Privacy Policy

Effective date: 21 July 2026  |  Last updated: 7 August 2026

1. Introduction

This Privacy Policy describes how MidMightBit Games ("we", "us", or "our") handles information in connection with the Sol Card Games mobile application ("App"). We have written this policy to be plain and direct: Sol Card Games collects no personal data and needs no account. Every game works fully offline; the only things that ever leave your device are anonymous, opt-out usage analytics (Section 9) and — only if you choose to use them — the optional wallet features (Section 7). None of these can identify you. We are committed to your privacy by design and by default.

Please read this policy carefully. If you do not agree with any part of it, please discontinue use of the App.

2. Data Controller

For the purposes of the General Data Protection Regulation (GDPR), the UK GDPR, and equivalent legislation, MidMightBit Games is the data controller for any information processed in connection with the App. As described throughout this policy, we process no personal data through any external system.

3. Data We Collect

We operate no user accounts and use no advertising SDKs. The only information that ever leaves your device is (a) anonymous, aggregate usage analytics (see Section 9) and (b) the optional wallet connection you may initiate in Settings (see Section 7), which talks to your own wallet app. Neither can identify you.

4. Local Storage

The App stores the following information locally on your device using Android's SharedPreferences mechanism:

• Your game statistics (such as games played and games won, per game)
• Your daily-challenge progress and streak
• Your achievement / unlock progress
• In-progress solitaire deals, saved so an interrupted game can resume
• Your in-app settings and preferences (such as haptics, timer, themes, and accessibility options)
• The Free tier's daily hint counter, and the Pro unlock flag with its payment signature (if purchased)
• A flag recording that you have accepted the in-app disclaimer
• The public key of a Solana wallet, only if you choose to connect one (see Section 7)

This data is stored solely on your device and is never transmitted to us or to any third party. It is deleted when you uninstall the App, with one exception you control: if you buy the optional Pro unlock, the small record that your device owns Pro (a flag and the payment's transaction signature — no personal data) may be included in Android's standard Auto Backup to your own Google account, so your purchase survives reinstalling the App. Nothing else is backed up, and you can turn Android backup off in your device settings. Independently of any backup, your Pro unlock is recorded permanently on the public blockchain and can be restored at any time from Settings.

5. Network Requests

Sol Card Games requires no internet connection to play — every game works fully offline, in aeroplane mode. There are no crash-reporting payloads, no remote configuration fetches, and no advertising network traffic. The only outbound requests are: the anonymous usage analytics described in Section 9; and, only if you use them, the optional wallet features in Section 7 (connecting a wallet, and — if you choose to buy Pro — reading public blockchain data to build the payment you sign yourself).

One such optional activity is the wallet connection (Section 7): the Solana Mobile Wallet Adapter communicates with your installed wallet app to complete Sign In With Solana. No gameplay data or personal information is transmitted to us at any time — the only endpoint we operate is the serverless analytics counter described in Section 9, which stores nothing that can identify you.

6. No Accounts Required

Sol Card Games requires no account registration, no email address, no username, no password, and no sign-in of any kind. You can use every feature of the App without identifying yourself to us in any way.

7. Wallet Connection (Optional)

Sol Card Games offers an optional feature to connect a Solana wallet from Settings using the Solana Mobile Wallet Adapter (MWA) and Sign In With Solana (SIWS). Connecting a wallet is entirely optional — every game is fully playable without one.

• Only your public key (wallet address) is read and stored locally in SharedPreferences.
• Your private key and seed phrase are never accessed, read, stored, or transmitted by Sol Card Games under any circumstances.
• Your public key is used only to show which wallet is linked, and is never sent to us or any third party.
• You may disconnect at any time from Settings, which removes the stored public key from your device.

The one exception to "no transactions" is the optional Pro unlock: if — and only if — you choose to buy it, the App builds a payment transaction that you sign and submit from your own wallet in SOL or SKR. Even then, Sol Card Games never accesses your private key or seed phrase and never takes custody of your funds. To prepare the optional Pro payment and to restore purchases, the App sends your wallet's public address to Solana RPC providers: api.mainnet-beta.solana.com and, as a fallback, solana-rpc.publicnode.com (Allnodes). These providers receive your IP address and the public address. Private keys never leave your wallet.

8. Permissions

The App declares the following Android permissions and uses them solely as described:

The App declares no location, contacts, storage, camera, microphone, or telephony permission. The sanctions region check (see our Sanctions page) reads only the SIM's country code and the device locale, both of which are available without any permission, entirely on-device. No permission is used to collect, read, or transmit personal data to us.

9. Anonymous Usage Analytics

Sol Card Games sends a small number of anonymous, aggregate usage signals to help us understand how the app is used (for example, that the app was opened, a game was won, or a wallet was connected). This contains no advertising SDKs, no third-party analytics SDKs (such as Firebase, Mixpanel, or Amplitude), and no cross-app tracking or profiling.

What is and is not collected:

• Each signal is a single opaque event name from a fixed list (e.g. app_open, game_won, daily_completed) — never scores, card state, or any gameplay content.
• No user ID, device ID, advertising ID, or wallet address is sent or stored.
• Your IP address is never stored. Our analytics endpoint (a serverless function) derives only an approximate country/city at the edge and immediately discards the IP; only aggregate counts per event, country, and date are retained.
• The data cannot be linked back to you or to any individual device or session.

Because this data is anonymous and aggregate, it is not personal data under the GDPR, UK GDPR, CCPA, or the Australian Privacy Act. You can turn it off at any time from Settings → Privacy, and builds without our analytics key send nothing at all.

10. Children's Privacy

Sol Card Games is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. Because the App collects no personal data from any user, this commitment is satisfied structurally. If you believe a child under 13 has provided personal information in connection with the App, please contact us at aardappvark@proton.me and we will take appropriate action.

11. International Data Transfers

Sol Card Games collects no personal data. The App's only outbound traffic — the anonymous analytics signals (Section 9) and the public Solana RPC lookups used by the optional wallet features (Section 7) — may be processed on infrastructure located outside your country. Because these requests contain no personal data beyond the transient handling of your IP address by the receiving service, no regulated international transfer of personal data occurs in connection with this App.

12. Your Rights

Various privacy laws around the world grant individuals rights over their personal data. Because Sol Card Games holds no personal data about you, most of these rights are satisfied automatically. For completeness, the table below lists the key rights and our response:

To exercise any right or to submit a privacy inquiry, contact us at aardappvark@proton.me. We will respond within 30 days. Because we hold no data, we will typically confirm that immediately.

13. Data Retention

The only data associated with your use of Sol Card Games — your locally stored game statistics, progress, preferences, and the public key of a connected wallet (if any) — is retained on your device for as long as the App is installed. A connected wallet's public key is also removed as soon as you disconnect it. This data is automatically and permanently deleted when you uninstall the App, with one exception you control: the Pro unlock record may persist in your own Google backup as described in Section 4, and the purchase itself remains on the public blockchain. We retain no copy of any such data.

14. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top of this page and, where required by law, notify you via the App or the Dapp Store listing. Continued use of the App after a policy update constitutes acceptance of the revised policy.

15. Contact

16. Governing Law

This Privacy Policy is governed by the laws of the Commonwealth of Australia. Any disputes arising under or in connection with this policy shall be subject to the exclusive jurisdiction of the courts of Victoria, Australia.