Unchained — Cryptocurrency Intelligence Platform
Version: 1.0 | Effective Date: May 21, 2026 | Operator: JolleyTech, LLC
Contact: jolleytech+unchainedlegal@gmail.com
This brief describes how Unchained classifies, constrains, and logs its AI-generated outputs, and how it handles applicable obligations under the EU Markets in Crypto-Assets Regulation (MiCA), the General Data Protection Regulation (GDPR), and the U.S. Securities Exchange Act and Investment Advisers Act. It is a living document and will be updated as regulatory guidance matures.
Unchained is a cryptocurrency monitoring and intelligence platform. It watches on-chain events (large transfers, smart-contract activity, price movements) and delivers alerts, market briefings, and contextual AI explanations to subscribers. The platform does not execute trades, hold custody of assets, or manage money on behalf of users.
GET /api/v1/ai/briefing.GET /api/v1/ai/sentiment.GET /api/v1/explain.GET /api/v1/macro/dashboard and GET /api/v1/macro/analysis.All AI outputs pass through a shared CompliancePrompt system fragment (see §4) before being sent to the language model. No AI feature executes or recommends specific trades.
MiCA Article 88 requires that marketing communications relating to crypto-assets or crypto-asset services be clearly identifiable as such, fair, clear, and not misleading. Our AI briefings and alert explanations could be read as "marketing communications" if they promote a particular asset in a way that could influence a purchasing decision.
Unchained's AI outputs are informational, not promotional. Specifically:
CompliancePrompt enforces these constraints at the model level.CompliancePrompt.COMPLIANCE_SYSTEM_PROMPT fragment, which prohibits buy/sell recommendations, price targets, urgency language, and implied guarantees.MiCA enforcement timelines for AI-generated content are still being clarified by ESMA. We will monitor ESMA Q&A publications and update this section when authoritative guidance is issued. If Unchained were ever found to constitute a "crypto-asset service" under MiCA Title V, we would register with the competent national authority.
GDPR Article 22 restricts automated decisions that "produce legal effects" or "similarly significantly affect" the data subject. A significant effect is something like denial of credit, employment, or insurance — not receiving a market briefing.
Unchained's AI outputs do not produce legal effects or significantly affect users. No access to the platform, pricing tier, or service entitlement is determined by AI output. Therefore, Article 22 restrictions do not apply to our current feature set.
Unchained does not build personal behavioural profiles for automated scoring or segmentation purposes. Alert configurations, watchlist preferences, and push-notification device tokens are used solely to deliver the service the user configured.
| Right | How We Honour It |
|---|---|
| Access (Art. 15) | Users can export their alert configurations and watchlist via account settings. AI-generated briefings are not personalised; they are shared across all users. |
| Rectification (Art. 16) | Users can update email, device names, and preferences in-app. |
| Erasure (Art. 17) | Deletion requests enter a 30-day grace period (cancellable in-app). After the grace period, AccountDeletionService.purgeExpiredAccounts() scrubs personal data (email, device tokens) via markDeleted, deletes user agreements, and removes the Keycloak account. Alert configs and watchlist entries cascade-delete with the user row. AI briefing narratives contain no PII and are retained for audit and reproducibility. |
| Portability (Art. 20) | Alert and watchlist data is available in structured JSON via the API. |
| Objection (Art. 21) | Users may disable AI features in-app. Doing so stops AI processing of their alert events. |
AI inputs (on-chain event data, aggregated market metrics) contain no PII. AI outputs (briefing narratives) are stored in the ai_briefing_narratives and alert_explanations tables for auditing and reproducibility. These records are associated with a timestamp and model version but not with individual user identifiers. A time-bounded retention policy for these tables is planned; current status tracked in UNC-124.
The Investment Advisers Act defines an "investment adviser" as any person who, for compensation, engages in the business of advising others on the value of securities or on investing in securities. §202(a)(11) excludes, among others, publishers of bona fide newspapers, news magazines, or business or financial publications of general and regular circulation.
Unchained's AI briefings are analogous to financial news publications: they report on market conditions and on-chain events using data aggregated from public blockchains. They are distributed to all subscribers equally (not tailored to individual financial positions), and they do not advise on whether a particular person should buy or sell a particular security.
The SEC's position on which crypto-assets are securities remains unsettled. Unchained monitors Ethereum, Polygon, Arbitrum, Optimism, and Base events. If a monitored asset is reclassified as a security and our analysis of it is deemed advisory, we will promptly review our carve-out position and, if necessary, cease covering that asset or register as an investment adviser.
| Control | Location | Status |
|---|---|---|
| Compliance system prompt | unchained-common/.../ai/CompliancePrompt.kt |
Live — wired into all LLM call sites |
| Prompt injection mitigation | unchained-common/.../ai/PromptSanitizer.kt |
Live — wired alongside CompliancePrompt |
| AI output logging | DB tables: ai_briefing_narratives, alert_explanations, market_regime_analysis |
Live — retention policy planned (UNC-124) |
| In-app disclaimer | Unchained UI — all AI screens | Live |
| Account deletion (GDPR Art. 17) | Account settings flow | Live |
| No personalised AI advice | Architecture — briefings are shared across all users | Live |
| ESMA/SEC monitoring | This document — reviewed quarterly | Manual |
This document is an internal compliance posture statement. It is not legal advice, and it has not been reviewed by a licensed attorney. JolleyTech, LLC is a small software company, not a licensed financial institution or crypto-asset service provider. If you are a regulator or legal professional with questions or concerns, contact us at jolleytech+unchainedlegal@gmail.com.
| Version | Date | Notes |
|---|---|---|
| 1.0 | 2026-05-21 | Initial publication |
| 1.1 | 2026-05-22 | Fix API paths (§1); correct account-deletion prose and add 30-day grace period (§3.3); soften retention claim pending purge job (§3.4) |