# Privacy Policy *Last Updated: May 27, 2026* {% hint style="info" %} Sol-Incinerator is designed to minimize the collection of personal data. Most users interact with this Interface using only a public wallet address — no account, no email, no identity required. {% endhint %} Sol-Incinerator ("we," "us," or "our") provides a non-custodial software interface available at sol-incinerator.com (the "Interface"), the API at api.dashboard.sol-incinerator.com, and related services (collectively, the "Services") that enable users to interact with token burn and account cleanup functionality implemented via smart contracts deployed on the Solana blockchain. This Privacy Policy describes what data we collect, why, and what we do with it. This Policy applies to all interactions with the Interface and Services. It does not govern data processed by third-party wallet providers, RPC nodes, advertising partners, or the Solana blockchain itself — those are independent systems operating outside our control. Questions? Contact us at ### **1. Changes to This Policy** *** We may update this Privacy Policy at any time by posting the revised version to the Interface with an updated effective date. Revised versions become effective upon posting. The "Last Updated" date at the top of this document reflects the most recent revision. Continued use of the Interface following any update constitutes your acceptance of the revised Policy. If you disagree with any update, stop using the Interface. For material changes — including changes that significantly expand the categories of data collected, the purposes for which data is used, or the parties with whom data is shared — we will endeavor to provide advance notice by posting a prominent notice on the Interface prior to the change taking effect. What constitutes a material change is determined at our reasonable discretion. ### 2. Eligibility *** The Interface is intended for users who are 18 years of age or older (or the age of majority in their jurisdiction, whichever is greater). We do not knowingly collect data from anyone under 18. Because the Interface does not require account creation or identity verification, we have no means of independently verifying user age. If you are under 18, you are not permitted to use the Interface. **Children's Privacy.** The Interface is not directed to children under the age of 13. Because the Interface does not require account creation or identity verification, we have no means of independently verifying the age of any user. We do not knowingly collect personal information from children under 13. Parents or guardians who believe their child under 13 has accessed the Interface or submitted personal information may contact us to request deletion of any such information from records we control. ### 3. What We Collect *** For the purposes of this Policy, "personal information" or "personal data" means information that identifies, relates to, or could reasonably be linked with a particular individual. Wallet addresses and public transaction data recorded on the Solana blockchain may constitute personal data in certain jurisdictions where they can be linked to an individual through reasonably available means. However, on-chain records are public, immutable, and not within Sol-Incinerator's control — we cannot modify, erase, or restrict access to blockchain data regardless of any request. #### 3a. On-Chain Data (Public Blockchain) When you interact with the Interface, your public wallet address and all associated transaction data are recorded immutably on the Solana blockchain. This data is public by design — it is accessible to anyone and is not controlled by us. To display token balances, account activity, and estimated recoverable amounts, we or our service providers query publicly available on-chain data associated with your connected wallet. This information is already publicly available and is surfaced to you for convenience. We may analyze pseudonymous wallet identifiers and transaction data to understand usage patterns and improve the Interface. Wallet addresses are pseudonymous identifiers and may be personal data where reasonably linkable to an individual. We do not attempt to identify real-world identities or build behavioral or marketing profiles tied to individuals. We do maintain operational records linking wallet addresses to referrals, API usage, and fee attribution where necessary to operate the Services. #### 3b. Technical and Log Data Standard web infrastructure may automatically capture the following when you access the Interface: * IP addresses and general (non-precise) location information derived from IP addresses * Browser type, version, and language * Device type and operating system * Referring and exit URLs * Date, time, and duration of access * Pages visited and features used This data is used for security monitoring, fraud detection, infrastructure maintenance, and aggregate usage analysis. It is not used to build individual user profiles. The Interface uses Google Ads conversion tracking. When you arrive at the Interface after clicking a Google Ad, and when you complete certain actions such as burn or cleanup transactions, Google receives a conversion signal associated with your ad click. This data is used to measure the effectiveness of our advertising campaigns and to optimize future ad delivery. Google processes this data under its own privacy policy. The Interface uses Cloudflare for content delivery, infrastructure security, and analytics. Cloudflare may collect IP addresses, request metadata, and general location information derived from IP addresses to provide these services. Cloudflare processes this data under its own privacy policy. The Interface and API rely on third-party RPC node providers (including but not limited to Helius, Alchemy, and QuickNode) to query blockchain state and relay transactions to the Solana network. These providers receive wallet addresses, account data queries, and transaction payloads as part of providing blockchain infrastructure services. RPC providers process this data under their own privacy policies. #### 3c. API and Partner Integration Data If you access the Interface via the Sol-Incinerator API as a developer or integration partner, we collect: * API keys (issued by Sol-Incinerator) * API usage metrics, request volumes, and rate limit events * Partner fee account addresses (Solana wallet addresses provided via the partnerFeeAccount parameter) * Referral codes (alphanumeric identifiers used to attribute wallet activity to a referrer) * Wallet addresses attributed to referral codes for fee-split computation This data is used to operate the partner program, calculate fee splits and referral rewards, prevent abuse, and maintain API integrity. Partner and referral data is retained for the duration of the relationship and for a reasonable period thereafter to resolve disputes or meet legal obligations. The API is also accessible via a hosted Model Context Protocol (MCP) server, which exposes burn, close, and cleanup operations as tools for AI agents and automated tooling. When accessed via MCP, the same data categories described in this section apply — wallet addresses and operation parameters are processed identically to standard API requests. All transactions initiated through the MCP server must be signed locally by the wallet owner before relay. Integrators and developers building AI-powered products using the MCP server are solely responsible for making appropriate disclosures to and obtaining any required consent from their end users. #### 3d. Advertising Data The Interface may display banner advertisements from select third-party gaming partners where permitted by applicable law and subject to jurisdictional restrictions as described in the Terms of Use. These advertisements are clearly identified as sponsored content from an external platform not affiliated with Sol-Incinerator. In connection with the display of partner advertisements, Sol-Incinerator collects only anonymous aggregate impression and click count data solely for the purposes of performance verification and geoblocking compliance confirmation. Sol-Incinerator does not collect, store, or process any personally identifiable information, wallet addresses, IP addresses, or individual user identifiers in connection with the display of or interaction with partner advertisements. This limitation applies specifically to data collected in connection with partner advertisements and does not affect data collected through standard web infrastructure as described in Section 3b. When a user chooses to interact with a partner advertisement and affirmatively proceeds to an external platform, all data collection from that point forward occurs solely through the partner's own technologies, independently of Sol-Incinerator, and is subject to their own privacy practices and policies. Sol-Incinerator has no access to, visibility into, or control over any data collected by advertising partners on their own platforms. Prior to redirecting any user to a partner advertising platform, the Interface displays a departure notice informing the user that they are leaving Sol-Incinerator and visiting an independently operated external platform. Data collection by the external platform begins only after the user affirmatively chooses to proceed. Sol-Incinerator may receive advertising fees in connection with your exposure to or interaction with partner advertisements displayed on the Interface. The receipt of advertising fees does not constitute an endorsement of any advertiser or their services. Sol-Incinerator functions solely as a passive advertising publisher and is not responsible for any data collected by advertising partners. #### 3e. Referral Program Data The Interface operates a user-facing referral program. If you generate or use a referral link, we associate: * Your public wallet address as the referrer * The wallet addresses of users attributed to your referral link * Transaction history relevant to reward calculation This data is used solely to calculate and distribute referral rewards (20% of protocol fees generated by referred wallets). It is not shared with third parties for marketing purposes. Referrers have access only to their own aggregate reward totals and do not have visibility into the wallet addresses or transaction details of referred users. Referral terms, including reward rates and program availability, may be modified or discontinued at any time at our sole discretion. #### 3f. Voluntary Communications If you contact us via email, Discord, Telegram, or any other channel, we retain the contents of that communication in order to respond to your inquiry. We do not use this data for any other purpose. Please note that Discord and Telegram are independent platforms that operate as separate data controllers under their own privacy policies. Communications sent through those platforms are subject to their respective data practices, which are outside Sol-Incinerator's control. ### 4. What We Do Not Collect *** {% hint style="info" %} We will NEVER ask for your private keys, seed phrase, or wallet password. Anyone claiming to be Sol-Incinerator and asking for these credentials is a scammer. {% endhint %} We do not collect: * Private keys, seed phrases, or wallet credentials of any kind * Government-issued identification, bank account details, or payment card data * Sensitive personal data (health, biometric, political, or religious information) * Individual user profiles built from on-chain behavioral data ### 5. How We Use Your Information *** We use collected data for the following purposes. We collect and process only the minimum data necessary to provide the Services: * Operating, maintaining, and improving the Interface and Services * Processing and recording on-chain protocol fees, partner fee splits, and referral rewards * Administering API access, enforcing rate limits, and preventing abuse * Detecting and mitigating abuse, malicious activity, or prohibited use of the Interface * Displaying partner advertisements within the Interface where permitted by applicable law, and maintaining anonymous aggregate impression and click records for performance verification and geoblocking compliance confirmation * Responding to user and partner support inquiries * Complying with applicable legal obligations We do not sell or rent personal information. We do not transmit personal information to advertising networks or gaming advertising partners. Anonymous aggregate impression and click data collected in connection with partner advertisements is not personal information. We use Google Ads conversion tracking to measure campaign effectiveness and optimize ad delivery. This involves Google receiving conversion signals when users who arrived via a Google Ad complete certain actions on the Interface, including burn and cleanup transactions. Beyond Google Ads conversion tracking, we do not use information collected through the Interface for targeted advertising or direct marketing. Ad networks, if enabled, may independently collect browser-level data directly from your device in accordance with their own privacy policies. We do not control this collection and do not have access to the data they collect. ### 6. Blockchain Immutability *** The Solana blockchain is a public, decentralized, permissionless network. All transactions submitted through the Interface are permanently recorded and visible to any party with access to the network. Sol-Incinerator cannot modify, erase, reverse, or obscure any on-chain record. Blockchain data may, in combination with external data sources, allow third parties to associate a public wallet address with a real-world identity. This is a fundamental property of public blockchain networks and is not controlled by Sol-Incinerator. ### 7. Cookies and Analytics *** The Interface may use cookies, local storage, and web analytics tools to understand aggregate usage patterns. Where analytics tools are used, we configure them to minimize data collection, anonymize IP addresses where possible, and disable cross-site tracking. You may disable cookies through your browser settings. Doing so may affect the functionality of certain Interface features. We do not use cookies or analytics data to target or profile individual users. Essential cookies necessary for the Interface to function are used without additional consent. You may manage cookie preferences at any time through your browser settings. Analytics data is retained in aggregated, anonymized form for as long as commercially necessary to improve the Interface, and may be deleted at any time. You may disconnect your wallet from the Interface at any time. Disconnecting your wallet will limit your ability to use certain Interface features but does not affect any on-chain data or previously submitted transactions. We do not currently respond to browser Do Not Track signals as there is no established industry standard for their interpretation. We will update this section if such a standard is adopted. ### 8. Third-Party Services *** The Interface integrates with third-party services including wallet providers (Phantom, Solflare, Backpack, and others), wallet connection infrastructure (WalletConnect, which relays wallet connection data through its own infrastructure under its own privacy policy), RPC node providers (including but not limited to Helius, Alchemy, and QuickNode, which receive wallet address queries and transaction submissions as part of providing blockchain infrastructure), swap routing services (currently provided by Jupiter), select third-party gaming partners (whose banner advertisements may be displayed on the Interface where permitted by applicable law; Sol-Incinerator functions solely as a passive advertising publisher with respect to such advertisements and does not endorse, operate, or control any gaming partner platform), Google (Google Ads conversion tracking — see Section 3b), Cloudflare (content delivery, security, and analytics — see Section 3b), decentralized applications, external blockchain protocols, and partner platforms. Each third-party service operates under its own privacy policy and data practices, and Sol-Incinerator is not responsible for their privacy practices, availability, functionality, or outcomes. Swap transactions executed through the Interface are routed via the Jupiter API and are subject to Jupiter's own terms of service and privacy policy; Sol-Incinerator is not responsible for any data processed by Jupiter in connection with swap routing. Your interactions with any external service you access through or in connection with the Interface are governed by those parties' policies. Sol-Incinerator may receive referral fees, affiliate compensation, or advertising revenue in connection with your use of or exposure to Third-Party Services, as disclosed in the Terms of Use. We do not guarantee the accuracy, completeness, or reliability of any data presented through the Interface, including wallet balances, token valuations, estimated recoverable amounts, or fee calculations. ### 9. Data Retention *** We retain data only as long as necessary for the purposes described in this Policy or as required by applicable law: * Infrastructure and server logs (IP addresses, HTTP request logs, error logs, security logs): retained for up to 90 days, unless a security incident or legal obligation requires longer retention * API transaction logs, partner fee account addresses, and fee history: retained indefinitely as part of operational and financial records * Referral program data: retained for as long as necessary to calculate and distribute referral rewards, and for a reasonable period thereafter to resolve any reward disputes * Voluntary communications: retained until the inquiry is resolved, unless a legal obligation requires longer retention * Aggregated, anonymized analytics and anonymous aggregate advertising impression and click count data: retained for as long as commercially necessary, or as otherwise required or permitted by applicable law ### 10. Data Security *** We implement reasonable technical and organizational measures to protect data in our possession, including encryption in transit, access controls, and monitoring. No system is perfectly secure. We cannot guarantee absolute protection against unauthorized access, loss, or disclosure. You are solely responsible for the security of your wallet, private keys, seed phrase, and connected devices. Sol-Incinerator has no access to your wallet and cannot recover lost or stolen digital assets. Sol-Incinerator cannot reverse, cancel, or modify any transaction once submitted to the Solana network. ### 11. Data Disclosure *** We do not sell or rent your data. We may disclose data in the following limited circumstances: * To comply with applicable law, regulation, or a valid legal process (subpoena, court order, regulatory demand) * To investigate, prevent, or respond to fraud, abuse, or security incidents * In connection with a merger, acquisition, restructuring, or transfer of all or substantially all of Sol-Incinerator's assets, provided the receiving party agrees to honor this Policy * To service providers and vendors acting on our behalf under confidentiality obligations, solely to the extent necessary to operate the Services In all cases, disclosure is limited to the minimum data necessary for the specified purpose. We do not voluntarily disclose personal information to government authorities except in response to valid legal process or where required by law. Where lawful and feasible, we will notify affected users of any compelled disclosure. We will notify affected users where required by applicable law in the event of a data breach involving personal data we control. For security-related concerns or to report a suspected incident, contact us at . ### 12. Your Rights and Choices *** Depending on your jurisdiction and applicable law, you may have rights regarding the personal data we hold about you. Given the limited personal data Sol-Incinerator controls, the most applicable rights are: * **Access** — request details of personal data we hold about you, such as referral attribution records, API usage data, or support communications * **Deletion** — request deletion of personal data we control, subject to legal hold and retention obligations described below * **Non-discrimination** — we will not penalize you for exercising any privacy right * **Complaint** — you may lodge a complaint with a relevant data protection authority or state regulator in your jurisdiction Where required by applicable law, additional rights including correction, portability, restriction, objection, and appeal may also apply. Contact to submit any request. **Note on Blockchain Data:** Because on-chain data is public and immutable, rights such as erasure or correction generally cannot be exercised with respect to Solana blockchain records. These rights apply only to personal data we control and do not extend to public blockchain data. Residents of certain U.S. states (e.g., California under CCPA/CPRA) may have additional rights, including the right to know what personal information is collected. We do not sell personal information. We will respond to verifiable requests within 45 days (or within one month where required by applicable law), with an extension of up to a further 45 days (or two additional months where required by applicable law) where reasonably necessary. We may deny requests that are unreasonable, repetitive, or that relate to data we are not required to retain or handle — including public blockchain data. **Deletion requests will not be honored where the data is subject to a legal hold, is required to be retained by applicable law or regulation, is relevant to pending or reasonably anticipated litigation, or is otherwise exempt under applicable privacy law.** For requests relating to data associated with a specific wallet address, we may require reasonable verification of wallet ownership before processing the request. #### European Union, United Kingdom, Switzerland, and Other Jurisdictions If you are located in the European Economic Area ("EEA"), the United Kingdom, or Switzerland, the General Data Protection Regulation ("GDPR") or equivalent local legislation applies to our processing of your personal data. Slug Holdings Inc acts as the data controller in respect of personal data processed in connection with the Services. #### Legal Bases for Processing We process your personal data on the following legal bases: * **Legitimate interests** — to operate, secure, and improve the Interface, detect and prevent fraud or abuse, and analyze aggregate usage patterns; * **Contract performance** — to provide the Interface and Services you access; and * **Legal obligation** — to comply with applicable laws, regulations, and valid legal process. Where we rely on legitimate interests, you have the right to object to that processing as set out below. #### Your GDPR Rights Subject to applicable law, you have the right to: * **Access** — request a copy of the personal data we hold about you; * **Rectification** — request correction of inaccurate or incomplete data; * **Erasure** — request deletion of your personal data, subject to legal retention obligations and the blockchain immutability limitations described in Section 6; * **Restriction** — request that we limit processing of your data in certain circumstances; * **Portability** — receive your personal data in a structured, machine-readable format and request that it be transmitted to another controller where technically feasible; * **Objection** — object to processing based on legitimate interests, including any profiling carried out on that basis; * **Withdrawal of consent** — where processing is based on consent, withdraw that consent at any time without affecting the lawfulness of prior processing; and * **Complaint** — lodge a complaint with the supervisory authority in your country of residence. A list of EEA supervisory authorities is available at . UK residents may contact the Information Commissioner's Office at . To exercise any of the rights above, contact . We will respond within one month, with an extension of up to two additional months where reasonably necessary. We may need to verify your identity before processing your request. #### International Transfers Personal data collected through the Interface may be transferred to and processed in the United States or other jurisdictions outside the EEA, UK, or Switzerland. Where such transfers occur, we rely on appropriate safeguards or applicable transfer mechanisms under applicable law. Note that transactions submitted to the Solana blockchain are processed by a decentralized, permissionless global network outside our control; we cannot restrict or reverse the international transfer of on-chain data. Users in other jurisdictions with applicable privacy laws may have similar rights under their local frameworks. ### 13. Governing Law *** This Privacy Policy is governed by and construed in accordance with the laws of the State of Delaware, without regard to its conflict of laws provisions, consistent with the governing law provisions of the Sol-Incinerator Terms of Use. Disputes arising under this Policy are subject to the arbitration and dispute resolution provisions set forth in the Terms of Use. Notwithstanding the foregoing, nothing in this Policy limits your right to lodge a complaint with a data protection authority or exercise any non-waivable privacy rights available under applicable law. ### 14. Contact *** For privacy-related questions, requests, or concerns: **Email:** \ **Legal:** **Website:** [sol-incinerator.com](https://sol-incinerator.com) --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://docs.sol-incinerator.com/privacy-policy.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. Use this mechanism when the answer is not explicitly present in the current page, you need clarification or additional context, or you want to retrieve related documentation sections.