PRIVACY POLICY

The Solborn Platform ("Solborn", "we", "us") is operated by [OPERATOR LEGAL ENTITY NAME — pending registration], registered at [REGISTERED ADDRESS — pending]. We are the data controller for the personal data described in this Policy.

Privacy enquiries and requests: privacy@solborn.fun. Community channels (Discord, X) are not a valid channel for privacy requests.

This Policy covers personal data processed when you use the Solborn website, web application, and associated services. It also explains the special status of data recorded on the Solana blockchain, which we do not control.

3.1 Wallet address. Your Solana wallet public address is our primary account identifier. We never collect, see, or store your private keys or seed phrase.

3.2 Gameplay data. Match history and results, replays, in-game statistics, quest and progression data, leaderboard rankings, deck compositions, and pack opening records, each associated with your wallet address.

3.3 Acceptance records. When you accept our Terms of Service, we store the accepted version, timestamp, acceptance message, and your wallet signature.

3.4 Contact data. If you join our waitlist or referral programme, we store the email address or referral details you provide.

3.5 Technical data. IP address, browser user-agent, and request metadata, collected in server logs and used for security functions such as rate limiting and abuse prevention.

3.6 Analytics events. First-party gameplay and platform analytics (for example match, pack, and account events) associated with your wallet address, stored on our own infrastructure.

3.7 On-chain data. Transactions you sign — profile creation, wager lobbies, pack purchases, marketplace activity — are recorded publicly and permanently on the Solana blockchain by the network itself.

(a) To operate the game: matchmaking, match resolution, settlement, progression, leaderboards, and replays.

(b) To secure the Platform: rate limiting, anti-cheat and match-manipulation detection, fraud prevention, and incident investigation.

(c) To keep records of legal significance: Terms acceptance records and dispute investigation records.

(d) To communicate with you where you have asked us to (waitlist, referral programme).

(e) To understand and improve the Platform through first-party analytics.

(f) To comply with legal obligations that apply to us.

We do not sell your personal data, and we do not use it for third-party advertising.

Where the GDPR or UK GDPR applies, we rely on: performance of a contract (operating the game and settling matches under the Terms you accepted); legitimate interests (platform security, anti-cheat, first-party analytics, record-keeping); consent (waitlist and marketing emails, which you may withdraw at any time); and legal obligation (where processing is required by law).

Data recorded on the Solana blockchain is public, replicated across the network, and permanent. Neither we nor anyone else can modify or erase confirmed on-chain records. If you interact with the Protocol, your wallet address and transaction history are publicly visible by design.

Rights such as erasure and rectification therefore apply only to the off-chain data we hold on our own infrastructure, and cannot be applied to the blockchain itself. Please consider this before transacting.

We share personal data only with: (a) infrastructure providers that host and operate the Platform on our behalf (cloud hosting, database, and caching providers), acting under contract as processors; (b) professional advisers where reasonably required; and (c) courts, regulators, or law enforcement where required by law or necessary to protect the Platform and its users. We do not sell or rent personal data.

Our infrastructure providers may store or process data in countries other than your own, including the United States. Where data of EEA/UK users is transferred internationally, we rely on appropriate safeguards such as standard contractual clauses entered into by our providers.

We retain: gameplay and analytics data for as long as your account is active and thereafter as needed for the purposes above; Terms acceptance records for as long as legally relevant to the agreement between us; security logs for a limited operational period; and waitlist emails until you unsubscribe or ask us to delete them. When data is no longer needed, we delete or anonymise it.

We apply reasonable technical and organisational measures to protect the data we hold, including access controls, origin checks, rate limiting, and signature verification for sensitive operations. No system is completely secure; we encourage you to protect your wallet and report suspected incidents to privacy@solborn.fun.

Depending on your jurisdiction, you may have the right to access, correct, delete, or receive a copy of your personal data, to object to or restrict certain processing, and to withdraw consent where processing is based on consent. EEA/UK users also have the right to lodge a complaint with their supervisory authority.

To exercise any right, email privacy@solborn.fun from a channel that allows us to verify your control of the relevant wallet address (we may ask you to sign a verification message with the wallet concerned). We respond within the timescales required by applicable law. Note the blockchain limitations described in Section 6.

The Platform currently sets no cookies. We use browser local storage for functional purposes only, such as remembering your wallet connection and interface preferences.

We may introduce cookies or similar technologies in the future — for example for session management, security, or analytics. If we do, we will update this Policy to describe them before they take effect and, where required by applicable law, request your consent. We will not use third-party advertising cookies or cross-site tracking without your consent.

The Platform is not intended for, and may not be used by, anyone under 18 years of age (or the age of majority in their jurisdiction, if higher). We do not knowingly collect personal data from minors; if we learn that we have, we will delete it.

We may update this Policy from time to time. Material changes will be notified via the Platform interface with an updated version number and revision date before they take effect.