Privacy Policy

1. Introduction

Replica ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform. Please read this policy carefully.

2. Information We Collect

2.1 Information You Provide

• Wallet addresses when you connect to the Platform
• Transaction data when you copy portfolios or create portfolios
• Profile information if you choose to create a creator profile
• Email address, name, and investor profile information provided via Early Access requests or newsletter signup
• Communications you send to us

2.2 Information Collected Automatically

• Device information (browser type, operating system)
• Usage data (pages visited, features used)
• IP address (anonymized for analytics)
• Cookies and similar tracking technologies
• Referring website or source

2.3 Blockchain Data

Please note that blockchain transactions are public by nature. Your wallet address and transaction history on the Solana blockchain are visible to anyone and are not covered by this Privacy Policy.

While blockchain data is inherently public, Replica strives to minimize the cross-referencing of off-chain personal data (such as email addresses or profile information) with on-chain wallet activity. We implement data minimization practices and do not publish or share associations between your personal identity and your wallet addresses.

3. How We Use Your Information

We use the information we collect to:

• Provide and maintain the Platform
• Process your transactions
• Improve and optimize the Platform
• Analyze usage patterns and trends
• Communicate with you about updates and changes
• Detect and prevent fraud or abuse
• Comply with legal obligations
• Enforce our Terms of Service

4. Information Sharing

We do not sell your personal information. We may share your information in the following circumstances:

• Service Providers: With third-party vendors who assist in operating the Platform (e.g., hosting providers, analytics services)
• Infrastructure Providers: Technical data (such as wallet addresses and transaction requests) may be shared with blockchain RPC providers (e.g., Helius), data oracles, and decentralized exchange protocols to ensure platform execution and transaction processing
• Legal Requirements: When required by law, court order, or governmental authority, or to protect our legal rights
• Business Transfers: In connection with a merger, acquisition, or sale of assets
• With Your Consent: When you have given us explicit permission

4.1 Third-Party Service Providers

We work with the following categories of service providers:

• Cloud hosting and infrastructure (Vercel, Railway)
• Blockchain RPC services (Helius)
• Analytics services (privacy-focused, anonymized data only)
• Email communication services (for newsletters and updates)

5. International Data Transfers

Your information may be transferred to and processed in countries outside your country of residence, including countries that may not have data protection laws equivalent to those in your jurisdiction.

When we transfer data internationally, we implement appropriate safeguards to protect your information, including:

• Standard Contractual Clauses approved by relevant authorities
• Data processing agreements with all third-party providers
• Technical security measures including encryption in transit and at rest

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide our services to you
• Comply with legal obligations (e.g., tax records may be retained for 7 years)
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

Specific retention periods:

• Account data: Duration of account plus 2 years after closure
• Transaction records: 7 years (for legal and tax compliance)
• Analytics data: 26 months (anonymized)
• Marketing communications: Until you unsubscribe

7. Data Security

We implement appropriate technical and organizational measures to protect your information, including:

• Encryption of data in transit (TLS 1.3) and at rest
• Regular security assessments and monitoring
• Access controls and authentication requirements
• Employee training on data protection practices

However, no method of transmission over the Internet or electronic storage is 100% secure. We cannot guarantee absolute security of your data. In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by law.

8. Your Rights

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information (subject to legal retention requirements)
• Restriction: Request restriction of processing in certain circumstances
• Portability: Receive your data in a structured, machine-readable format
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent where processing is based on consent

8.1 How to Exercise Your Rights

To exercise any of these rights, please contact us at privacy@usereplica.finance. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

8.2 Limitations

Your right to deletion applies to off-chain personal data only. Blockchain data (including wallet addresses and transaction history recorded on the Solana network) is immutable and cannot be deleted by Replica or any other party.

8.3 EEA Residents

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR), including the right to lodge a complaint with your local data protection authority.

9. Cookies and Tracking

We use cookies and similar technologies to enhance your experience on the Platform.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the Platform to function (e.g., session management, wallet connection state)
• Analytics Cookies: Help us understand how users interact with the Platform (anonymized, no personal identification)
• Preference Cookies: Remember your settings and preferences

9.2 Managing Cookies

You can control cookies through your browser settings. Disabling essential cookies may affect the functionality of the Platform. Most browsers allow you to:

• View and delete existing cookies
• Block all or specific cookies
• Set preferences for certain websites

10. Third-Party Links

The Platform may contain links to third-party websites or services, including decentralized exchanges, token issuers, and blockchain explorers. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any information.

11. Children's Privacy

The Platform is not intended for users under 18 years of age. We do not knowingly collect information from children. If you believe we have collected information from a child, please contact us immediately at privacy@usereplica.finance, and we will take steps to delete such information.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new policy on this page and updating the "Last updated" date. For significant changes, we will also notify you via email (if you have provided one) or through a prominent notice on the Platform.

Your continued use of the Platform after changes constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

13. Contact Us

If you have questions about this Privacy Policy, wish to exercise your rights, or have concerns about how we handle your data, please contact us:

• Privacy inquiries: privacy@usereplica.finance
• General inquiries: @andres_build on X (Twitter)