Privacy Policy

This Privacy Policy explains how Splurge Tech LLC (“Splurge”, “we”, “us”, or “our”) collects, uses, discloses, and safeguards personal information in connection with our websites, applications, and related services, including https://www.splurge.tech (the “Services”).

Splurge operates a non-custodial gifting platform where creators and fans exchange USDC on Base directly between their own wallets. Splurge does not hold customer funds or private keys. Fiat on-ramp/off-ramp and KYC/AML procedures are performed by regulated third-party providers.

1. Scope & Third-Party Links

This Policy applies to personal information processed by Splurge. It does not apply to third-party sites or services (wallet providers, on/off-ramps, or analytics tools). When you access those, review their privacy policies.

2. Personal Information We Collect

a) Information You Provide

b) Information Collected Automatically

c) Information from Third Parties

3. Blockchain Data

Transactions on Base are recorded on a public blockchain. Public addresses and metadata are visible to anyone and cannot be removed. While Splurge may associate wallet addresses with user profiles for functionality, we cannot delete or alter on-chain records.

4. How We Use Personal Information

5. Legal Bases for Processing (GDPR/UK GDPR)

6. Cookies & Similar Technologies

Splurge uses first-party cookies for login sessions, preferences, and security. You may disable cookies in your browser; some features may not work correctly. For more information, see our Cookie Policy.

7. Disclosure of Personal Information

8. Security

We employ administrative, technical, and organizational safeguards including encryption, access control, and continuous monitoring. Users are responsible for keeping their wallet and login credentials secure.

9. Data Retention

Personal information is retained only as long as necessary for service provision, compliance, or dispute resolution. Data is deleted or anonymized when no longer required.

10. Children’s Privacy

Splurge is not directed to individuals under 18. We do not knowingly collect information from minors. Contact support@splurge.tech for removal requests.

11. International Data Transfers

Data may be processed in the U.S. or other jurisdictions. Transfers are protected by Standard Contractual Clauses or equivalent safeguards.

12. Your Privacy Rights

To exercise these rights, contact support@splurge.tech. We may need to verify your identity before responding.

13. Regional Disclosures

California (CPRA/CCPA)

We collect identifiers (email, wallet address, IP), usage logs, and limited commercial data. We do not sell personal information or share it for behavioral advertising. California users may request access, correction, or deletion of their data without discrimination.

GDPR & UK GDPR

Splurge Tech LLC acts as the Data Controller for user information. Users have rights to access, rectify, erase, restrict, or object to processing, and to data portability. Complaints may be filed with a supervisory authority in your country.

PIPEDA (Canada)

We comply with Canadian privacy law. You may access or correct your data, withdraw consent, or inquire about storage locations. A nominal fee may apply for access requests.

Australian Privacy Act

Under the Australian Privacy Principles (APPs), users may request access or correction of their personal data and submit complaints. International transfers are safeguarded.

14. Business Transfers

If Splurge Tech LLC undergoes a merger, acquisition, or sale of assets, personal data may transfer to the successor entity subject to this Policy.

15. Policy Updates

We may revise this Policy periodically. The latest version will always be available at https://www.splurge.tech/legal/privacy-policy. Major updates may be emailed to registered users.

16. Contact Us