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Draft prepared by the PANDA team, not by a lawyer — treat this as a good-faith starting point, not final legal advice, until it's reviewed by qualified counsel in the relevant jurisdiction.
PANDA is a software interface for interacting with public, permissionless Solana programs: Pump.fun's bonding curve, PumpSwap and, for other coins, Solana DEXes through Jupiter's aggregator. For buying, selling and creating coins PANDA never holds your funds, private keys or seed phrase: each of those transactions is built unsigned and only becomes real once you review and sign it in your own wallet (for example Phantom or Solflare).
Coins created through PANDA are created by their users through Pump.fun's public program. PANDA does not issue, endorse or guarantee any coin created or traded through it, including $PANDA.
Market and pool data shown in the app comes from Pump.fun's public API, Dexscreener and GeckoTerminal — independent third parties that index public Solana activity — swap quotes come from Jupiter, and the risk indicator on each coin comes from RugCheck (rugcheck.xyz), also a third party. PANDA sets aside coins whose data looks unreliable (for example a huge market cap on almost no liquidity); that is a data-quality filter, not a judgment on any coin.
Stop Loss / Take Profit orders and Draw Your Trade strategies are custodial. They are built on Jupiter's Trigger API, which moves the deposited tokens into a vault managed by Jupiter and held by Privy until the order or strategy fills or is cancelled. PANDA has no keys and no access to that vault and cannot move or withdraw the funds; only you can take them out, by signing the cancellation in your wallet. It is still a genuine exception to PANDA's otherwise non-custodial design, and the app says so before any deposit.
Holder rewards are the one feature in which PANDA itself briefly holds funds, only in transit. If a coin's creator assigns part of its creator fees to "Holders", those fees are paid on-chain to PANDA's Rewards Pool wallet (whose key is held by PANDA's servers), and sent straight on to the coin's holders, in SOL and in proportion to what each one holds, automatically — nothing to claim, no signature needed from a holder's wallet. A coin's own Holders share only pays out once it has built up at least 0.1 SOL; below that it simply waits in the Rewards Pool wallet for the next collection to add to it.
