Privacy Policy
This Privacy Policy explains how Splurge Tech LLC (“Splurge,” “we,” “us,” or “our”) collects, uses, discloses, and protects personal information in connection with our websites, applications, and related services, including https://www.splurge.tech(collectively, the “Services”).
Splurge operates a non-custodial gifting platform where creators and fans exchange USDC on the Base network directly between their own wallets. Splurge does not hold private keys or customer funds. Fiat on-ramp/off-ramp and KYC/AML processes are handled by independent, regulated third-party providers.
By using the Services, you acknowledge this Policy. If you do not agree, please do not use the Services.
1. Scope & Third-Party Links
This Policy applies to personal information processed by Splurge through the Services. It does not apply to third-party websites, apps, or services — including on/off-ramp or wallet/authentication providers — which maintain their own privacy policies. When you follow a link or use an embedded flow, review that provider’s policy directly.
2. Information We Collect
a) Information You Provide
Account & Profile: email, display name, username/handle, avatar/banner, and short bio.
Wallet Data You Link: public wallet address(es) on Base (EVM).
User-Generated Content: wishlist items, gift titles, images, and descriptions.
Communications & Support: messages or email contents and related metadata.
Marketing Preferences: opt-ins/opt-outs for waitlists, product updates, or newsletters.
b) Information Collected Automatically
Technical/Usage: IP address, device/OS/browser type, language, pages/events, timestamps, referrers, and performance metrics.
Cookies & Similar Tech: session, security, and preference cookies, plus first-party analytics (see “Cookies & Similar Technologies”).
c) Information from Third Parties
Wallet/Auth Provider (e.g., Privy): authentication status and anonymized identifiers; Splurge never receives private keys.
On/Off-Ramp Providers (e.g., Ramp, Coinflow): limited status signals or identifiers to reconcile transactions; Splurge does not receive or store KYC documents.
Blockchain/Public Sources: transaction hashes and public on-chain events tied to public addresses.
We may combine the above where permitted by law.
3. Blockchain Transparency
Transactions on Base are public and immutable. Public addresses and transaction metadata may be visible on-chain and are outside our control. Splurge cannot delete or alter blockchain records.
4. How We Use Information
Provide, operate, and improve the Services.
Authenticate users and enable wallet experiences.
Facilitate payments through regulated third-party providers.
Debug, analyze usage, and ensure security and fraud prevention.
Communicate with you about service, security, or product updates.
Comply with law and enforce our Terms and AUP.
Splurge does not sell personal information or use it for cross-context behavioral advertising.
5. Legal Bases (GDPR/UK GDPR)
Performance of a Contract (to provide the Services you request).
Legitimate Interests (to secure, maintain, and improve the Services).
Consent (for optional communications).
Legal Obligation (to comply with law or regulator requests).
6. Cookies & Similar Technologies
Splurge uses first-party cookies and identifiers to maintain sessions, security, and preferences. We may use privacy-respecting analytics in aggregate form. You can disable cookies in your browser; some features may not function properly.
We currently do not respond to “Do Not Track” (DNT) signals.
7. Disclosure of Personal Information
Wallet/Auth: Privy (embedded wallets and authentication).
On/Off-Ramps: Ramp Network, Coinflow (fiat ↔ crypto conversion, KYC handled by them).
Blockchain Infrastructure: Alchemy (RPC, webhooks).
Hosting/Database/CDN: Vercel and Supabase.
Monitoring & Security: error logging, analytics, and fraud detection tools.
Professional & Legal: advisors, auditors, or regulators as required.
Business Transfers: if Splurge is involved in a merger or acquisition, consistent with this Policy.
All service providers must protect personal data under appropriate contractual and technical safeguards.
8. Security
We implement administrative, technical, and organizational safeguards — including access controls, encryption in transit, and monitoring — to protect personal information. No system is 100% secure; users are responsible for protecting their own login and wallet credentials.
9. Data Retention
We retain information only as long as necessary for the purposes described here or as required by law. When no longer needed, data is deleted or de-identified.
10. Children’s Privacy
Splurge is not intended for individuals under 18. We do not knowingly collect personal information from minors. If you believe a minor has provided information, contact support@splurge.tech.
11. International Data Transfers
We may process information in the United States and other jurisdictions where our partners operate. Where required, we use safeguards such as Standard Contractual Clauses (SCCs) or equivalent mechanisms.
12. Your Privacy Rights
Depending on your location, you may have rights to access, correct, delete, restrict, or transfer your personal information, and to withdraw consent for optional processing. Submit requests to support@splurge.tech. We will verify your identity and respond as required by law. Blockchain data cannot be altered or erased.
13. U.S. State Privacy Notices (e.g., California CPRA)
Categories Collected: Identifiers (email, IP, wallet address, account info); Internet/Network Activity (usage logs, device/browser data); Commercial Information (transaction metadata, not full payment data); User Content (profile and gift materials).
Sources: directly from you, devices, blockchain, and service providers.
Purposes: as described in Section 4.
Disclosure: only to service providers listed above.
Sale/Sharing: Splurge does not sell or share personal information for cross-context advertising.
Sensitive Data: Splurge does not collect sensitive identifiers; ramps handle KYC independently.
Rights: access, deletion, correction, portability, and non-discrimination.
Requests: support@splurge.tech.
14. GDPR / UK GDPR
Controller: Splurge Tech LLC.
Legal Bases: see Section 5.
Your Rights: access, rectification, erasure, restriction, portability, objection, and consent withdrawal.
You may lodge a complaint with your local supervisory authority.
15. Canada (PIPEDA)
You may access or correct your information or withdraw consent where applicable. We may use U.S. or other foreign service providers; foreign laws may allow access by authorities. Contact support@splurge.tech for requests.
16. Australia
Individuals covered by the Australian Privacy Principles (APPs) may request access or correction. If data is transferred outside Australia, it receives protection comparable to this Policy and the APPs.
17. Business Transfers
In the event of a merger, acquisition, or asset sale, information may transfer to the successor entity subject to this Policy or a substantially similar one.
18. Changes to This Policy
We may update this Policy periodically. Updates will appear at https://www.splurge.tech/privacy with a new “Last Updated” date. Material changes may be notified via email to registered users.
19. Contact Us
Splurge Tech LLC
Email: support@splurge.tech
Website: https://www.splurge.tech