Privacy Policy

Effective date: 13 February 2025 · Last updated: 13 February 2025 · Version 1.0

Summary: Sol Clock stores all data locally on your device. We do not operate servers, collect personal information, or track your behaviour. The only network requests are read-only API calls to fetch publicly available price and blockchain data.

1. Data Controller

Sol Clock is developed and maintained by an independent developer operating under Australian law.

Entity: Sol Clock (sole proprietor)
Jurisdiction: Australia
Privacy contact: aardappvark@proton.me
Package name: com.solclock.app

For the purposes of the EU General Data Protection Regulation (GDPR) and UK General Data Protection Regulation (UK GDPR), the data controller is the developer identified above. If you are located in the European Economic Area (EEA) or United Kingdom and have questions about data protection, please contact us at the email address above.

2. What Data Sol Clock Collects

Sol Clock is designed with a privacy-first, local-only architecture. All data remains exclusively on your device in app-private storage (Android SharedPreferences and EncryptedSharedPreferences). No data is transmitted to any server we operate, because we do not operate any servers.

2.1 Data stored locally on your device

Data type	Purpose	Legal basis (GDPR)
Wallet public address	Display balance on clock face (opt-in)	Consent (Art. 6(1)(a))
Wallet app name	Show which wallet was used to sign in	Consent (Art. 6(1)(a))
SGT status & member number	Display Seeker Genesis Token verification	Consent (Art. 6(1)(a))
App preferences	Clock display settings, world clock cities, themes	Contract (Art. 6(1)(b))
Engagement data	Streak counts and daily interaction counters	Contract (Art. 6(1)(b))
Device timezone	Display local time and location label	Contract (Art. 6(1)(b))

2.2 Coarse location (ACCESS_COARSE_LOCATION)

Sol Clock requests Android coarse location permission solely for regulatory compliance — specifically to detect whether the device is located in a jurisdiction subject to international sanctions. This permission:

Is used only at app startup for sanctions screening
Returns approximate location (network-based, not GPS)
Is not stored, not logged, and not transmitted to any server
Is processed entirely on-device using Android Geocoder
Can be denied — the app will fall back to SIM card and network carrier country detection

Legal basis (GDPR): Legitimate interest (Art. 6(1)(f)) — compliance with international sanctions law. We have conducted a balancing test and determined that the compelling legal obligation to screen for sanctioned regions outweighs the minimal privacy intrusion of a single on-device coarse location check that is never stored or transmitted.

2.3 Data we do NOT collect

Names, email addresses, phone numbers, or any personally identifiable information (PII)
Private keys, seed phrases, wallet credentials, or passwords
Device identifiers, Android Advertising ID, or hardware serial numbers
Precise GPS location data
Usage analytics, behavioural tracking, or session data
Cookies, browser history, or web tracking data
Biometric data
Health, financial (beyond read-only public blockchain balance), or demographic data
Contact lists, call logs, SMS, camera, or microphone data

3. No Server-Side Data Storage

Sol Clock does not operate any backend servers, databases, cloud storage, or analytics infrastructure. We have no server-side systems capable of receiving, storing, or processing user data. All data exists exclusively in your device's app-private storage and is inaccessible to other applications.

4. Third-Party API Calls

Sol Clock makes read-only API requests to the following third-party services to retrieve publicly available data. These requests are HTTPS-encrypted and no user-specific data is included in the requests except where noted:

Service	Endpoint	Data retrieved	User data sent
Jupiter API	lite-api.jup.ag	SOL and SKR token prices	None
Raydium API	api-v3.raydium.io	SOL and SKR token prices (fallback)	None
CoinGecko API	api.coingecko.com	Prices and 24-hour change data (fallback)	None
Solana RPC	api.mainnet-beta.solana.com	Blockchain slot height; wallet SOL balance	Wallet public address*

* Your Solana wallet public address is sent to the Solana RPC endpoint only when you have opted in by signing in with your wallet. Wallet public addresses are publicly visible on the Solana blockchain and are not generally considered personal information, though GDPR may classify pseudonymous identifiers as personal data. The legal basis for this processing is your explicit consent (Art. 6(1)(a) GDPR).

Note on IP addresses: When Sol Clock makes HTTP requests to the above APIs, your device's IP address is inherently transmitted as part of the network protocol. This is standard for all internet-connected applications. We do not control how these third-party services handle IP addresses — please refer to their respective privacy policies.

5. Mobile Wallet Adapter (MWA)

Wallet sign-in uses Solana's Mobile Wallet Adapter protocol, which operates entirely locally between Sol Clock and your wallet app on the same device via Android inter-process communication. During the MWA sign-in process:

No data leaves your device
Your private keys remain exclusively within your wallet app
Sol Clock receives only your wallet's public address and wallet name
The sign-in can be revoked at any time by disconnecting in Settings

6. Data Security

We implement the following security measures to protect locally stored data:

Encryption at rest: Wallet-related data (public address, wallet name, SGT status) is stored using Android EncryptedSharedPreferences with AES-256-SIV encryption (via Google Tink)
Encryption in transit: All network communications use HTTPS/TLS encryption
App-private storage: All SharedPreferences files are stored in the app's private directory, inaccessible to other apps on non-rooted devices
No remote attack surface: With no server infrastructure, there is no server-side data to breach

7. Data Retention and Deletion

All data is stored locally on your device and is retained until you explicitly delete it. You can delete all Sol Clock data at any time by:

Disconnecting your wallet: Settings → Wallet → Disconnect (clears wallet-related data)
Clearing app data: Android Settings → Apps → Sol Clock → Storage → Clear Data (clears all preferences)
Uninstalling the app: Removes all Sol Clock data from your device

Since no data is stored on our servers, deletion from your device constitutes complete deletion.

8. International Data Transfers

Sol Clock does not transfer personal data to our servers (we have none). However, when Sol Clock makes API calls to third-party services (see Section 4), network requests may be routed through servers located outside your country of residence, including servers in the United States.

For users in the EEA or UK: these API calls are limited to fetching publicly available price data and, where you have consented, querying your wallet's public balance. We rely on the derogation under Article 49(1)(a) GDPR (explicit consent for wallet balance queries) and Article 49(1)(c) (necessary for the performance of the contract for price data retrieval).

9. Your Rights

9.1 European Economic Area & United Kingdom (GDPR / UK GDPR)

If you are located in the EEA or UK, you have the following rights under the GDPR:

Right of access (Art. 15) — You may request confirmation of whether we process your personal data and access to that data. Since all data is on your device, you already have full access.
Right to rectification (Art. 16) — You may correct any inaccurate data by modifying your app settings.
Right to erasure (Art. 17) — You may delete all data by clearing app data or uninstalling (see Section 7).
Right to restriction of processing (Art. 18) — You may restrict processing by revoking permissions in Android settings.
Right to data portability (Art. 20) — As all data is stored locally in standard Android SharedPreferences, it is inherently portable.
Right to object (Art. 21) — You may object to processing based on legitimate interest (sanctions screening) by denying the location permission.
Right to withdraw consent (Art. 7(3)) — You may withdraw wallet-related consent at any time by disconnecting your wallet.
Right to lodge a complaint — You may lodge a complaint with your local supervisory authority.

9.2 Australia (Privacy Act 1988)

Under the Australian Privacy Principles (APPs), you have the right to:

Access any personal information we hold about you (APP 12) — all data is on your device
Request correction of inaccurate information (APP 13)
Make a complaint to the Office of the Australian Information Commissioner (OAIC) at oaic.gov.au

9.3 California, USA (CCPA / CPRA)

If you are a California resident, you have the right to:

Right to know: What personal information is collected, used, and disclosed
Right to delete: Request deletion of personal information (see Section 7)
Right to opt-out of sale: We do not sell, share, or rent any personal information to any third party.
Right to non-discrimination: We will not discriminate against you for exercising your privacy rights
Right to correct: Correct inaccurate personal information via app settings
Right to limit use of sensitive personal information: We do not process sensitive personal information beyond the coarse location check described in Section 2.2

9.4 Japan (Act on Protection of Personal Information — APPI)

If you are located in Japan, you have the right to request disclosure, correction, cessation of use, and deletion of your personal information. All data is stored locally on your device and can be deleted by clearing app data or uninstalling. For inquiries, please contact us at the email address in Section 1.

9.5 South Korea (Personal Information Protection Act — PIPA)

If you are located in South Korea, you have the right to:

Access your personal information
Request correction or deletion of your personal information
Suspend processing of your personal information
Lodge a complaint with the Personal Information Protection Commission (PIPC)

All data is stored locally on your device. The personal information protection officer for this application can be contacted at aardappvark@proton.me.

9.6 Singapore (Personal Data Protection Act — PDPA)

If you are located in Singapore, you have the right to access and correct your personal data. We have designated the developer as the Data Protection Officer. For PDPA inquiries, contact aardappvark@proton.me.

10. Children's Privacy

Sol Clock is not directed at, marketed to, or intended for use by children under the age of 16 (or 13 in jurisdictions where that threshold applies, including the United States under COPPA). We do not knowingly collect any information from children. If you believe a child has provided data to the app, the data exists only on that child's device and can be removed by clearing app data or uninstalling the app.

11. Automated Decision-Making

Sol Clock performs one automated decision: sanctions region screening at app startup. If your device is detected in a sanctioned jurisdiction, the app displays an informational screen explaining the restriction. This automated decision is based on legitimate interest in regulatory compliance (GDPR Art. 22(2)(b)) and does not produce legal effects beyond restricting access to the app's informational features. You may contact us to contest this decision.

12. Data Protection Impact Assessment

We have conducted an internal assessment of our data processing activities and determined that a formal Data Protection Impact Assessment (DPIA) under GDPR Art. 35 is not required because:

We do not engage in large-scale processing of personal data
We do not systematically monitor public areas
We do not process special categories of data
Location data is processed on-device only and never stored or transmitted

13. Do Not Track

Sol Clock does not track users in any way and therefore inherently honours Do Not Track (DNT) signals. There is no tracking to disable.

14. Local Storage Disclosure (ePrivacy)

For the purposes of the EU ePrivacy Directive (2002/58/EC) and its national implementations: Sol Clock stores configuration data on your device using Android SharedPreferences and EncryptedSharedPreferences. This storage is strictly necessary for the functioning of the application (exempted from consent requirements under Art. 5(3)) and does not involve any tracking, profiling, or advertising functionality.

15. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will:

Update the "Last updated" date at the top of this page
Update the version number
Make the new version available within the app and at this URL

Continued use of Sol Clock after changes take effect constitutes acceptance of the updated policy. We encourage you to review this policy periodically.

16. Contact

For any privacy-related questions, concerns, or to exercise your data subject rights, please contact:

Email: aardappvark@proton.me
Subject line: "Privacy Inquiry — Sol Clock"

We aim to respond to all privacy inquiries within 30 days.

17. Governing Law

This Privacy Policy is governed by the laws of Australia, without regard to conflict of law principles. This does not affect your statutory rights under the laws of your country of residence, including rights under GDPR (for EEA/UK residents), CCPA/CPRA (for California residents), or other applicable local privacy laws.