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Solana Mobile Device and dApp Store Privacy Policy

Effective as of May 21, 2025

Please click here to view the previous version of our Privacy Policy.

California Notice at Collection/State Law Privacy Rights: See the State privacy rights notice section below for important information about your rights under applicable state privacy laws.

This Privacy Policy describes how Solana Mobile Inc. ("Solana Mobile," "we," “us,” or "our") processes personal information that we collect through our mobile devices (“Solana Mobile Devices”), our decentralized application store (“dApp Store”), and wherever this Privacy Policy is linked (the “Services”).

Solana Mobile may provide additional or supplemental privacy policies to individuals for specific products or services that we offer at the time we collect personal information. For example, for information about how we process personal information that we collect through our website, please visit: https://solanamobile.com/privacy-policy-homepage-web.

This Privacy Policy does not apply to third-party apps made available for download on the dApp Store. We do not control how third-party apps use your personal information. For more information on the privacy practices of third-party app providers, please see their privacy policies. See more in the Other Sites, Services, and Apps section below.

NOTICE TO EUROPEAN USERS: Please see the Notice to European Users section for additional information for individuals located in the European Economic Area, United Kingdom, or Switzerland (which we refer to as “Europe”, and “European” should be understood accordingly) below.

You can print a copy of this Privacy Policy.

Index​

Personal information we collect​

Information you provide to us. Personal information you may provide directly to us through the Service or otherwise includes:

  • Contact data, such as your first and last name, email address, and phone number.

  • Demographic data, such as your time zone and language when provided to us through the dApp Store.

  • Device information, including the serial number of your Solana Mobile Device, device identifier (e.g., IMEI), and authentication tokens that are linked to your Solana Mobile Device.

  • Payment and transactional (including blockchain) data, such as information relating to your orders through the dApp Store, your purchase history on the dApp Store, and your blockchain transaction history.

  • dApp Store interaction history data, including reviews of apps and other information relating to what content and apps you search for, browse, view, download, and update through the dApp Store.

  • Cryptocurrency-related information, including wallet information (such as public key, public wallet address, and wallet name (where applicable)) and of Solana Mobile Device non-fungible token (“NFT”) holdings.

  • Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise, including to troubleshoot issues with your Solana Mobile Device or dApp Store experience or to dispute a transaction on the dApp Store.

  • Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

  • Promotion data, including information or content (such as photos) you share when you enter a competition, promotion, or complete a survey. We may offer promotions for NFT or other giveaways.

  • Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

  • Public sources, such as transaction history from public blockchain(s) and ledgers and other personal information from other publicly available sources.

  • Application Developers, such as usage and earning data from apps you may download and use from the dApp Store.

  • Seed Vault wallet app providers whose applications are included with Solana Mobile Devices, such as blockchain transaction history.

  • Operating system provider, such as Google, which provides the Android operating system for the Solana Mobile Device.

  • Other third parties who you direct to share your personal information with us, such as your mobile phone service provider who may share data about your mobile account to help us provide you with Solana Mobile Device -related services.

Automatic data collection. We, our service providers, or our business partners (including our hardware providers) may automatically log information about you, your Solana Mobile Device, and your interaction over time with the Service, our communications, and other online services, such as:

  • Device usage and activity data about your interaction with and use of the Solana Mobile Device, when you grant us permission to collect this data. Such data may include information about apps you install and download; information about app launches and crashes; product interaction (e.g., touch interaction data and how long you use an app); Seed Vault events (but excluding seed usage events, your seed phrase, public keys and private keys); performance and other diagnostic data; and other Solana Mobile Device usage and activity data. For more information about how to opt out of our collection of certain Device Usage and Activity Data, please visit the Your Choices section below.

  • dApp Store usage and activity data about your interaction with and use of the dApp Store, including when you open and close the dApp Store, your interactions with dApp Store notifications and messages, and information about dApp Store launches and crashes; performance and other diagnostic data; and other usage and activity data.

  • Location data, including information about nearby Wi-Fi access points and cell towers. If you permit third parties (such as app developers) to collect your location data via the Services, those third parties can process your information according to their privacy policies, see the Other Sites, Services, and apps section below.

  • Device information, such as Solana Mobile Device operating system version, IP address, general location data, and unique device identifiers. Google provides the Android operating system for the Solana Mobile Device and may collect and process personal information related to the Services, as described in the Google Privacy Policy at https://policies.google.com/privacy.

How we use your personal information​

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and operations. We may use your personal information to:

  • provide, operate, and improve the Service and our business;

  • provide you the content you purchase, download, or want to update in the dApp Store;

  • process your transactions through or related to the Services (for example, we may use your personal information to facilitate payment for Solana Mobile Device or to process Solana Mobile Device refund requests);

  • identify and authenticate your access to certain features of the Services (for example, we may use your personal information to authenticate your access to your Solana Mobile Device or transactions through the dApp Store);

  • personalizing the service (for example, we may use personal information collected from the camera to dim the brightness of the screen display if you do not appear to be looking at your Solana Mobile Device);

  • enable security features of the Service, such as by sending you security codes via email or SMS;

  • communicate with you about the Service, including by sending Service-related announcements (such as messages about new content and offers on the dApp Store), updates, security alerts, and support and administrative messages;

  • communicate with you about events or contests in which you participate;

  • understand your needs and interests; and

  • provide support for the Service, such as debugging and repairing errors, and respond to your requests, questions, and feedback.

To create aggregated, de-identified, and/or anonymized data. We may create aggregated, de-identified, and/or anonymized data from the personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified, or otherwise anonymized data and share it with third parties, including app developers, for our lawful business purposes, including to analyze and improve the Service and promote our business. We will not attempt to reidentify any such data except as permitted by law.

Marketing. We and our service providers may collect and use your personal information for marketing purposes. For example, we may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt out of our marketing communications as described in the Communication choices subsection below.

Events, promotions, and contests. We may use your personal information to:

  • administer promotions and contests

  • communicate with you about promotions or contests in which you participate

  • contact or market to you after collecting your personal information at an event

Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which apps are most and least visited and how those apps perform, and develop new products and services.

Compliance and protection. We may use your personal information to:

  • comply with applicable laws, lawful requests, and legal process, such as responding to subpoenas, investigations, or requests from government authorities;

  • protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims);

  • audit our internal processes for compliance with legal and contractual requirements or our internal policies;

  • enforce the terms and conditions that govern the Service; and

  • prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

How we share your personal information​

We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.

Affiliates. Our corporate parent, subsidiaries, and affiliates.

Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as processing or hosting, including personal information, information technology, customer service and support, email delivery, marketing, consumer research, and analytics).

Operating system provider. For example, we may share information about what software is currently running on your Solana Mobile Device for the operating system provider to check if software updates are available.

App developers. Third-party app developers who make their app available in the dApp Store and who develop apps. For example, we may share your personal information (such as information to prove a dApp Store purchase) with app developers so they can provide your purchased content to you. As another example, we may also share your personal information about app crashes and errors, including Solana Mobile Device operating system version, Solana Mobile Device type, and crash logs, with app developers for the purpose of identifying and fixing technical issues within the app.

Seed Vault wallet app providers. Third parties whose wallet applications are included with Solana Mobile Devices.

Business partners. Third parties with whom we co-sponsor events or promotions and with whom we jointly offer products or services.

Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Solana Mobile, financing of Solana Mobile, public stock offerings, or the sale, transfer, or merger of all or part of our business, assets, or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Solana Mobile as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.

Other users and the public. Certain of your personal information may be visible to other users of the Service and the public. For example, members of the public may have access to information published on the blockchain through the Service, such as when we issue you an NFT. As another example, other users of the dApp Store and the public can view your reviews of apps that you submit to the dApp Store. This information can be seen, collected, and used by others, including being cached, copied, screen captured, or stored elsewhere by others, and we are not responsible for any such use of this information.

With your consent. We may share your personal information with others at your direction or with your consent.

Your choices​

In this section, we describe the rights and choices available to all users. Users who are located in California and certain other US states and in Europe can find additional information about their rights below.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

Privacy settings. We make available certain privacy settings on the Service, including options to control the collection of information we and/or our partners use to improve our Services. To access this setting on your Solana Mobile Device, go to Settings > Solana Mobile > Improve our services.

You can also control the collection of usage and diagnostic data by going to Settings >Solana Mobile. If you change your settings after we have initiated a data upload, your new settings will go into effect after that process has been completed. You cannot disable our use of anonymous, de-identified, or aggregated data about crashes and errors for Solana Mobile apps.

Communication choices. If you receive marketing emails from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt-out from receiving marketing emails from us, and any other promotional communications that we may send to you from time to time (e.g., by postal mail) by sending your request to us by email at privacy@solanamobile.com or by writing to us at the address given in the ‘How to contact us’ section of this Privacy Policy.

Please be aware that if you opt out of receiving marketing emails from us, it may take up to ten business days for us to process your opt-out request, and you may receive marketing emails from us during that period. Additionally, even after you opt out of receiving marketing messages from us, you will continue to receive security-related, administrative, and transactional messages from us regarding your use of the Services.

Other sites, services, and apps​

The Service may contain links to websites, mobile applications, and other online services operated by third parties. For example, you can download apps from third-party app developers through the dApp Store. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile apps, or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile apps, and online services you use.

Security​

We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.

International data transfer​

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Users in Europe should read the important information provided below about the transfer of personal information outside of Europe.

Children​

The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us at privacy@solanamobile.com. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.

Changes to this Privacy Policy​

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or by other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgement that the modified Privacy Policy applies to your interactions with the Service and our business.

How to contact us​

● Email: privacy@solanamobile.com

● Mail: 530 Divisadero St. PMB 722 San Francisco, CA 94117

State privacy rights notice​

Except as otherwise provided, this section applies to residents of California and other states to the extent they have privacy laws applicable to us that grant their residents the rights described below (collectively the “State Privacy Laws”).

This section describes how we collect, use, and share Personal Information of residents of these states and the rights these users may have with respect to their Personal Information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.

For purposes of this section, the term “Personal Information” has the meaning given to “personal data”, “personal information” or other similar terms and “Sensitive Personal Information” has the meaning given to “sensitive personal information,” “sensitive data”, or other similar terms in the State Privacy Laws, except that in neither case does such term include information exempted from the scope of the State Privacy Laws. In some cases, we may provide a different privacy notice to certain categories of residents of these states, such as employees or job applicants, in which case that notice will apply instead of this section.

Your privacy rights. The State Privacy Laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and some State Privacy Laws do not provide these rights to their residents. Therefore, we may decline your request in certain cases as permitted by law.

  • Information. You can request the following information about how we have collected and used your Personal Information:

    • The categories of Personal Information that we have collected.

    • The categories of sources from which we collected Personal Information.

    • The business or commercial purpose for collecting and/or selling Personal Information.

    • The categories of third parties with which we share Personal Information.

    • The categories of Personal Information that we sold or disclosed for a business purpose.

    • The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

  • Access. You can request a copy of the Personal Information that we have collected about you.

  • Appeal. You can appeal our denial of any request validly submitted.

  • Correction. You can ask us to correct inaccurate Personal Information that we have collected about you.

  • Deletion. You can ask us to delete the Personal Information that we have collected from you.

  • Opt-out.

    • Opt-out of certain processing for targeted advertising purposes. We do not process your personal information for targeted advertising purposes.

    • Opt-out of profiling/automated decision making. We do not use your Personal Information to engage in profiling or to perform automated decision-making that results in significant financial impacts, significant impacts on housing, education, employment, health care, or criminal justice, or similarly significant impacts.

    • Opt-out of other sales of personal data.  We do not sell your Personal Information within the meaning of State Privacy Laws.

  • Consumers under 16. We do not have actual knowledge that we collect, sell or share the personal information of consumers under 16 years of age.

  • Sensitive Personal Information. While we process certain categories of Sensitive Personal Information as described in this Privacy Policy, we do not process Sensitive Personal Information for the purpose of inferring characteristics about consumers under the California Consumer Privacy Act (“CCPA”).

  • Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to information/know, access, appeal, correction, and deletion. You may submit requests to exercise your right to information/know, access, appeal, correction, or deletion by calling us toll-free at 1 (888) 212-2019, or via email to privacy@solanamobile.com.

Verification of Identity; Authorized agents. We may need to verify your identity in order to process your information/know, access, appeal, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information, where permitted by law.

Under some State Privacy Laws, you many enable an authorized agent to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your State Privacy Laws rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.

Personal information that we collect, use and disclose. We have summarized below the Personal Information and Sensitive Personal Information we collect, the purposes for which we collect it and the third parties to or with whom we may disclose, sell or share it by reference below to both the categories defined in the Personal information we collect section of this Privacy Policy above and the categories of Personal Information and Sensitive Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). The categories of Personal Information and Sensitive Personal Information described below may be collected via any of the sources described in the Personal information we collect section of this Privacy Policy above. The summary below describes our practices currently and during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below.

  • Personal Information (“PI”) we collect:
    • Contact data
      • CCPA statutory category: Identifiers
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Seed Vault wallet app providers; Business partners; Professional advisors; Authorities and others; Business transferees
    • Demographic data
      • CCPA statutory category: Identifiers
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Business partners; Professional advisors; Authorities and others; Business transferees
    • Payment and transactional (including blockchain) data
      • CCPA statutory category: Commercial information
      • Business/commercial purpose for SPI collection: Service delivery and operations; Research & development; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Seed Vault wallet app providers; Authorities and others
    • Device information
      • CCPA statutory category: Identifiers; Commercial information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Operating system provider; App developers; Seed Vault wallet app providers; Authorities and others; Business transferees
    • dApp Store interaction history data
      • CCPA statutory category: Identifiers; Commercial information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Business partners; Authorities and others; Business transferees; Other users and the public
    • Cryptocurrency-related information
      • CCPA statutory category: Commercial information; financial information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Seed Vault wallet app providers; Authorities and others; Business transferees
    • Communications data
      • CCPA statutory category: Identifiers; Commercial information; Internet or Network Information
      • Business/commercial purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Business partners; Professional advisors; Authorities and others; Business transferees; Seed Vault wallet app providers Other users and the public
    • Marketing data
      • CCPA statutory category: Identifiers; Commercial information; Internet or Network Information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Business partners; Authorities and others; Business transferees
    • Promotion data
      • CCPA statutory category: Identifiers; Commercial information; Internet or Network Information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Business partners; Professional advisors; Authorities and others; Business transferees; Other users and the public
    • Device usage and activity data
      • CCPA statutory category: Identifiers (other); Internet or Network Information
      • Purpose for PI collection: Service delivery and operations; Marketing; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; App developers; Seed Vault wallet app providers; Professional advisors; Authorities and others; Business transferees
    • dApp Store usage and activity data
      • CCPA statutory category: Identifiers (other); Internet or Network Information
      • Purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Professional advisors; Authorities and others; Business transferees
    • Operating system information
      • CCPA statutory category: Identifiers
      • Business/commercial purpose for PI collection: Service delivery and operations; Marketing; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Service providers; Operating system provider; App developers; Business partners; Professional advisors; Authorities and others; Business transferees
    • Data derived from the above
      • CCPA statutory category: Inferences
      • Business/commercial purpose for PI collection: Service delivery and operations; Marketing; Events, promotions, and contests; Service improvement and analytics; Compliance & protection
      • Categories of third parties to whom we “disclose” PI for a business purpose: Affiliates; Business partners; Professional advisors; Authorities and others; Business transferees

Your personal information, including your sensitive personal information, may also be disclosed to third parties at your request or with your consent, to third parties in connection with a business transaction, and/or to law enforcement, regulators and other third parties for legal reasons.

Additional information for California residents.

Shine the light law. Under California’s Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to provide the names of third parties to which they have disclosed certain personal information (as defined under the Shine the Light law) during the preceding calendar year for their own direct marketing purposes, and the categories of personal information disclosed. You may send us requests for this information to privacy@solanamobile.com. In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we will not accept requests via telephone, mail, or facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.

Additional information for Nevada residents. Nevada residents have the right to opt-out of the sale of certain personal information for monetary consideration. While we do not currently engage in such sales, if you are a Nevada resident and would like to make a request to opt out of any potential future sales, please email privacy@solanamobile.com.

Contact Us. If you have questions or concerns about our privacy policies or information practices, please contact us at privacy@solanamobile.com.

Notice to European users​

General​

Where this Notice to European users applies. The information provided in this “Notice to European users” section applies only to individuals in Europe.

Personal information. References to “personal information” in this Privacy Policy should be understood to include a reference to “personal data” governed by European data protection legislation, including the “GDPR” (i.e., the General Data Protection Regulation 2016/679 (“EU GDPR”), the EU GDPR as it forms part of UK law (“UK GDPR”), and the Swiss FADP – i.e., information about individuals from which they are either directly identified or can be identified.

Controller. For the purposes of European data protection legislation, Solana Mobile is the data controller (i.e., the company that is responsible for and controls the processing of your personal information).

Our GDPR Representatives.

  • If you are located in the European Union: we have appointed the European Data Protection Office (EDPO) as our GDPR Representative in the EU. You can contact the EDPO regarding matters pertaining to the GDPR by using the EDPO’s online request form: https://edpo.com/gdpr-data-request/, or in writing to the EDPO Avenue Huart Hamoir 71, 1030 Brussels, Belgium.

  • If you are located in the UK: we have appointed EDPO UK Ltd as its UK GDPR representative. You can contact EDPO UK regarding matters pertaining to the UK GDPR by using EDPO’s online request form: https://edpo.com/uk-gdpr-data-request/, or in writing to the EDPO UK at 8 Northumberland Avenue, London WC2N 5BY, United Kingdom.

In respect of each of the purposes for which we use your personal information, the GDPR requires us to ensure that we have a “legal basis” for that use.

Our legal bases for processing your personal information described in this Privacy Policy are listed below.

  • Where we need to perform a contract, we are about to enter into or have entered into with you (“Contractual Necessity”).
  • Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More details about the specific legitimate interests pursued with respect to each purpose we use your personal information for are set out in the table below.
  • Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
  • Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).

We have set out below the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these purposes and the data types involved, see ‘How we use your personal information.’

Categories of personal informationLegal basis
Service delivery and operations
Contact data Demographic data Device serial number data Payment and transactional (including blockchain) data Cryptocurrency-related informationContractual Necessity
Location dataConsent
dApp Store interaction history data dApp Store usage data Communications data Solana Mobile Device usage dataLegitimate Interests. We have a legitimate interest in understanding your use of the Services in order to maintain a reliable and secure service and ensure the correct operation of associated IT services, systems, and networks. Consent
To create aggregated, de-identified, and/or anonymized data
Any and all data types relevant to the circumstancesLegitimate Interests. We may aggregate, de-identify, or otherwise anonymize data for research and development purposes. We have a legitimate interest in analyzing the use of our Services on an aggregated, de-identified, or otherwise anonymized basis.
Marketing
Contact data Demographic data Registration data Payment and transactional (including blockchain) data Marketing dataLegitimate Interests. We have a legitimate interest in marketing our Services, including sending marketing communications where you have agreed to receive them or where you had previously contacted us. Consent. In circumstances or in jurisdictions where consent is required under applicable data protection laws for sending marketing communications.
Events, promotions and contests
Contact data Demographic data Device serial number data Marketing data Promotion dataContractual Necessity to administer the promotions and contests in accordance with the terms or rules thereof (including communicating with you as and where necessary) In respect of promoting these promotions and contests: Legitimate Interests – we have a legitimate interest in promoting these promotions and contests, including associated publicizing of our business and operations. Consent – in circumstances or in jurisdictions where consent is required under applicable data protection laws for sending promotional communications.
Service improvement and analytics
Contact data Demographic data Device serial number data Cryptocurrency-related information Communications data Solana Mobile Device usage data dApp Store interaction history data Location dataLegitimate Interests. We have a legitimate interest in understanding how you use the Services in order to develop and improve the Services Consent, where required under applicable laws
Compliance and protection
Any and all data types relevant in the circumstancesCompliance with Law Legitimate Interests. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through cooperation with authorities. We and any relevant third parties may also have a legitimate interest in ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety.
Further uses
Any and all data types relevant in the circumstancesThe original legal basis relied upon if the relevant further use is compatible with the initial purpose for which the Personal Information was collected. Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.

Retention​

We retain personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information, and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information, we have collected about you, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

Other info​

No sensitive personal information. If you provide any sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) to us when you use the Services, you must consent to our processing and use of such sensitive personal information in accordance with this Privacy Policy. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Services.

No Automated Decision-Making and Profiling. As part of the Service, we do not engage in automated decision-making and/or profiling, which produces legal or similarly significant effects.

Your rights​

General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take the following actions in relation to your personal information that we hold:

  • Access. Provide you with information about our processing of your personal information and give you access to your personal information.

  • Correct. Update or correct inaccuracies in your personal information.

  • Delete. Delete your personal information where there is no good reason for us continuing to process it - you also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).

  • Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.

  • Restrict. Restrict the processing of your personal information, for example, if you want us to establish its accuracy or the reason for processing it.

  • Object. Object to our processing of your personal information where we are relying on Legitimate Interests – you also have the right to object where we are processing your personal information for direct marketing purposes.

  • Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time.

Exercising These Rights. You may submit these requests by email to privacy@solanamobile.com or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part), we will let you know our grounds for doing so at the time, subject to any legal restrictions.

Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make or how we process your personal information, you can file a complaint with the data protection regulator in your habitual place of residence.

  • For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en

    • For users in the UK – the contact information for the UK data protection regulator is below:

      The Information Commissioner’s Office

      Water Lane, Wycliffe House

      Wilmslow - Cheshire SK9 5AF

      Tel. +44 303 123 1113

      Website: https://ico.org.uk/make-a-complaint/

Data Processing outside Europe​

We may share your personal information with third parties who may be based outside of the EEA, Switzerland, and/or UK. In such circumstances, those parties’ processing of your personal information will involve a transfer of your personal information outside of the EEA, Switzerland, and/or UK, where privacy laws may not be as protective as those in your state, province, or country.

You can obtain further information or a copy of or access safeguards under which your personal information is transferred outside of the EEA, Switzerland, and/or UK by contacting us at privacy@solanamobile.com.