1. Introduction

SOLcloser ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, and safeguard information when you use our decentralized application, in compliance with:

• General Data Protection Regulation (GDPR) - Regulation (EU) 2016/679
• French Data Protection Act (Loi Informatique et Libertés)
• Applicable international data protection laws

Because SOLcloser is a decentralized application built on the Solana blockchain, we collect minimal personal information and operate with transparency and user privacy as core principles.

2. Data Controller

3. Information We Collect

3.1 Blockchain Data (Public)

When you use SOLcloser, we interact with publicly available blockchain data:

• Wallet Address: Your Solana public key
• Transaction History: On-chain transactions you perform through the Service
• Token Account Data: Information about your SPL token accounts
• Balance Information: Amounts of SOL reclaimed

3.2 Usage Statistics (Anonymized)

We collect anonymous usage statistics to improve the Service:

• Number of accounts closed
• Total SOL reclaimed (aggregated)
• Referral activity (wallet addresses only)
• Transaction success/failure rates

Legal Basis: Legitimate interest (service improvement and analytics)

3.3 What We DON'T Collect

We explicitly do NOT collect:

• ❌ Email addresses
• ❌ Names or personal identification
• ❌ IP addresses
• ❌ Location data
• ❌ Private keys or seed phrases (we NEVER have access to these)
• ❌ Tracking cookies or pixels
• ❌ Browsing history

4. How We Use Information

We use the collected information exclusively to:

• Provide and operate the SOLcloser Service
• Process blockchain transactions
• Calculate and distribute referral rewards
• Display global statistics and leaderboards
• Improve and optimize the Service
• Detect and prevent abuse or fraudulent activity
• Comply with legal obligations

5. Data Retention

Data is retained for the following periods:

• Blockchain Data: Permanent (immutable nature of blockchain)
• Usage Statistics: 3 years from last activity
• Compliance Data: 5 years (legal obligation)

6. Data Sharing and Disclosure

We do not sell, trade, or rent your information to third parties. We may share information only in these cases:

6.1 Service Providers

• Vercel Inc. (USA): Application hosting
• Supabase (USA): Database hosting
• Helius (USA): Solana RPC provider

These providers are bound by contractual obligations to protect your data and may only use it for the specific purposes we've authorized.

6.2 Legal Requirements

We may disclose your information if required by law or valid legal process.

6.3 Public Blockchain

Transaction data is publicly visible on the Solana blockchain by design.

7. Your Rights (GDPR)

Under the GDPR and applicable data protection laws, you have the following rights:

• Right to Access: Request a copy of your data
• Right to Rectification: Request correction of inaccurate data
• Right to Erasure: Request deletion of your data*
• Right to Object: Object to processing of your data
• Right to Restriction: Request limitation of processing
• Right to Data Portability: Receive your data in a structured format
• Right to Withdraw Consent: Where processing is based on consent

To exercise your rights, contact us at: solcloser@gmail.com

8. Right to Lodge a Complaint

You have the right to lodge a complaint with a supervisory authority:

France (CNIL)

Your Country

You may also contact the data protection authority in your country of residence.

9. Data Security

We implement appropriate technical and organizational measures to protect your data:

• Encrypted communications (HTTPS/TLS)
• Strict access controls
• Regular backups
• Security audits
• Secure database configurations

Your Responsibility: You are solely responsible for the security of your wallet and private keys. We never have access to your private keys and cannot recover lost funds.

10. International Data Transfers

Our Service is hosted in the United States (Vercel, Supabase). By using the Service, you consent to the transfer of your information to countries outside your country of residence, including the United States, which may have different data protection rules.

We ensure that such transfers are protected by appropriate safeguards, including:

• Standard Contractual Clauses approved by the European Commission
• Privacy Shield Framework (where applicable)
• Other legally approved transfer mechanisms

11. Children's Privacy

SOLcloser is not intended for use by individuals under the age of 18. We do not knowingly collect information from children. If you are a parent or guardian and believe your child has used our Service, please contact us immediately.

12. Cookies and Tracking

SOLcloser does not use tracking cookies, advertising cookies, or analytics cookies.

We may use strictly necessary cookies for technical functionality (e.g., session management, user preferences). These cookies do not track you across websites and are essential for the Service to function.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last Updated" date.

Your continued use of the Service after any changes constitutes acceptance of the updated Privacy Policy.

14. Contact Us

If you have questions about this Privacy Policy or wish to exercise your rights, please contact us: