A. Information You Provide.

We may collect the following information when you interact with our Services:

Correspondence and Support: When you contact us for support or other enquiries, you may share with us your contact details (such as your email address) and contextual information relevant to your issue (such as wallet type, token or transaction details, device type, or error codes). This helps us respond and improve the Services.

You may choose to voluntarily provide other information to us that we have not solicited from you, and in such instances, you are solely responsible for such information.

B. Information Collected Automatically.

We collect the following information automatically when you access the Services:

Wallet Address: When you choose to connect a self-custodial wallet to terminal.seasons.wtf, we may collect the wallet address you use in order to display personalized on-chain analytics data in the My Node module, and to verify Node status against the Seasons on-chain protocol. We do not use wallet addresses for any other purpose.

Device Information: We may collect information about the device you use to access the Services, such as the device type, operating system, browser type, and screen dimensions. This helps us optimize the Services for different devices and diagnose technical issues. When a wallet connection, sign-in, account change, claim, swap or card payment fails in the Terminal, we may also receive an anonymous diagnostic report describing the failure: the error message, the steps that led to it, the connection method and the wallet product used (for example a mobile wallet adapter, a browser extension or a Seasons wallet), and the coarse device facts above. These reports do not include your wallet address, IP address, country, any account identifier, the amount of a purchase, or any transaction or payment identifier.

Country: Our network provider, Cloudflare, attaches to each request a two-letter country code based on your IP address. The Terminal reads it on each request only to decide whether card purchases can be offered where you are, which provider offers them (Stripe where it sells SOL in your currency, today in the United States, MoonPay elsewhere) and in which currency (US dollars, euros or pounds). We do not store it, it is not included in diagnostic reports, and it is not passed to Turnkey, MoonPay or Stripe: each determines your country itself.

Usage Information: We may collect information about how you use the Services, including the time you access the Services, pages visited, features and assets you interact with, and links you click. This helps us understand user behavior and make improvements to the Services.

We will not make decisions producing legal effects concerning you, or otherwise significantly affecting you, based solely on automated processing of your personal data, unless we have considered the proposed processing in a particular case and concluded in writing that it meets the requirements of applicable Data Protection Law.

We may collect and use information for our legitimate business purposes in accordance with the practices described in this Privacy Policy, including where this is necessary for the performance of a service, compliance with applicable legal or regulatory obligations, or in pursuance of our legitimate interests. In particular, our purposes for collecting and using information include:

Operating and managing the Services: To make the Services available to you and perform services requested by you, such as responding to your comments, questions, and requests; sending technical notices, updates, security alerts, and support and administrative messages; detecting, preventing, and addressing fraud, breaches of our Terms of Use, and threats or harm; and compliance with legal and regulatory requirements.

Improving the Services: To continually improve the Services and fulfil any other legitimate business purpose as permitted under applicable laws.

Merger or Acquisition: In connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition, financing, reorganization, or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another entity.

Security and Compliance with Laws: As we believe necessary or appropriate to operate and maintain the security or integrity of the Services, including to prevent or stop attacks on our systems or networks, investigate possible wrongdoing in connection with the Services, enforce our Terms of Use, and comply with applicable laws, lawful requests, and legal process, such as responding to subpoenas or requests from governmental authorities.

Facilitating Requests: To comply with your requests or directions.

Consent: Purposes for which we have obtained your consent as required by applicable laws.

Notwithstanding the above, we may use information that does not identify you (including information that has been aggregated or de-identified) for any purpose except as prohibited by applicable law.

We may share or disclose information we collect in accordance with the practices described in this Privacy Policy and for the purposes set out in the “Use of Information” section above. The categories of parties with whom we may share information include:

Affiliates: We may share information with our affiliates and related entities, including where they act as our service providers or for their own internal purposes.

Professional Advisors: We may share information with our professional advisors for purposes of audits and compliance with our legal obligations.

Service Providers: We may share information with third-party service providers for business purposes, including security threat detection, information technology and storage, and infrastructure services. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers we engage are restricted to using the information only on our behalf and in accordance with our instructions.

Regulatory and Government Authorities: In certain circumstances, we may be legally obliged to share personal data and other information with relevant regulatory or governmental authorities in accordance with applicable law.

Notwithstanding the above, we may share information that does not identify you (including aggregated or de-identified information) except as prohibited by applicable law.

Our Services may integrate technologies operated or controlled by other parties. For example, the Services may include links that hyperlink to websites, platforms, and other services not operated or controlled by us.

When you interact with other parties, including when you interact with third-party integrations within the Terminal, those parties may independently collect information about you and solicit information from you. The information collected and stored by those parties remains subject to their own policies and practices. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

In particular, terminal.seasons.wtf integrates the Jupiter exchange aggregator API. When you initiate a token swap via the Jupiter integration, your interaction is processed by Jupiter’s infrastructure and is governed by Jupiter’s applicable terms of service and privacy policy. Price previews are requested from Jupiter by our servers without any wallet address. When you ask for a swap you can sign, our servers send Jupiter the address of the wallet you are viewing in the Terminal, the token you pay with and the amount, so that Jupiter can build the transaction; the transaction your wallet signs is then passed to Jupiter to be sent to the Solana network. Jupiter charges its own fee on each swap (currently 0.1%), which the Terminal shows before you sign; we charge no fee and receive no part of Jupiter’s. We do not control how Jupiter processes your data and we are not responsible for Jupiter’s data practices.

Card purchases are provided by MoonPay (moonpay.com) and arranged through Turnkey (turnkey.com), the wallet infrastructure provider behind Seasons wallets. When you choose to pay by card, the Terminal asks Turnkey to open a MoonPay purchase for the address of the wallet you are viewing, with the amount, the currency and the payment method you chose. You then pay in MoonPay’s own window. MoonPay takes the payment, carries out the identity checks the law requires for card purchases (for example your name, date of birth and a photo of an identity document) and sends the digital dollars (USDC) or SOL it sells you directly to your wallet. Your card details and identity documents go to MoonPay only; we never receive or store them, and we never hold the money or the tokens you buy. The Terminal reads the status of the purchase from Turnkey and your wallet’s balance from the Solana network to know when the funds have arrived. MoonPay processes your information as an independent controller under its own terms of use and privacy policy (available at moonpay.com), and Turnkey under its own; we are not responsible for their data practices.

Where Stripe sells SOL in your currency (today in the United States), card purchases are provided by Stripe (stripe.com) instead, in Stripe’s own payment form shown within the Terminal. When you choose to pay by card, our servers ask Stripe to open a purchase of SOL for the address of the wallet you are viewing, locked so it cannot be sent anywhere else, with the amount and currency you chose, an identifier of your Seasons account (so that only you can read the purchase’s status), your IP address (so that Stripe can tell at once whether it can serve you where you are) and, if your account has a confirmed email address, that email address (so that you need not type it). Stripe takes the payment, carries out the identity checks the law requires for card purchases and sends the SOL directly to your wallet. Your card details and identity documents go to Stripe only; we never receive or store them, and we never hold the money or the SOL you buy. The Terminal reads the purchase’s status from Stripe and your wallet’s balance from the Solana network to know when the SOL has arrived, and shows Stripe’s own estimate of its fee and of the SOL your amount buys before you pay. Stripe processes your information as an independent controller under its own terms and privacy policy (available at stripe.com), and we are not responsible for its data practices.

Your browser remembers a card purchase that is still on its way (the wallet, the amount and when it started) in local Storage for up to 24 hours, so the Terminal can pick up where you left off if you close the tab. It is not sent to us and you can clear it in your browser at any time.

Similarly, by using a third-party wallet to connect to terminal.seasons.wtf, your interactions with any third-party wallet provider are governed by the applicable terms of service and privacy policy of that wallet provider.

We are committed to being transparent about the technologies we use on our Services.

A. Do we use cookies?

We do not set proprietary HTTP cookies on your device through the Services. We use local Storage only for conveniences on your own device, such as remembering a card purchase that is still on its way (see “Third-Party Services”); it is not used for tracking, profiling, or analytics.

We make limited use of session Storage — a browser-based storage mechanism that exists only for the duration of a single browser session and is automatically deleted when the browser tab or window is closed. Specifically, a technical flag (“adobeCleanFontAdded”) is written to session Storage by the font loading infrastructure to prevent duplicate font loading requests within a session. This entry contains no personal data and is not used for tracking, profiling, or analytics purposes.

B. What is a cookie?

A cookie is a small text file placed on your device by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie. Similar technologies include session Storage and local Storage, which allow websites to store data locally in your browser. session Storage holds data only for the duration of a single browser session; local Storage persists across sessions until manually cleared.

C. Third-party requests.

The Services load web font assets from Google Fonts (fonts.googleapis.com and fonts.gstatic.com). When your browser requests these assets, your IP address and browser data may be transmitted to Google’s servers. This is handled in accordance with Google’s Privacy Policy (policies.google.com/privacy). No advertising networks, third-party analytics platforms, or tracking pixels are loaded by the Services.

D. Wallet browser extensions.

If you have a Solana-compatible wallet browser extension installed (such as Phantom or Solflare), that extension may independently write its own data to your browser’s session Storage or local Storage when active on any web page, including our Services. Such data is set by the wallet extension itself, not by us, and is governed by the respective wallet provider’s privacy policy.

E. How to manage cookies and storage.

You can manage, block, or delete cookies and browser storage through your browser’s privacy or security settings. Doing so will not materially affect the functionality of the Services, as the Services do not depend on proprietary cookies or local Storage. For detailed guidance, please visit www.aboutcookies.org.

We implement and maintain reasonable administrative, physical, and technical security safeguards to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you. We will take reasonable technical and organizational precautions to protect any personal data we hold.

We retain information we collect for as long as it is necessary to fulfil the purpose for which it was collected, as outlined in this Privacy Policy, and to the extent permitted by applicable legal requirements. Where you request the deletion of your information, we may continue to retain and use your information as permitted or required under applicable laws, for legal, tax, or regulatory reasons, or for legitimate and lawful business purposes.

We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining it.

Please note that we have no ability to delete data that is stored on the Solana blockchain. Blockchain transaction data, including wallet addresses and transaction history, is stored on a public, immutable ledger and cannot be modified or erased by us.

Information collected through the Services may be transferred to, processed, stored, and used in the British Virgin Islands and in other jurisdictions where we or our service providers maintain facilities. Data protection laws in those jurisdictions may differ from those of your country of residence. Your use of the Services, or your provision of any information, therefore constitutes your consent to the transfer to, processing, usage, sharing, and storage of your information in the British Virgin Islands and other jurisdictions as set out in this Privacy Policy.

Where personal data is transferred to jurisdictions that may not offer equivalent protection to the Data Protection Act, 2021 of the British Virgin Islands, we will ensure that such transfers are conducted in accordance with applicable requirements, which may include having appropriate contractual undertakings in place with service providers who process personal data on our behalf.

You have certain data protection rights under the Data Protection Act, 2021 of the British Virgin Islands and, where applicable, other data protection legislation. These rights include the right to:

Be informed about the purposes for which your personal data is processed;

Access your personal data held by us;

Request rectification of inaccurate or incomplete personal data;

Request erasure of your personal data in certain circumstances;

Object to or request restriction of the processing of your personal data;

Withdraw any consent you have given to the processing of your personal data at any time, without affecting the lawfulness of processing carried out prior to withdrawal;

Lodge a complaint with the competent data protection authority in your jurisdiction.

Please note that we cannot edit or delete information that is stored on the Solana blockchain. This includes transaction data related to your blockchain wallet address, which is stored on a public, immutable ledger.

To exercise any of the above rights, please contact us using the details in Section 13 below. We will respond to your request within thirty (30) days. We may require specific information from you to confirm your identity and process your request. We retain information as necessary to fulfil the purposes for which it was collected and may continue to retain and use it as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.

The Services are intended for general audiences and are not directed at children. You must be at least 18 years of age to use the Services. We do not knowingly collect personal data from any person under the age of 18. If you are a parent or guardian and believe that a child has provided us with personal data, please contact us at contact@seasons.wtf and we will take steps to delete such information.

A. Roles.

The General Data Protection Regulation in the European Economic Area and the United Kingdom (“GDPR”) distinguishes between organizations that process personal data for their own purposes (“controllers”) and organizations that process personal data on behalf of other organizations (“processors”). Where applicable, we act as a controller with respect to personal data collected as you interact with the Services.

B. Your Data Subject Rights.

If you are a user in the European Economic Area or the United Kingdom, you have the following rights under the GDPR: the right to request access to and a copy of your personal data; the right to request rectification or erasure; the right to object to or restrict processing; and the right to request portability of your personal data. Additionally, if we process your personal data based on consent, you have the right to withdraw that consent at any time.

Please note that we cannot edit or delete information stored on the Solana blockchain, as this information is stored on a public, immutable ledger outside our control.

To exercise any of these rights, please contact us at contact@seasons.wtf. If you have concerns about our compliance, you also have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction.

We reserve the right to revise and reissue this Privacy Policy at any time. Any changes will be effective immediately upon our posting of the revised Privacy Policy. Where changes are material, we will endeavor to provide advance notice via an in-Service notification or through our official communication channels (see Section 13). For the avoidance of doubt, your continued use of the Services constitutes your acknowledgement of and consent to the revised Privacy Policy then in effect.

If you have any questions or comments about this Privacy Policy, our data practices, or our compliance with applicable law, please contact us: email: contact@seasons.wtf