Privacy Policy

1. Who this Policy applies to

This Policy applies when you visit or use Refundary's website and supported product features. Refundary acts as the controller of personal data it determines the purposes and means of processing, where applicable.

2. Information we process

Public blockchain information

When you scan or connect a wallet, Refundary processes the public wallet address and publicly available Solana account and transaction information needed to provide the requested feature. Blockchain data is public by design and may remain permanently available on the Solana network independently of Refundary.

Transaction and service data

We may process transaction signatures, selected account identifiers, transaction status, error information, and related technical records where needed to build, validate, troubleshoot, secure, or improve supported actions.

Technical information

Like most online services, our hosting and security infrastructure may process IP address, browser/device information, request timestamps, referring pages, and diagnostic or security logs. We may also use limited first-party or privacy-oriented analytics to understand aggregate usage and reliability.

Information you send us

If you contact support or make a recovery request, we process the information you choose to provide, such as your wallet address, transaction signature, contact details, and the contents of your request.

3. What we do not ask for

• Refundary does not ask for or need your seed phrase.
• Refundary does not ask you to send us your private key.
• No account registration is required for the public wallet scan.
• We do not intentionally collect sensitive personal information through the normal wallet-scanning flow.

4. Why we process information

We process information as necessary to provide requested features, calculate and display recovery opportunities, build and validate transactions, prevent abuse and security incidents, troubleshoot errors, respond to support requests, maintain records needed for legal or operational purposes, and improve the reliability and usability of Refundary.

5. Legal bases for EEA/UK users

Where data-protection law requires a legal basis, processing may rely on: performance of a contract or steps at your request when you use a Refundary feature; legitimate interests in operating, securing, preventing abuse of, and improving the Service; legal obligations where records must be retained or disclosed by law; and consent where we specifically ask for it, such as for optional non-essential cookies or communications.

6. Wallets, blockchains, and third parties

Refundary interacts with the Solana blockchain and may use third-party wallet software, RPC/infrastructure providers, hosting, security, analytics, pricing, token metadata, or swap-routing services. Information necessary to make a request may be transmitted to those providers. Their own privacy terms may apply to information they independently receive.

On-chain transactions are public. Once a transaction is broadcast, Refundary cannot erase it from the Solana blockchain.

7. Cookies and local storage

Refundary may use browser storage or cookies that are necessary for security, preferences, or core functionality. If non-essential analytics or marketing cookies are introduced where consent is required, we will provide the appropriate choice before using them.

8. Data retention

We keep off-chain personal data only for as long as reasonably necessary for the purpose for which it was processed, including security, troubleshooting, support, fraud prevention, and legal obligations. Retention periods may vary by data type. Public blockchain information remains subject to the blockchain's own permanent and decentralized nature.

9. Data sharing

We do not sell personal data. We may share limited information with service providers that help operate Refundary, when required by law or valid legal process, to protect users or the Service from fraud or security threats, or as part of a legitimate business reorganization subject to appropriate safeguards.

10. International processing

Internet and blockchain infrastructure may operate in multiple countries. Where personal data is transferred internationally, we take steps required by applicable law to use appropriate transfer mechanisms or safeguards where necessary.

11. Your privacy rights

Depending on where you live, you may have rights to request access, correction, deletion, restriction, portability, or objection regarding personal data we control, and to withdraw consent where processing is based on consent. These rights can be subject to legal exceptions and cannot remove data from a public blockchain.

EEA users may also lodge a complaint with their competent data-protection authority.

12. Security

We use reasonable technical and organizational safeguards appropriate to the nature of the Service. No internet or blockchain service can guarantee absolute security. Protect your wallet credentials and never send a seed phrase or private key to anyone claiming to represent Refundary.

13. Children

Refundary is not directed to children. If applicable law requires a minimum age or parental authorization to use digital-asset services in your jurisdiction, you must satisfy those requirements.

14. Changes to this Policy

We may update this Policy as Refundary evolves or legal requirements change. The latest version will be identified by the “Last updated” date above.

15. Contact

To ask a privacy question or exercise a privacy right, contact Refundary through the official support channel published on the Service. We may need enough information to verify and locate the relevant off-chain records without requesting your private keys or seed phrase.