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Privacy Policy

Draft — pending legal review

This document is a draft. It will be reviewed by counsel before publication and may change. Items in square brackets are placeholders.

Contents
  1. 1. Introduction
  2. 2. Information We Process
  3. 3. Purposes
  4. 4. Legal Basis
  5. 5. Retention
  6. 6. Sharing
  7. 7. International Transfers
  8. 8. Your Rights
  9. 9. Minors
  10. 10. Changes
  11. 11. Contact

1. Introduction

This Privacy Policy (the "Policy") explains how [Operator legal name] ("we" or "us") handles information about you in connection with the web interface "WOW" (the "Service"). By design, the information we process is very limited. We do not create accounts, we do not ask for your name, email address or postal address, and we use no advertising trackers. Our only usage analytics is cookie-less and uses no identifier that could single you out (see 2.3).

This Policy applies together with the Terms of Service.

2. Information We Process

2.1 Wallet address and on-chain activity

When you connect a wallet, the Service reads its public address and fetches balances, token holdings, transaction history and claimable creator fees from the blockchain (Soneium) to display them to you.

Your wallet address and the transactions tied to it are public information recorded on a public blockchain. We do not create or control that record and cannot delete or correct it. Please note that blockchain records are permanent and viewable by anyone. We hold no information linking a wallet address to a real-world identity, but a third party may be able to identify you by combining it with information you have published elsewhere.

2.2 Server access logs

Our web server and hosting provider may automatically record the following when you access the Service, for security and incident response:

  • IP address
  • date and time of access, requested URL, referrer
  • browser type and version, operating system, language settings (User-Agent, Accept-Language)

The only cookie the Service sets is NEXT_LOCALE, which remembers your display language. It is a technical cookie required for language switching and is not used for tracking or advertising. You can delete or block it in your browser settings, in which case your language preference will not be remembered.

To understand how the Service is used we rely on Vercel Web Analytics, provided by our hosting provider (Vercel Inc.). It sets no cookies and creates no identifier that tracks a device or a person. It collects aggregate statistics — pages viewed, referrer, country or region, browser and device type — and counts of product actions such as "connected a wallet", "traded" and "launched a coin". These action events carry no wallet address, no token address and no amounts. Your IP address is used to receive the request and is not stored as analytics data. See Vercel's privacy policy for details.

We use no cookie-based analytics such as Google Analytics, no advertising pixels and no fingerprinting. Should we introduce any in the future, we will update this Policy and ask for consent where required.

2.4 Requests to third-party providers

The Service communicates with the following third-party services in order to function. Each provider may log the connecting IP address and similar data under its own policy.

  • RPC endpoints: to read the blockchain and send transactions, your browser sends requests directly to Soneium's public RPC (rpc.soneium.org) or to an RPC node we provide.
  • Block explorer: links to transaction and address details point to the Soneium block explorer, which we do not operate.
  • Hosting provider: the hosting and CDN provider that serves the Interface (Vercel Inc.) may collect access logs; it also processes the usage analytics described in 2.3.
  • Wallet software: the wallet you use (browser extension, mobile app and so on) is governed by its own provider's privacy policy.
  • WalletConnect (Reown): only if you choose "WalletConnect" as the way to connect, your browser communicates directly with WalletConnect servers operated by Reown (the relay that carries the connection, the wallet-list and domain-verification APIs, Reown's own usage measurement of its SDK, and font delivery; the domains are walletconnect.org, web3modal.org and reown.com). Those requests carry the connecting IP address, the domain of the Service and the connection and signing requests exchanged with your wallet in encrypted form, and the information needed to keep the connection is stored in your browser (local storage). None of these requests are made unless you choose WalletConnect. Reown's privacy policy applies to that data.

3. Purposes

We use the information we obtain for the following purposes:

  • providing the Service (showing wallet balances and holdings, sending transactions, switching language);
  • keeping the Service secure (detecting and preventing unauthorised access, attacks and excessive load);
  • investigating and recovering from incidents, and improving quality;
  • responding to breaches of the Terms of Service (such as hiding content from the Interface); and
  • complying with legal obligations and responding to requests from duly authorised bodies.

We handle information in accordance with the Act on the Protection of Personal Information of Japan (APPI), only to the extent necessary for the purposes above, and do not use it for any other purpose. An IP address or wallet address may not identify a specific individual on its own, but we treat them with the care due to personal information.

If you are in the European Economic Area, the United Kingdom or Switzerland, our legal bases are (a) performance of a contract, namely providing the Service (GDPR Art. 6(1)(b)), and (b) our legitimate interest in keeping the Service secure and preventing abuse (Art. 6(1)(f)). We currently set no cookies requiring consent and perform no profiling.

5. Retention

  • Server access logs: kept for as long as needed for security purposes (as a rule no longer than [90 days]), then deleted or anonymised, except where needed to investigate abuse or to meet a legal obligation.
  • Language cookie: stored in your browser, not on our servers. It expires after about one year and you can delete it at any time.
  • Blockchain records: outside our control and permanently public.

6. Sharing

We do not share the information we obtain with third parties except:

  • with the processors and providers listed in section 2.4, as needed to provide the Service;
  • where required by law, or in response to a request from a court, law-enforcement agency, regulator or other duly authorised body;
  • where necessary to protect a person's life, body or property and obtaining consent is difficult; or
  • to a successor in the event of a business transfer (in which case the successor is bound by this Policy).

We do not sell your information.

7. International Transfers

Our hosting providers, RPC nodes and CDN may be located outside Japan, in which case your information (such as your IP address) is transmitted to those countries. As required by the APPI, we check the data-protection regime of the destination country and the measures taken by the recipient, and apply appropriate safeguards. For users in the EEA and similar jurisdictions, transfers rely on adequacy decisions, standard contractual clauses or another lawful transfer mechanism.

8. Your Rights

Under the APPI and other applicable law you may request disclosure, correction, addition, deletion, suspension of use or suspension of third-party provision of the personal information we hold about you. Users in the EEA and similar jurisdictions also have the rights to data portability, to object to processing and to lodge a complaint with a supervisory authority.

Send requests to the contact in section 11. We may ask for additional information to verify your identity. Note that we cannot delete or correct information recorded on the blockchain, and because access logs are not linked to wallet addresses we may be unable to identify the log entries that relate to you.

9. Minors

The Service is intended only for persons who have reached the age of majority in their country of residence (and in any case are at least 18). We do not knowingly collect information from minors. If we learn that a minor has used the Service, we will delete the related information to the extent possible.

10. Changes

We may revise this Policy in response to changes in the law or in the Service. The revised Policy takes effect when posted on the Interface. For material changes that expand the information we process, such as the introduction of analytics, we will give notice on the Interface.

11. Contact

Questions and requests regarding this Policy or our handling of personal information can be sent to:

  • Operator: [Operator legal name]
  • Address: [Registered address]
  • Contact: [contact email]

Effective date: 12 September 2026