travels inside the same transaction as the curve trade through the Cartel fee router, so the two land or fail together. Where the router has no active route for a launchpad on a chain yet, that row says "Trades on the launchpad until it graduates" (for example "Trades on Flap") and links there instead of showing a dead button; once a token graduates it trades like any other
• Ask about Cartel Family: the assistant at the corner of this page and on the docs site (docs.cartel.family) answers from these pages, the developer docs and the blog, with a citation on every passage it used and live platform figures taken from the public endpoints at the moment you ask. It never gives financial advice, and when no summary is available it shows the matching passages instead of guessing
• Follow other traders and copy their trades in real time
• Track a live feed of trades and posts from people you follow
• See launches as they happen: a token launched on Cartel Family arrives in the feed as a card naming who launched it, how far its bonding curve is from graduating and which members are already in, with Buy one tap away. When it graduates (to Meteora DAMM v2, or to DeepSwap for a DEEP launch) that is a card too, and everyone holding it, and its creator, is notified
• Launch a token on the venue you choose: a Meteora bonding curve, or DEEP's curve with an optional creator reward on every trade. Each option shows its real fees before you sign; DEEP tokens trade right here on their curve and, after graduation, on DeepSwap, and a DEEP token's page and the search read its curve or pool directly when the market feeds know nothing about it yet. On Base, Robinhood Chain and BNB Chain you can also launch on Peddles: you pick the trading tax (1% to 10%) and how much of it above the first 1% you keep, fixed forever in the launch transaction, with an optional first buy in the same transaction. Peddles' own launch fee is shown as theirs, read from its contract; Cartel Family charges no launch fee there. A Peddles token is a live pool from its first block, so there is no curve and no graduation
• Chat directly with other traders, share images and trade cards. In any post, reply, family post or comment, @handle links to the member, $TICKER links to the token (only when exactly one token answers to it — otherwise to the market search), and a pasted contract address or link becomes a link too; the composer suggests handles and tokens as you type @ or $, and a mentioned member is notified
• Find help from wherever you are: the "?" in the top bar and the foot of the rail on the web, the help sheet in the Telegram Mini App and the Account tab in the phone app all open the same list — Docs, Developers, Blog and Status where they exist, Ask about Cartel Family, and What's new
• Use the Telegram bot: /start shows a short animated banner with the live figures (the chains, the traders in, the fee) and the main keyboard; paste any contract address for an instant token card with Buy, and open the Mini App — the same product, in Telegram
• Earn a family rank (Associate, Soldier, Capo, Underboss, Boss) and badges from what you actually do: a trade closed in profit, a call that runs 2x or more, followers, members copying you, a launch that graduates, a family you built. Losses, trade size and volume never count, and nothing rewards trading every day. Each week is a season, with a members' race and a family league on the Leaderboard. Ranks and badges are cosmetic: no money, no fee discount
• Share any token, trade or P&L card to X, Telegram or WhatsApp from one Share button. Every link carries your referral code, so anyone who joins through it counts as yours
• Set a price alert on any token, on any chain, from the bell on its page: above a price, below one, or a move of N%. It arrives in your inbox and on the channel you have — the phone app, Telegram or browser push, in that order — with buttons straight back to the token
• Choose, per kind of notice, which of the phone app, Telegram and browser push may deliver it, in Settings. An ordinary notice goes to one channel and moves on to the next only if you have not read it; a stop-loss, a take-profit, a bot exit, a send or a security event about your account reaches every channel you allow at once. Quiet hours in your own time zone hold ordinary notices into one digest, and a daily cap keeps the rest in your inbox
• Buy on any chain from whatever you hold: if the USDC is on another chain, or what you hold is SOL, the trade sheet bridges it first and buys when it lands. The bridge fee comes out of the amount you set, never on top
• Bridge SOL, ETH, BNB, POL, MON, HYPE or USDC between Solana and every EVM chain we trade, Robinhood Chain, Ethereum, Monad and HyperEVM included, from the Wallet's Bridge sheet. Routes go through Relay; Cartel Family takes 0.25% of a bridge, and the review shows that fee, the route's own cost, the minimum you receive and the time it takes before you confirm
• Join a Family: a room per token where the people in the trade talk to each other, with its own moderators
• Block or report any member from a thread, a profile or a family; the team reads every report
• Connect your X account in Settings to post your own trade cards there in one tap

Getting started with the bot

1. Join: sign in with Telegram, X or Google, or connect a wallet (Phantom, Solflare, MetaMask or any EVM wallet) — use one that isn't holding your main savings.
2. Fund your dedicated trading wallet (shown on the Portfolio page) with USDC — that is what every trade spends, on every chain. The quickest way is Receive → Fund from wallet: the wallet you signed in with pays the trading wallet in one tap, signed in your own wallet. Network fees are handled for you; you do not need to hold the gas token of each chain. The bot starts once the wallet holds at least the minimum deposit the Deposit sheet shows.
3. Under Bot Settings, set:
   • Breakout Trigger — the minimum price move that qualifies a token as an entry candidate.
   • Take Profit / Stop Loss — the % gain or loss at which the bot automatically closes a position.
   • Max Concurrent Positions — how many tokens the bot can hold open at the same time.
4. Toggle Auto Trading on when you're ready. You can pause it at any time — open positions stay open and are still managed by your TP/SL rules while paused.

How the bot decides to trade

The bot scans the live market for tokens moving past your configured breakout threshold, checks mint/freeze authority and runs a rug-pull check before entering. It exits a position automatically once your take profit or stop loss is reached — no manual action needed.

Live Market

Live Market shows the same real-time, scored token list the bot scans — price change, volume, and risk signals for each token — across all nine chains, balanced so no chain crowds out the others, with a chip per chain to narrow the list. The Majors tab lists each chain's large tokens (SOL, ETH, BTC, BNB, POL and the top DeFi and meme assets) with the same one-tap trade. The Launches tab opens on Running: the launches that clear a quality bar (liquidity, 24-hour volume, age and holders; the bar itself is printed on the tab, and a token still on its curve needs real curve progress and distinct buyers in the last hour instead of liquidity). New (all) shows everything that launched, with clone names folded into the first; Hot and Near graduation keep their meaning. Each row names who launched it, how far its bonding curve is from graduating, liquidity, volume, holders and age (a figure nobody publishes is "—", never a guess), its market cap and how many members here hold it, with Buy and Copy the creator one tap away. Where the market feed carries nothing yet — a Peddles pool, a DeepCore pool, a DEEP curve before it graduates — the figures come from that venue's own sources and the row says which. It also lists new tokens from four.meme and Flap (BNB Chain) and from Flap and Pons (Robinhood Chain), read straight from their contracts; pick All, Ours or one launchpad, and a chain. A token still on one of those bonding curves trades here through the Cartel fee router on BNB Chain and Robinhood Chain (see "What you can do"); where the router has no active route for that launchpad yet, its row links to the launchpad; once it graduates it trades here like any other token. Every token on Peddles (Base, Robinhood Chain, BNB Chain) is listed under the Peddles filter, whoever launched it, and trades here in place from the first block: Peddles pays Cartel Family's trading fee inside the same transaction as the swap, so there is nothing extra to approve for a buy. Fresh launches also appear in Discover. Every row's chart moves with the live price. Tap a token to open the quick trade panel and buy or sell manually, at any time, independent of whether Auto Trading is on.

Wallet

The Portfolio page shows your dedicated trading wallet — a separate address from the one you connected with (the Auto Bot page shows the same wallet as its bot wallet). Send SOL (or the chain's own coin) to fund trading — the bot trades with it; USDC works too — and send it back to your own wallet at any time from the same page. Receive has a Fund from wallet tab: the wallet you signed in with (Phantom, Solflare, MetaMask) pays your trading wallet in one tap — SOL or USDC on Solana, the chain's coin or USDC on any EVM chain — signed in your own wallet, with the destination shown in full first; it shows as arrived once the chain confirms it, and appears in History as "from your wallet". Send works on every chain, for both USDC and the chain's own coin (SOL, ETH, BNB, POL, MON, HYPE), the same way on the web, in the phone app and in the Telegram Mini App: pick the chain and the asset, or tap Max, and the confirmation names the exact amount, network and address before anything is signed. Sending the chain's own coin leaves its network fee behind; sending USDC pays the fee in the chain's coin. At most three sends an hour leave an account. Keeping trading funds in this dedicated wallet (rather than your main wallet) limits what the bot can ever touch.

One coin is enough. A buy pays with USDC when your USDC covers it, and otherwise with the coin you hold — SOL on Solana, or the chain's own coin on an EVM chain, paid directly in one transaction with the platform fee taken in that coin — always keeping a little back for network fees. The trade sheet lets you choose: pay with USDC or with ETH (BNB, POL, MON, HYPE on their chains), and a sell can pay out in either. A trade on a chain where your balance is not yet sitting will bridge it there first and then complete on its own — you do not have to move anything by hand.

Copy trading

Enable copy trading on a trader's profile to automatically mirror their entries at your own configured position size. Your own TP/SL rules still apply to copied positions — copy trading only mirrors entries, not their exit timing.

Copy any wallet

You can also copy an on-chain wallet that is not a member here — a trader on fomo or any other app. Paste its address on Traders (or open /w/ followed by the address): from that moment we read its swaps from the chain, show its record (realised P&L per closed round trip, win rate, trades per day, what it holds) and mirror its buys into your wallet at your size, through the same copy engine and fee as a member's copy. The record starts when someone here began watching; nothing earlier is claimed. The badge ("trades on fomo") is detected from the wallet's on-chain routes, is not an affiliation, and no username is ever attached unless the wallet's owner proves it by signature. A buy that lands more than 30 seconds (Solana) or 60 seconds (EVM) before we see it is skipped and shown to you as missed — never copied at a stale price. Where it is switched off, the pages say so and offer nothing.

Last updated: September 2026
Controller: Gully Labs LLC, doing business as Cartel.Family, Seattle, Washington, United States.
Contact: see the Contact section below.

This policy explains what Gully Labs LLC collects when you use Cartel Family, why, who else sees it, and what you can ask us to do about it. It covers the website, the mobile apps and the Telegram bot and Mini App.

1. What we collect

Because you connected a wallet

• Your public wallet address or addresses, on every chain you use.
• The signature you produce to prove you control that wallet, and the one-time challenge it signed.
• The private key of the trading wallet we generate for you, stored encrypted. See section 4 — this is the most sensitive thing we hold and it is held deliberately.

Because you used the product

• Trades: token, chain, size, entry and exit price, realised profit and loss, timestamps, and whether the trade came from you, from the bot, or from copying somebody.
• Open positions and balances read from chains.
• Your settings: take-profit, stop-loss, position size, daily loss limit, and who you copy.
• Usage analytics, on our own analytics server (not a third party's): which pages are opened and a handful of named events (a sign-in completed, a trade done, a copy switched on, a share, a launch) with the surface they happened on. It sets no cookie, it is never sent a wallet, handle, address or amount, and a browser that sends Do Not Track is not tracked at all.
• Social activity: your username, profile picture, bio, posts, replies, likes, comments, token-thread messages, follows, families you join, calls you publish, and direct messages you send through the product.
• Referral relationships and any referral balance.

Because you connected another account

• Telegram: your Telegram user id, username, display name and language, taken from the signed initData Telegram provides when you open the Mini App, and the chat id of any conversation you have with the bot.
• X (Twitter): if you link it, your handle and an access token, stored encrypted, used only for the sharing you ask for.

Because the service has to run safely

• Session identifiers, device identifiers, and passkey credential identifiers where you register one.
• IP address and user agent, for rate limiting, abuse prevention and security logging.
• Security events: sign-ins, key access for trade execution, withdrawal attempts, and failures of either.

What we never ask for and never want: a seed phrase or recovery phrase. Nobody at Cartel Family will ever ask you for one. Anyone who does is stealing from you.

2. Why we process it, and on what basis

Purpose	Basis (GDPR/UK GDPR)
Operating your account, executing trades you or your bot initiate, running copy-trading you enabled	Performance of a contract
Publishing your trading record, username and social activity to other users	Performance of a contract — the product is social trading, and a published record is how copying works
Security, rate limiting, fraud and abuse prevention, audit logging	Legitimate interests
Fee collection, accounting and reconciliation	Legal obligation and legitimate interests
Responding to you when you contact us	Legitimate interests

3. What other people can see

Cartel Family is a social trading product, so some of what you do is public by design and you should decide accordingly.

Public to anyone, signed in or not: your username, profile picture, bio, abbreviated wallet address, closed trades, realised profit and loss, win rate, number of copiers, published calls, posts, comments and token-thread messages, and your position in any ranking.

Not public: your balances, your open positions, your bot settings, your direct messages, your email or contact details if you give them, and your full private key — which is never shown to anyone, including you, except through the explicit export flow.

Separately, everything that happens on a blockchain is public on that blockchain to everybody, forever, whether or not you use this product.

4. The trading wallet key

Gully Labs LLC generates a trading wallet for you and stores its private key, encrypted, on our servers. The key is decrypted server-side at the moment a trade is signed, and every such access is written to a security log. It is encrypted twice: once under a service-wide key held in the deployment environment, and again under a key derived from your own wallet address.

We hold it because the auto-trading bot and copy-trading cannot work otherwise — neither can wait for a human to approve each signature. That is a deliberate trade of custody for automation, and you should know you are making it. If you do not want it, do not fund the trading wallet and do not enable the bot or copy-trading; the rest of the product works without either.

5. Who we share it with

We do not sell personal information, and we do not share it for cross-context behavioural advertising.

• Blockchain networks. A transaction is broadcast publicly and permanently. This is not something we can undo.
• Infrastructure and data providers used to run the product — RPC providers, DEX aggregators and market-data services. They receive what a request requires, such as a token address or a wallet address, under their own terms.
• Telegram, where you use the bot or Mini App, under Telegram’s own privacy policy.
• Hosting. Data is stored on servers we operate.
• Law enforcement or regulators, where we are legally required to respond.

6. How long we keep it

• Account, trade and social records: for as long as the account exists, and afterwards where needed for accounting, dispute resolution or a legal obligation.
• Session records: until the session expires or you sign out, which revokes it server-side.
• Security logs: retained for a limited period for abuse investigation.
• Encrypted backups: retained on a rolling schedule and encrypted at rest.

7. Your rights, and the one we cannot give you

Depending on where you live you may have the right to access, correct, delete, restrict or object to our processing of your data, to receive a copy in a portable form, and to withdraw consent where we relied on it. California residents additionally have the rights to know, delete, correct, and to opt out of sale or sharing — we do neither — and not to be discriminated against for exercising them.

What we cannot do is erase a blockchain. Transactions you have made are recorded on public networks that nobody can edit, including us. We can delete your account and the data we hold about you; we cannot remove your on-chain history, and any statement that we could would be false.

To exercise a right, contact us using the details below. We may need to verify control of your wallet — typically by signature — before acting, because a wallet address is the only identity this product has.

8. Security

Sessions are server-side and revoked on sign-out. Private keys are encrypted at rest under two layers. Backups are encrypted. Access to keys for trade execution is logged. You can sign in with a Solana wallet signature, an EVM wallet signature, a passkey you add in Settings (bound to cartel.family), Telegram approval, or a password you set; signing out ends the session on this device, and Settings can end it everywhere.

No system is perfectly secure. If you believe you have found a vulnerability, contact us before disclosing it publicly.

9. Children

Cartel Family is not for anyone under 18. We do not knowingly collect data from children, and we will delete such an account if we learn of one.

10. International users

Gully Labs LLC operates from the United States, so using the service involves transferring your data to the United States. If you are in the EEA or the UK, that is a transfer outside your jurisdiction.

11. Changes

We will update this policy as the product changes and will alter the date at the top. Material changes will be notified in the product.

Risk disclosure

Draft pending legal review. This text was prepared for review by counsel and has not been reviewed. It is not legal advice and should not be relied on as final.

Last updated: September 2026 · Operator: Gully Labs LLC, doing business as Cartel.Family, Seattle, Washington, United States.

Trading digital assets can lose you everything

The assets traded through Cartel Family are volatile, frequently illiquid, and often newly created with no operating history. Prices can move by large percentages within a single block. You should assume that any amount you trade can go to zero, and you should not trade with money you cannot afford to lose entirely.

Nothing here is financial, investment, legal or tax advice

Cartel Family is a tool. Nothing on this platform — not a chart, a ranking, a leaderboard position, a trader’s published record, a “call”, a feed post, a promoted placement or any figure shown anywhere in the product — is a recommendation to buy, sell or hold anything. Gully Labs LLC is not a registered investment adviser, broker-dealer or financial planner, and no communication from the platform or its staff should be treated as personalised advice. Decide for yourself, and get professional advice if you need it.

Past performance is not a prediction

Traders on Cartel Family publish real, server-calculated records: closed trades, realised profit and loss, and win rates. Those figures describe what has already happened. They do not predict what will happen next, and a trader who has been right repeatedly can be wrong on the next trade and on every trade after it. Rankings are ordered by past realised performance and are not an endorsement, a recommendation, or a statement that a trader is suitable for you.

Copy-trading multiplies your exposure, not your edge

When you copy a trader, orders are placed for your account automatically, at a size you set, without you approving each one. You will copy their losses on exactly the same terms as their gains. You may enter at a materially different price than they did because of network latency, liquidity, slippage or the order in which transactions are included in a block. You remain responsible for every position opened in your account, including positions opened by copying somebody else. Traders being copied owe you no duty, make no promises about future results, and can stop, change strategy or trade against their published approach at any time.

The automated trading bot acts without asking you first

If you enable the auto-trading bot, it opens and closes positions according to the rules you configure, at any hour, without further confirmation from you. Take-profit and stop-loss levels are targets, not guarantees: in a fast or illiquid market a position can move past a stop before an exit can be executed, and you can lose more than the stop level implies. Software can fail, an RPC endpoint can go down, a chain can congest, and a price feed can be wrong or stale. You are responsible for the settings you choose and for the trades the bot makes under them.

About the wallets, stated plainly

There are two wallets and the position is different for each.

• Your sign-in wallet — the wallet you connect to prove who you are. Its private key never leaves your device and Cartel Family never receives it.
• Your trading wallet — generated by Cartel Family. Its private key is stored by Gully Labs LLC in encrypted form and is decrypted on our servers in order to sign trades. This is what allows the auto-trading bot and copy-trading to place orders without you signing each one. Assets in that wallet belong to you and can be withdrawn at any time, but while they are there, the ability to move them depends on systems operated by Gully Labs LLC.

You should understand that arrangement before funding the trading wallet. If you would rather not have a third party able to sign for you, do not fund it, and do not enable the bot or copy-trading.

Blockchain transactions are final

Transactions submitted to a blockchain are generally irreversible. There is no chargeback, no cancellation and no support process that can reverse a confirmed transaction — including one sent to a wrong address, one made by mistake, and one made by a bot configured by you.

Risks outside our control

• Smart-contract risk. Tokens and the routers and pools used to trade them are third-party code that may contain bugs or deliberate traps.
• Fraudulent tokens. A token can be created by anyone. Its creator may remove liquidity, mint without limit, block selling, or abandon it. Appearing in our market list, feed or search results is not a safety check and is not a representation that a token is legitimate.
• Network and infrastructure failure. Chains, validators, bridges, RPC providers, price feeds and DEX aggregators are operated by third parties and can fail, halt, fork or return wrong data.
• Regulatory change. The legal treatment of digital assets is unsettled and changing. A token that is tradable today may not be tomorrow, and rules may change in ways that affect your access or your tax position.
• Tax. Trades may create taxable events in your jurisdiction. Reporting and paying tax is your responsibility. We do not provide tax records or advice.

Paid placements are advertising

Some tokens appear in promoted slots because somebody paid for that placement. Those slots are labelled as paid placements wherever they appear. A paid placement is advertising, not an endorsement, not a recommendation and not a due-diligence check, and the fact that a token was promoted tells you nothing about whether it is a good or safe investment.

Fees

Trading fees are stated in the Fees section above and are charged on each leg of a trade. Fees are charged whether the trade is profitable or not, and they apply to trades placed by copy-trading and by the bot in the same way as to trades you place yourself. Network gas is separate and paid to the network, not to us.

Availability

Cartel Family is provided on an “as is” and “as available” basis. We do not guarantee that the service will be uninterrupted, that data will be accurate or current, or that a trade you intend to make will be executable at a particular time or price.

[DECISION REQUIRED — for counsel] Four points a reviewer should resolve before this is published:

• Custody and licensing. Gully Labs LLC holds the private keys of user trading wallets and transmits user digital assets. Under Washington’s Uniform Money Services Act (RCW 19.230) and WA DFI’s virtual-currency guidance this appears to require a money transmitter licence, with a tangible net-worth requirement, a surety bond and like-kind holdings; federally it appears to require FinCEN MSB registration and an AML programme. This needs a determination before real funds are accepted.
• Copy-trading and the bot. Placing discretionary trades for users, and operating a service that mirrors one user’s trades into another’s account, may constitute investment advisory or discretionary management activity.
• Token status. Some assets tradable through the platform may be securities under US law.
• Geographic restrictions. The platform currently restricts no jurisdiction. Whether to block US persons, non-licensed states, or only sanctioned jurisdictions is an open decision and materially changes this document and the Terms.

Terms of use

Draft pending legal review. Prepared for review by counsel; not yet reviewed, and not legal advice.

Operator: Gully Labs LLC, doing business as Cartel.Family, a Washington limited liability company with its principal place of business in Seattle, Washington, United States (“Cartel Family”, “we”, “us”).

1. Agreement

By connecting a wallet, opening an account, or using the website, apps, Telegram bot or Mini App, you agree to these Terms. If you do not agree, do not use the service.

2. Eligibility

You must be at least 18 and legally able to enter a contract. You must not be a person or entity subject to sanctions administered by OFAC or any other applicable authority, nor located in a jurisdiction subject to comprehensive sanctions. You are responsible for whether using this service is lawful where you are.

[DECISION REQUIRED] Whether US persons, or residents of states where the operator is not licensed for money transmission, may use the service is an open question pending the determination in section 4. Until it is answered this clause cannot state a definitive list.

3. What the service is

Cartel Family is a social trading platform. It shows you what other users are trading, lets you copy them, lets you trade yourself, and can run an automated strategy you configure. It operates across Solana and several EVM chains.

We are not a bank, a broker-dealer, an investment adviser, an exchange, or a fiduciary. We give no advice. See the Risk Disclaimer, which forms part of these Terms.

4. Wallets and custody — read this one

There are two wallets and the arrangement differs between them.

Your sign-in wallet is yours. Its private key never leaves your device and we never receive it.

Your trading wallet is generated by us, and we store its private key in encrypted form and decrypt it on our servers to sign trades. This is what lets the automated bot and copy-trading act without you approving each signature. Assets in that wallet are yours and you may withdraw them at any time, but while they are there your ability to move them depends on systems we operate.

You accept that arrangement by funding the trading wallet. If you do not want it, do not fund it and do not enable the bot or copy-trading.

[DECISION REQUIRED] Holding customer private keys and transmitting customer digital assets from Washington State appears to require a money transmitter licence under RCW 19.230 and WA DFI virtual-currency guidance, and FinCEN MSB registration federally. This must be determined before the service accepts funds, and the answer changes sections 2, 5 and 12.

5. Your account and your responsibility

You are responsible for your wallet, your device, your credentials and everything done through your account, including trades placed by the bot under settings you chose and trades placed by copying another user. We cannot reverse a blockchain transaction and will not be able to recover funds sent in error.

Do not use a wallet that holds assets you are not prepared to risk.

6. Fees

We charge a fee on each leg of a trade, at the rate published in the Fees section. Fees apply whether a trade is profitable or not, and apply equally to trades you place, trades placed by copying, and trades placed by the bot. Network gas is paid to the network, not to us. Paid placements are billed separately and are advertising, not endorsement.

We may change fees. Changes take effect prospectively and will be published before they apply.

7. What you may not do

• Break the law, or use the service to launder money, evade sanctions or finance terrorism.
• Manipulate a market, wash trade, or use the platform’s social features to pump a token you are about to sell into.
• Publish a trading record you know to be misleading, or operate accounts to fabricate a track record others may copy.
• Attack, probe, overload, scrape at scale, or attempt to circumvent access controls, rate limits or security measures.
• Impersonate another person, or use another user’s account.
• Post content that is unlawful, abusive, or infringes somebody else’s rights.

We may suspend or terminate an account that does any of this, and may be obliged to report it.

8. Social features and your content

You keep ownership of what you post. You grant us a worldwide, non-exclusive, royalty-free licence to host, display and distribute it within the service so it can be shown to other users. You are responsible for what you publish.

Your closed trades, realised profit and loss, win rate and published calls are visible to other users. That is how copying works and it is not optional while you use the social features.

9. Copy-trading

Copy-trading places orders in your account automatically at a size you set. You may fill at a materially different price than the trader you copy. A trader you copy owes you no duty, gives no assurance, and may change or stop at any time. Every position opened in your account is yours, regardless of what prompted it.

10. Automated trading

If you enable the bot you authorise it to open and close positions according to your configured rules without further confirmation. Take-profit and stop-loss levels are targets and not guarantees; in fast or illiquid markets a position can move past a stop before an exit executes.

11. Third parties

The service depends on blockchains, RPC providers, DEX aggregators, market-data providers, wallet software and Telegram. We do not control them and are not responsible for their acts, omissions, outages or data.

12. Disclaimers and limitation of liability

The service is provided “as is” and “as available”, without warranties of any kind, express or implied, including merchantability, fitness for a particular purpose and non-infringement, to the fullest extent permitted by law.

To the fullest extent permitted by law, Gully Labs LLC will not be liable for indirect, incidental, special, consequential, exemplary or punitive damages, or for lost profits, lost opportunity, or the loss in value of any digital asset, however caused.

[DECISION REQUIRED] A liability cap figure and its interaction with any licensing obligation, and whether a cap is enforceable against Washington consumer-protection claims, need counsel’s input. No figure is stated here because an unenforceable one is worse than none.

13. Indemnity

You agree to indemnify Gully Labs LLC against claims, losses and costs arising from your use of the service, your breach of these Terms, your violation of law, or your infringement of another’s rights.

14. Suspension and termination

You may stop using the service at any time and withdraw your assets. We may suspend or terminate access where we reasonably believe it is necessary to comply with law, to protect users or the service, or where these Terms have been breached. We will not withhold your assets except where legally required to do so.

15. Governing law and disputes

These Terms are governed by the laws of the State of Washington, without regard to conflict-of-laws rules. Any dispute will be resolved by binding individual arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules, seated in King County, Washington. You and Gully Labs LLC each waive any right to a jury trial and to participate in a class action. Either party may bring a qualifying claim in small-claims court instead.

[DECISION REQUIRED] Whether to include an arbitration opt-out window, and how the class-action waiver interacts with Washington consumer-protection law, are for counsel.

16. Changes

We may change these Terms. Material changes require you to accept again before continuing to use the service, and the version you accepted is recorded.

17. Contact

Gully Labs LLC, Seattle, Washington, United States. Contact details are in the Contact section.

For product, account, privacy or security questions, contact Cartel Family through the official channels below.

• Email: [email protected]
• Telegram: @JoinCartelFamily
• X: @carteldotfamily
• Website: cartel.family

For security reports, describe the affected URL or feature and the observed behavior. Do not send private keys, seed phrases, authentication secrets or funds.