Privacy Policy

1. Introduction

Solflare and its affiliate(s) (together, “Solflare”, “we”, “us” or “our” in this privacy policy) respect your privacy and are committed to protecting your personal data. We respect and value privacy rights and data security and we have adopted appropriate security measures in place to guide how we collect, store, and use the information you provide us. Please read this privacy policy carefully as it explains our practices regarding your personal data and how we will treat it. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and use the Solflare wallet, inform you about your privacy rights and how the law protects you. Terms used in this policy are defined in the Glossary, in Section 10. This privacy policy is incorporated by reference into our Terms of Use. By agreeing to this privacy policy through your continued use of our services, you agree to the terms and conditions of this privacy policy. If you do not agree to this privacy policy, please do not use, register to or otherwise access our services.

2. Important information and who we are

Purpose. This privacy policy aims to give you information on how Solflare collects and processes your personal data through your use of the Solflare wallet and the Solflare website, including any data you may provide when you use them. Our website and the Solflare wallet are not intended for minors and we do not knowingly collect data relating to minors. It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide from time to time on our website when we are collecting or processing personal data so that you are fully aware of how and why we are using your data.

Controller. Solrise Finance Ltd is the controller and responsible for your personal data. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details. Please contact us on [email protected] if you have any questions or complaints about our privacy policy, the personal data we hold about you or to discuss your rights under applicable law.

Changes to the privacy policy. We reserve the right to modify this privacy policy at any time. We keep our privacy policy under regular review and publish new versions on this page. We encourage you to read this privacy policy periodically to stay up-to-date about our data collection practices. By continuing to access or use our services after any revisions become effective, you agree to be bound by the updated privacy policy.

Third-party links. Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit. Please note that we cannot control, nor will we be responsible for the personal information collected and processed by third parties, its safekeeping or a breach thereof, or any other act or omission pertaining to it and their compliance with applicable privacy laws or regulations.

3. The data we collect about you

We may collect and process the following personal data about you:

Information you give us. You may give us information about you when you register with our website https://www.solflare.com (“our website”) or by communicating with us. This includes information you provide when you subscribe to our services, provide us with feedback, participate in surveys, and when you report a problem with the Solflare wallet or website. Depending on which of our products and services you elect, the information you give us may include your name or email address. If you engage with us through social media this may also include your social media contact details, such as your LinkedIn profile name or X (former Twitter) handle/username.

Information we collect about you when you communicate with us remotely in person or otherwise, and when you use our services: we collect engagement metric information such as information about how, when and how often you contacted us, and how, when and how often you responded to communications from us and about how and when you use our services.

Information we collect about you if you use our wallet or website or interact with us over the internet, including via social media: each time you visit our website or interact with us we may automatically collect the following information: (a) technical information, including the Internet protocol (IP) address used to connect your device to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; (b) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.

Information we collect about you from publicly available sources: this may include information available from social media (depending on your settings and the applicable privacy policies), including social media engagement metrics such as numbers of connections, followers and clicks.

Information we receive from other sources. We may receive further information about you if you use any of the services we provide. We work closely with third parties (including, for example, business partners, service providers, analytics providers such as Google, advertising networks search information providers) and may receive information about you from them. We may combine information we receive from these other sources with information you give to us and information we collect about you.

We may monitor or record communications between you and us and keep recordings or transcripts of them and, if you contact us, we may keep a record or copy of that correspondence.

We also collect, use and share aggregated data such as statistical or demographic data. Aggregated data may be derived from your personal data, but it is not considered personal data under the data protection legislation as it does not directly or indirectly identify you. If at any time we do combine any aggregated data with your personal data so that it can identify you, we treat the combined data as personal data, which we will use and process in accordance with this Privacy Policy.

Purposes for which we will use your personal data. We have set out below, in a table format, a description of all the ways we use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Direct marketing. Where we have your consent (including when you change a mobile device or reset an advertising ID or cookies), we may send direct marketing communications including push notifications to you. Whenever you receive direct marketing from us you will be told how you can unsubscribe so that you no longer receive it. When we communicate with you via email you will also be given the opportunity to set or amend any preferences that you have indicated to us.

You are also able at any time to withdraw any consent to receive marketing communications that you have given to us. You can do this by contacting us at [email protected]. 

Third-party marketing. We will request your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, service experience or other transactions.

Cookies: these are alphanumeric identifiers that we place on your device through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our services, while others are used to enable a faster log-in process or to allow us to track your activities. There are two types of cookies: session and persistent cookies. Session cookies stay on your computer during your browser session and are deleted after the session ends. We use session cookies to understand site traffic and usage, including pages visited and countries of visitors. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly.

Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

Disclosures of your personal data. We may share your personal data with the parties set out below for the purposes set out in the table above.

• Third parties as set out in the Glossary below.
• Analytics and search engine providers that assist us in the improvement and optimisation of our website.
• IT and software providers who supply us with our IT infrastructure for the provision of our services and administering our business (including our internal and external communications) and who also help us manage our customer and contact databases, customer relationships and marketing.
• Any other business partners, suppliers and subcontractors for the performance of any contract we enter into with you.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

We review all our relationships with third parties carefully so that we can be sure as possible that their practices match our own commitments to you relating to privacy and security.

4. International transfers

We share your personal data within the Solflare group of companies. This may involve transferring your data outside the British Virgin Islands. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.

Some of our external third parties are based outside the British Virgin Islands so their processing of your personal data will involve a transfer of data outside the British Virgin Islands. Whenever we transfer your personal data out of the British Virgin Islands, we ensure a similar degree of protection is afforded to it in accordance with the Data Protection Act in the British Virgin Islands which give personal data the same protection it has in the British Virgin Islands.

Please contact us if you want further information on the specific mechanism we use when transferring your personal data out of the British Virgin Islands.

5. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

6. Data retention

How long we keep your information will depend on the purpose for which we use it and so may vary. We will only retain your information for as long as is necessary for the purposes set out in this Privacy Policy and as is necessary to comply with our legal obligations. We do not keep more information than we need for the particular purpose.

Where we have provided you with a service, we may keep an archived record of your personal data for a period of up to 7 years after termination (unless a longer period is prescribed by law) for the purposes of responding to legal disputes and legal or regulatory enquiries or investigations only, but will not use this data for any other purpose.

In order to ensure that we provide reliable and effective services, and to comply with our regulatory obligations, we regularly make back-up copies of our data. If we have provided any services to you then this will include your personal data. Where we delete your personal data from our systems, for whatever reason, a copy may be retained in our data back-ups for a period of up to 90 days afterwards. These are kept securely and only accessed in order to delete old versions or in the event of an emergency which means we have to utilise a back-up copy to reinstate data on our active systems. Where we have to do this, we will work to ensure as soon as we reasonably can that the copy of the data that has been used to reinstate data on our active systems is updated to take account of any previous amendments and deletions regarding your personal data.

If you ask us to stop sending direct marketing communications to you (see section 3, above), we will keep the minimum amount of information necessary (such as your name and email address) to ensure that we are able to adhere to your request. We also routinely seek to minimise the amount of personal data we hold where any marketing contact is deemed inactive. We deem a contact to be inactive if we have not been able to identify any engagement (e.g. through opening an email or visiting our website) for a period of 12 months or if an email is not delivered due to a hard bounce. In such circumstances we will anonymise all relevant data for aggregation purposes, with the exception of an email address. This does not affect your rights as set out in section 7 of this Privacy Policy.

7. Your legal rights

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data 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 data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
• You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain services to you. We will advise you if this is the case at the time you withdraw your consent.

These rights are limited in some situations. For example, if we have a legal requirement or a compelling legitimate ground, we may continue to process your data even where you request its deletion.

If you would like to exercise any of these rights, please contact us using the details in the Contact section below.

You also have the right to make a complaint if you feel your personal data has been mishandled. We would encourage you to contact us in the first instance but you are also entitled to complain directly to your local data protection authority.

No fee usually required. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

Time limit to respond. We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

8. Additional Information For U.S. residents

Several U.S. states have privacy laws which grant their residents certain rights and require specific disclosures. If you reside in one of these states (such as California or Colorado), this section applies to you. This section also serves as our California notice at collection.

As required by certain of these state privacy laws, we use the tables below to explain the same information that is covered in the above sections of this policy.

Categories of personal information: identifiers (such as digital asset wallet address, public blockchain data, email address, username, avatar, images), commercial information (such as transaction data), internet or other electronic network activity information (such as IP address, usage data).

Categories of recipients: cloud service providers, analytics companies, fraud prevention and information security companies, email service providers, promotion providers, customer service providers, affiliated entities, and law enforcement.

Use of personal information: provide our services, provide personalised services, improve and develop our services, offers and other communications, other legal reasons.

We do not “sell” or “share” personal information or disclose personal information for “targeted advertising”, as those terms are defined under the relevant state privacy laws.

As described above, we collect personal information from various sources, including directly from you, automatically when you access or use our services, and from third-party sources.

We do not knowingly or intentionally collect information that is considered “sensitive” under the state privacy laws and we do not use or disclose sensitive personal information for the purpose of inferring characteristics about you. We retain personal information for as long as necessary to carry out the purposes for which we originally collected it and for other purposes described in this policy.

Non-discrimination: you have the right not to be discriminated against for exercising any of your privacy rights.

Appeals: if we deny your request, you may appeal our decision by contacting us at the address shown above. If you have concerns about the result of an appeal, you may contact the attorney general in the state where you reside.

Authorised agents: if you reside in certain states (like California), you may also designate an authorised agent to submit a request on your behalf. We may ask authorised agents to submit proof of their authority to make a request, such as a valid power of attorney or proof that they have signed permission from the consumer who is the subject of the request. In some cases, we may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm the authorised agent has permission to submit the request. If you are an authorised agent seeking to make a request, please email us at [email protected].

9. Additional Information For Canadian Residents

If you are resident in Canada, this section applies to you.

Consent: by submitting personal information to us, or our service providers or agents, you consent to the collection, use, disclosure, and transfer of your personal information in accordance with this policy and as permitted or required by law.

You may withdraw your consent at any time to the collection, use, disclosure, or transfer of your personal information by contacting us by email at [email protected]. If you withdraw your consent (or if you decide not to provide certain personal information), you acknowledge that we may be unable to continue to provide you with certain products, services, or information that may be of value to you.

We store personal information for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this policy.

10. Glossary 

Data protection legislation: means the British Virgin Islands’ Data Protection Act, 2021.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties. 

• Regulators and other government authorities acting as processors or joint controllers based who require reporting of processing activities in certain circumstances.
• Other companies in the Solflare group which provide IT and system administration services and undertake leadership reporting.
• Professional advisers acting as processors or joint controllers including lawyers, bankers and auditors who provide consultancy, banking, legal and accounting services.