• Demographic data
• Device serial number data
• Payment and transactional (including blockchain) data
• Cryptocurrency-related information | **Contractual Necessity** | | • Location data | **Consent** | | • dApp Store interaction history data
• dApp Store usage data
• Communications data
• Solana Mobile Device usage data | • **Legitimate 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 circumstances | **Legitimate 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 data | • **Legitimate 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 data
• dApp Store interaction history data
• dApp Store usage data
• Solana Mobile Device usage data | • **Contractual 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 data | • **Legitimate 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 circumstances | • **Compliance 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 circumstances | • The 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](mailto: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](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/](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](mailto:privacy@solanamobile.com). # Solana Mobile Publisher Policy Source: https://docs.solanamobile.com/dapp-store/publisher-policy This Solana Mobile Publisher Policy (“Publisher Policy”) is part of and subject to the Solana Mobile dApp Store Developer Agreement (“Developer Agreement”). Capitalized words used but not defined herein have the meaning given in the Developer Agreement. By submitting any Developer Asset to Solana Mobile, you acknowledge and agree that such Developer Asset complies with the terms of this Publisher Policy. If you encounter any Developer Asset or other Content in the dApp Store or otherwise via our products and services that does not comply with the terms of this Publisher Policy, you may notify us at [concerns@dappstore.solanamobile.com](mailto:concerns@dappstore.solanamobile.com). We reserve the right, but assume no obligation, to investigate and take any action we deem appropriate. ## Restricted Content Solana Mobile does not allow any Developer Assets, User Content, or text, images, audio content, code, or other content of any sort (“Content”) that Solana Mobile determines in its sole discretion may violate applicable law, rule, or regulation (“Applicable Law”), or the Solana dApp Store mission (“Restricted Content”). Restricted Content includes, without limitation, the following: * **Illegality:** Content that violates or promotes the violation of Applicable Law, including the following: * Content that facilitates or promotes the facilitation of: the consumption of alcohol, tobacco, or other age-restricted products by minors; the purchase or sale of illegal narcotics; or the manufacturing of illegal substances, including narcotics; * Content that depicts, promotes, or encourages the abuse or exploitation of children, including all child sexual abuse materials; and * Content that depicts, promotes, or encourages activity or behavior that is illegal or restricted under Applicable Law, including (as applicable to your jurisdiction) pornography, prostitution, theft, murder, or other violent or offensive acts. * Content that infringes on intellectual property of any third-party. * **Content Adverse to Community:** Content that is antithetical to our community values, including: * Hate speech or speech that threatens, promotes or incites hatred or violence against individuals or groups based on immutable characteristics or other characteristics associated with systemic discrimination; * Content that depicts, promotes, advocates for or facilitates gratuitous or real-world violence or other dangerous activity, including any Content that promotes self-harm, suicide, or games where serious injury or death may result; * Content that promotes or encourages the promotion of false or misleading health claims or claims that can cause physical harm to users; * Pornography, prostitution, other sexually explicit Content; and * Content designed to interfere with the proper functions of government, including false election Content (such as “official voting dApps”). * **Deliberately Misleading Content:** Content that intentionally misleads users or can reasonably be expected to mislead users, e.g.,: * Content that falsely claims an affiliation with or endorsement by a third party (government, celebrity, private enterprise, etc.); * Content that falsely induces or influences a user to take action with respect to their device, such as encouraging users to modify security settings or features; * Content that misleads users as to the true intent, nature, or purpose of any dApp; and * Content designed to create, or to enable users to create, ‘deepfakes’ or other false or misleading Content. * Content designed to create a likelihood of confusion with a third-party’s entity, brand, products or services. ## Guidelines for User Data dApps that collect, access, use, store, or disclose User Content or other information from or about a user, including without limitation device information (“User Data”), must be transparent about the collection and use of such User Data. Without limitation, all dApps on the dApp Store must: * Disclose the dApp’s or its Developer’s practices with respect to the collection, use, and disclosure of User Data in a privacy policy or other statement that complies with Applicable Law; * Obligate all third-party services used by or integrated with the dApp that may have access to the applicable User Data to comply with this Publisher Policy; * Not collect User Data from minors (as determined by Applicable Law) without the consent of a parent or guardian; * Provide a means or method for users to delete their account, and delete the User Data associated with such account (except to the extent you have lawful reasons, such as regulatory requirements or fraud prevention, to retain such data); and * Not use fraudulent, deceptive, or coercive measures to obtain user consent to the collection, sharing, or any specific use of User Data, and respect users’ decisions if they decline to consent. dApps that collect, access, share, or encourage the collection, access, or sharing of Regulated Data from or between or among end users must comply with all Applicable Laws with respect to such Regulated Data. “Regulated Data” means any (a) Social Security numbers or other government-issued identification numbers; (b) protected health information subject to the Health Insurance Portability and Accountability Act (HIPAA) or other information regarding an individual’s medical history, mental or physical condition, or medical treatment or diagnosis by a health care professional; (c) health insurance information; (d) biometric information or biometric identifiers; (e) credentials to any financial accounts or credit, debit or payment card data subject to the Payment Card Industry Data Security Standard (PCI DSS); (f) tax return data; (g) precise geolocation data; (h) data revealing racial or ethnic origin, religious beliefs, sex life or sexual orientation, union membership, citizenship, or immigration status; (i) genetic data; (j) personal data collected from an individual under the age of 18; (k) personal data subject to any Applicable Law related to data protection, including U.S. state consumer privacy laws such as the California Consumer Privacy Act; (l) data relating to criminal convictions or offenses; or (m) online account credentials. Without limiting the foregoing: * dApps that collect Regulated Data should collect only the minimum amount of such Regulated Data required to perform such dApp’s function; * dApps should not offer Regulated Data for sale or otherwise make it available to any third party except with the applicable users’ express consent and in compliance with Applicable Law; and * dApps that collect, store, and transfer Regulated Data should use encryption and other industry best practices to protect such Regulated Data in transit and at rest. ## Restricted Activities and Transactions Solana Mobile does not knowingly allow any dApps that are designed to process transactions, provide services, or facilitate other activities that violate Applicable Law. Without limiting the foregoing: * dApps may not facilitate the sale or purchase of prescription drugs without a prescription; * dApps may not promote or sell any substance that is unapproved under Applicable Law, regardless of whether it is being sold for such purposes; * dApps that provide or purport to provide financial services subject to any regulation under Applicable Law must obtain and provide in connection with such Developer Assets all documentation required by Applicable Law to provide such financial services; * dApps that are or purport to be regulated medical devices must obtain and provide in connection with such Developer Assets all documentation required by Applicable Law to act as a medical device; * dApps that make any medical or health-related claims with respect to their services must substantiate those claims, and must have required legal and regulatory disclosures; * dApps may not interfere with, disrupt, damage, or gain unauthorized access to any user devices or any other devices, networks, or services; and * dApps may not include, distribute, or incorporate code that would introduce or exploit security vulnerabilities. Developer Assets may not include, and Solana Mobile will not knowingly permit the dApp Store to allow, any of the following: * dApps that block or interfere with the display of ads on other dApps; * dApps that facilitate the circumvention of or provide instructions on how to circumvent security protections or otherwise hack networks, services, software, or hardware; * dApps that encourage or cause cheating on or otherwise affect the gameplay of other dApps; * dApps that access or use any service in a manner that violates the terms of use of such service; * dApps that install other dApps or any other Content on a device without the user’s prior consent; * dApps that link to or facilitate the distribution or installation of viruses or other malicious software; * dApps or other Content containing a webview that loads untrusted web Content or unverified URLs obtained from untrusted sources; and * dApps that force user interaction with disruptive ads or notifications. ## Guidelines for User-Generated Content dApps that solicit, permit, host, display, enable, or otherwise make available (“Make Available”) user-generated Content (“UGC”) are solely responsible for ensuring that such UGC complies with the restrictions applicable to Content as set forth in this Publisher Policy. In particular, and without limitation, any dApp that Makes Available any UGC must: * Cause its user terms to include the same restrictions as this Publisher Policy, and require end users to agree to such user terms; * Enable users to report or flag offensive or inappropriate content from within the dApp; * Moderate UGC to ensure that there is no Restricted Content or other UGC that would violate this Publisher Policy or Applicable Law; and * Provide reasonable self-help remedies for end users (e.g., a “block” function) to enable end users to minimize disputes, and support user dispute resolution through established processes. # Mint your App NFT Source: https://docs.solanamobile.com/dapp-store/publishing-cli/app-nft If this is your first time publishing an app on the dApp Store, then you will need to mint a an **App NFT**.