Privacy Policy

Last Updated: March 12, 2026

1. Our Commitment to Your Privacy and Data Minimization

At ROTH MATE EV (SoulMinter) ("we," "us," or "our"), your privacy is paramount. This Privacy
Policy outlines our practices regarding the collection, use, and processing of information when you use
our web-based platform (the "Platform") to create and manage custom tokens on the Solana
blockchain. Our platform is built on the principle of data minimization, meaning we primarily interact
with information essential for the technical operation of our service, which includes public blockchain
data, technical identifiers, and certain usage data collected via analytics.

We are committed to transparency and compliance with global data protection principles, including the
General Data Protection Regulation (GDPR) (EU) 2016/679 and the California Consumer Privacy Act
(CCPA). While our core service is designed to operate without collecting directly identifiable personal
data, we acknowledge that certain technical information and analytics data may be considered personal
data under these regulations. This policy explains how we handle such information and your rights
concerning it.

By using the Platform, you acknowledge and agree to the practices described in this Privacy Policy. If
you do not agree with these practices, please do not use the Platform.

2. Who We Are (and What We Are Not)

SoulMinter provides a technical tool for interacting with the Solana blockchain. We are not a data
controller in the traditional sense for personal data that directly identifies you, as our primary
operations do not involve determining the purposes and means of processing such data. However, with
the introduction of analytics and other technical data collection, we recognize our responsibilities under
applicable data protection laws regarding this information.

For any questions regarding our data practices or this policy, you can contact us at:
main@soulminter.io

3. Information We Interact With (Public, Technical, and

Analytics Data)

SoulMinter is engineered to function with minimal collection of personal data. We interact with the
following types of information, which are either publicly available on the blockchain, are technical
details necessary for the service, or are collected for analytics purposes to improve our service. Where
such information could be considered personal data under applicable laws, we process it with due
regard for your privacy rights.

3.1. Public Wallet Addresses

When you connect your Solana-compatible wallet to the Platform, your public wallet address is
transmitted. This is a public identifier on the blockchain, essential for enabling your interaction with
the Solana network to create or manage tokens. We never collect, store, or have access to your private
keys, seed phrases, or any other sensitive wallet information. Your wallet remains entirely under your
control.

3.2. Token Creation and Management Details

Information you provide to create a token (such as the token name, symbol, decimals, initial supply) or
to manage an existing token (such as updating metadata or modifying authorities) is used to generate
the respective transactions on the blockchain. This information is inherently public, as it forms part of
the token's on-chain identity and metadata, and is generally not considered personal data.

3.3. Technical Connection Information

When you access the Platform, certain technical information is automatically transmitted:

• IP Addresses: Your IP address is used solely for immediate security purposes, such as real-time
  rate limiting to prevent abuse and denial-of-service attacks, and for general service stability. We
  do not store IP addresses in a way that links them to individual users, nor do we use them to
  identify you, track your browsing habits, or for marketing purposes.
• Blockchain Transaction Data: All details of transactions you initiate on the Solana blockchain
  through our Platform (e.g., token creation, authority management, fee payments) are publicly
  available and permanently recorded on the Solana blockchain. SoulMinter does not control the
  Solana blockchain, and all data on the blockchain is public and immutable.
• Aggregated Usage Data: We may gather anonymized and aggregated data about how the
  Platform is used (e.g., total number of tokens created, most frequently used features). This data
  cannot be linked back to any individual and is used purely for statistical analysis to improve our
  service.

3.4. Analytics Data (Vercel and Google Analytics)

We use Vercel Analytics and Google Analytics to collect information about how users interact with our
Platform. These services help us understand user behavior, identify areas for improvement, and
optimize the user experience. Both are designed to be privacy-friendly and primarily collect
anonymized data. However, certain technical identifiers or usage patterns collected by these services
may, in some jurisdictions, be considered personal data. The data collected includes, but is not limited
to, page views, unique visitors, and session duration.

• Vercel Analytics: This service does not use traditional cookies for tracking; instead, it relies on
  privacy-preserving methods to gather insights. Vercel Analytics is only enabled if you consent
  through our cookie statement. If you opt-out, Vercel Analytics will be disabled.

• Google Analytics: This service uses cookies and similar technologies to collect information
  such as your IP address, browser type, operating system, referring URLs, device information,
  and how you interact with our Platform. Google Analytics is only enabled if you consent
  through our cookie statement. If you opt-out, Google Analytics will be disabled.

3.5. Information from Third-Party Service Providers

We integrate with various third-party services that may interact with your device or browser. These
services may set cookies or use other local storage mechanisms for their functionality. This includes:

• Google Fonts: Used for font loading optimization. Google Fonts may set cookies or use other
  local storage mechanisms to improve performance and deliver fonts efficiently.
• Decentralized Storage Networks (Lighthouse, Pinata, Arweave): Used for storing token
  metadata. We route your metadata to these permanent, decentralized storage networks. These
  third-party services may set cookies or use other local storage mechanisms related to file upload
  and storage routing.
• Solana RPC Endpoints: When interacting with the Solana blockchain, various Solana API
  endpoints may set cookies or use other local storage mechanisms necessary for communication
  and transaction processing.
• Wallet Providers (e.g., Phantom, Solflare): When you connect your wallet, these providers
  may set cookies or use other local storage mechanisms to manage connection states and
  facilitate interactions with their services.

4. How We Use Information

Our use of information is strictly limited to the following technical, operational, and analytical
purposes:

• To Facilitate Token Services: We use the public wallet address and parameters you provide to
  enable the creation, management, and modification of tokens on the Solana blockchain as per
  your instructions.
• To Ensure Platform Security: IP addresses are used for real-time rate limiting and abuse
  prevention. This is a technical security measure and does not involve personal data processing
  or storage for identification purposes.
• To Improve Service Functionality and User Experience: Aggregated and anonymized usage
  data, including insights from Vercel Analytics and Google Analytics, helps us understand
  general platform usage patterns, identify areas for improvement, and enhance functionality and
  user experience.
• To Provide Essential Service Functionality: Certain information stored locally (e.g.,
  walletName, wallet-adapter-react-connection, autoConnect in
  localStorage) is used to remember your preferences and maintain your session for essential
  platform functionality. These are not traditional cookies but serve similar functional purposes.

5. Data Storage and Security

• No Directly Identifiable Personal Data Storage: SoulMinter is designed to minimize the
  storage of directly identifiable personal data. We do not store personal data such as names,
  email addresses, or physical addresses.
• Blockchain Data: Information recorded on the Solana blockchain (e.g., token creation details,
  transaction IDs) is immutable and publicly accessible. This data is not controlled by SoulMinter.
• Decentralized Metadata Storage: Token metadata (including descriptions and images) is
  routed to decentralized, permanent storage networks, primarily Lighthouse, with fallbacks to
  Pinata and Arweave. These networks distribute data across multiple nodes making it publicly
  accessible via content hashes. This is not personal data.
• No Private Key Storage: SoulMinter never collects, stores, or has access to your private keys
  or seed phrases. All blockchain interactions are performed directly by your connected wallet.
• Security Measures: We implement appropriate technical and organizational measures to
  protect the information we interact with against unauthorized access, alteration, disclosure, or
  destruction.

6. Information Sharing and Disclosure

Because SoulMinter minimizes the collection and storage of directly identifiable personal data, we
have no such data to sell, rent, or trade to third parties. Any information we interact with (public wallet
addresses, token parameters, technical connection data, and analytics data) is handled as follows:

• Public Blockchain: All token creation and transaction data is publicly recorded on the Solana
  blockchain, which is transparent and immutable.
• Service Providers: We use third-party services (e.g., Vercel for hosting and analytics,
  decentralized storage networks like Lighthouse, Pinata, and Arweave, cloud hosting providers
  for server infrastructure) that process technical data necessary for the Platform's operation.
  These providers are selected based on their commitment to security and data protection. While
  they may process technical information or usage data, they do not receive directly identifiable
  personal data from SoulMinter.
• Legal Compliance: In rare circumstances, we may be compelled by law to disclose technical
  information (e.g., IP addresses for specific security investigations) if required by a valid legal
  process. However, as we do not link this information to personal identities, such disclosures
  would not involve directly identifiable personal data.

7. International Data Transfers

As SoulMinter operates globally and utilizes service providers that may be located in different
jurisdictions (e.g., Vercel's infrastructure), technical information and analytics data may be transferred
to, and processed in, countries outside of your residence, including, but not limited to the United States.

We ensure that any such transfers comply with applicable data protection laws by relying on
appropriate safeguards, such as standard contractual clauses approved by relevant authorities, or by
ensuring that the service providers are certified under recognized data transfer frameworks.

8. Your Data Protection Rights

While SoulMinter primarily operates without collecting directly identifiable personal data, we
acknowledge that certain technical information and analytics data may be considered personal data
under regulations like GDPR and CCPA. Therefore, you may have the following rights concerning your
data:

• Right to Information/Access: You have the right to know what information we interact with
  and how it is used. This Privacy Policy serves to provide this information.
• Right to Object to Processing: You have the right to object to the processing of your data for
  certain purposes, such as analytics. You can manage your cookie preferences and opt-out of
  non-essential data collection through our cookie consent mechanism.
• Right to Deletion/Erasure: While we do not store directly identifiable personal data, if you
  believe we hold any information that should be deleted, please contact us.

To exercise any of these rights, or if you have any questions about our data practices, please contact us
at main@soulminter.io. We will investigate any such claims thoroughly and transparently.

9. Cookies and Other Local Storage Technologies

We use cookies and other local storage technologies (such as localStorage) to ensure the proper
functioning of our Platform and to collect analytics data. This section explains the types of technologies
we use and how you can manage your preferences.

9.1. What are Cookies and Local Storage?

• Cookies: Small text files stored on your device by your web browser. They are widely used to
  make websites work or to improve their efficiency, as well as to provide reporting information.
• Local Storage (e.g., localStorage): A web storage feature that allows websites to store data
  directly in the browser. Unlike cookies, data in localStorage does not automatically expire and
  is not sent to the server with every HTTP request.

9.2. How We Use Them

We categorize the cookies and local storage items we use as follows:

• Essential/Functional: These are strictly necessary for the operation of our Platform and to
  provide the services you request. They enable core functionalities like wallet connection state
  (walletName, wallet-adapter-react-connection, autoConnect in
  localStorage), basic Next.js framework functions, technologies used by storage providers and

RPC endpoints. These do not require your consent as they are essential for the service to
function. If you do not consent to these technologies you need to stop using the platform.

• Analytics: We use Vercel Analytics and Google Analytics to collect anonymized data about
  your usage of the Platform. This helps us understand how our Platform is used and allows us to
  improve it.
  - Vercel Analytics: May set cookies or use other privacy-preserving methods. This
  service is only activated if you provide your consent through our cookie statement. If
  you choose to opt-out, Vercel Analytics will be disabled.
  - Google Analytics: Uses cookies and similar technologies. This service is only activated
  if you provide your consent through our cookie statement. If you choose to opt-out,
  Google Analytics will be disabled.
• Optional: Our Platform integrates with third-party services (e.g., Google Fonts) that may set
  their own cookies or use local storage mechanisms. These are used to enhance user experience
  and may collect data according to their own privacy policies. Your consent is required for these
  technologies.

9.3. Your Cookie Consent and Management

Upon your first visit to our Platform, you will be presented with a cookie consent banner. This banner
will provide you with clear information about the types of cookies and local storage technologies we
use and allow you to:

• Accept All: Consent to the use of all cookies and local storage technologies.
• Manage Preferences: Customize your preferences by enabling or disabling specific categories
  of non-essential cookies (e.g., analytics, optional). You will always have the option to opt-out of
  non-essential cookies.

You can change your cookie preferences at any time by accessing the cookie settings link, typically
found in the footer of our website. Please note that disabling certain cookies may affect the
functionality of the Platform.

10. Links to Other Sites

Our Platform may contain links to other sites not operated by us. We strongly advise you to review the
Privacy Policy of every site you visit, as we have no control over and assume no responsibility for their
content, privacy policies, or practices.

11. Children's Privacy

Our Service is not intended for anyone under the age of 13 ("Children"). We do not knowingly collect
any personal data from anyone under 13, as our system is designed not to collect directly identifiable
personal data from any user. If you are a parent or guardian and believe that any personal data related to

your child has been inadvertently processed by our Platform (which should not occur), please contact
us immediately.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or legal
requirements. We will notify you of any significant changes by posting the new Privacy Policy on this
page and updating the "Last Updated" date. You are advised to review this Privacy Policy periodically.
Changes are effective when posted.

13. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us:

By email: main@soulminter.io

Service Provider Details: ROTH MATE EV, Hungary, 91818627-1-28