Privacy Notice
Last updated: 11 November 2026
This notice explains how we use personal data in the Breakpoint HUB. It covers the HUB only; the Solflare wallet, app and website are covered by the Solflare Privacy Policy. This notice is information for you, not a contract, and you are not asked to consent to it.
1. Who is responsible
The controller is Solrise Finance Ltd, 2nd Floor, Ellen L. Skelton Building, Fishers Lane, Road Town, Tortola, British Virgin Islands, VG1110. Contact: [email protected]. Data Protection Officer: [email protected], Kolodvorska 12, Varaždin, Croatia.
2. What we collect
| Data | Details |
|---|---|
| X account data | X user ID, handle, display name, profile photo, account creation date, follower and post counts, verification status |
| Campaign posts and engagement | Your public posts mentioning @solflare, and the likes, replies, reposts, quotes and views they receive in the 72 hours after posting; your engagement with accounts we track |
| Campaign activity | Pool chosen, points and adjustments, codes redeemed, booth taps and scans, check-in, claim codes, tiers claimed, order status, staff review of your Privacy Selfie post, fair-play flags |
| Shipping data (Online pool) | Name, shipping address, sizes, email address and phone number |
| Technical data | IP address, browser and device information, security and CAPTCHA (Completely Automated Public Turing test to tell Computers and Humans Apart) results |
We get your X account data, public posts and engagement from X, through the X API (Application Programming Interface), when you sign in with X. The rest you give us directly or is created when you use the HUB.
We only read public X data and the data X provides when you sign in. We never ask for your X password and we cannot post on X for you.
3. Why we use it
| Purpose | Legal basis |
|---|---|
| Running the Campaign: sign-in, points, claims and delivery of merch | Our contract with you (the Campaign Terms) |
| Fair play: account checks and detecting bots, fake accounts and bought engagement | Our legitimate interest in a fair Campaign |
| Security of the HUB | Our legitimate interest in protecting the HUB |
| Questions, complaints and legal claims | Our legitimate interests or legal obligations |
Our checks may flag accounts automatically. If you think a decision about your account is wrong, contact us. We do not use your data for marketing outside the Campaign, and we do not sell it.
4. Who we share it with
- NOMU Labs Ltd (British Virgin Islands), our fulfilment partner, which collects your shipping data and ships your merch on our behalf and on our instructions. NOMU passes the data its carriers need to deliver your parcel.
- X, through which you sign in. We send X no other data about you.
- Hosting and security providers that host and protect the HUB.
- Professional advisers and authorities, where needed to establish or defend legal claims or required by law.
5. International transfers
Your data may be processed outside your country, including in the British Virgin Islands and the United States; NOMU stores data in the European Economic Area and the United States. Where data protected by EU or UK law leaves the EEA or the UK, we rely on an adequacy decision or on the standard contractual clauses approved by the European Commission and, for UK data, the UK International Data Transfer Addendum. You can ask us for a copy of the safeguards.
6. How long we keep it
We delete or anonymise Campaign data 90 days after the Campaign ends. NOMU deletes shipping data 90 days after delivery. Where a claim or dispute is open, we keep the relevant data until it is resolved.
7. Your rights
You can ask us to access, correct or erase your data, restrict its use, or receive it in a portable format. You can object at any time to our use of your data based on legitimate interests. You can revoke the HUB’s access to your X account at any time in your X account settings; you then stop earning points.
To use your rights, email [email protected]. You can also complain to a data protection authority, in particular in the country where you live or work. In the UK, that is the Information Commissioner’s Office (ico.org.uk).
8. Age
The HUB is not for anyone under 18. If we learn that a participant is under 18, we delete their data and cancel their entry.
9. Changes
We will post any update in the HUB and change the date at the top.