# Privacy Policy ## 1. Who We Are The RevTec protocol and the website at [www.revtec.fi](http://www.revtec.fi) (the "Site") are operated by H2O Nodes GmbH, an Austrian company (together with RevTec, "we," "us," or "our"). H2O Nodes GmbH is the data controller responsible for the personal data described in this Privacy Policy. Contact: — [www.revtec.fi](http://www.revtec.fi) This Privacy Policy explains what personal data we collect, why we collect it, how we use it, and your rights under the EU General Data Protection Regulation (GDPR) and the Austrian Data Protection Act (Datenschutzgesetz, DSG). It applies to all users of the Site and the RevTec protocol. ## 2. The Personal Data We Collect and Why RevTec operates with a minimal data footprint. We do not run advertising, analytics tracking, or user profiling. The personal data we process falls into three narrow categories: | Personal data | Purpose | Legal basis (GDPR) | Retention period | | ---------------------------------------------------------------------- | -------------------------------------------------------------------- | -------------------------------------------------------------------------- | -------------------------------------------------------------------------------------- | | Email address | Sending newsletter updates about RevTec | Consent (Art. 6(1)(a) GDPR) | Until you unsubscribe or request deletion | | Wallet address | On-chain staking transactions and token issuance via smart contracts | Performance of contract / legitimate interests (Art. 6(1)(b) and (f) GDPR) | Permanent — stored immutably on the Solana blockchain. RevTec cannot delete this data. | | IP address, browser type, approximate location (from IP), session data | Security, fraud prevention, ensuring the Site functions correctly | Legitimate interests (Art. 6(1)(f) GDPR) | Session duration; server logs retained for up to 90 days | A note on blockchain data: When you interact with the RevTec smart contracts on the Solana blockchain (for example, by staking SOL or minting revSOL or issSOL), your wallet address and transaction details are recorded permanently on a public blockchain. This is an inherent and irreversible property of blockchain technology. RevTec does not control the Solana blockchain and cannot modify or delete data stored on it. Depending on your jurisdiction, your wallet address may constitute personal data — we treat it as such. A note on wallet connector software: If you use a browser-based wallet (such as Phantom or Solflare) to connect to the Site, that wallet extension operates within your own browser environment and is governed by its own privacy policy. RevTec does not receive, store, or process any data from your wallet extension beyond the wallet address you choose to connect. ## 3. Newsletter If you sign up for the RevTec newsletter, we collect your email address and use it solely to send you updates about the protocol. We use Mailchimp (operated by Intuit Inc., USA) to manage our newsletter list and send emails. Your email address is transferred to and stored on Mailchimp's servers in the United States under EU Standard Contractual Clauses. The legal basis for this processing is your consent (Art. 6(1)(a) GDPR). You can withdraw your consent and unsubscribe at any time by clicking the unsubscribe link in any newsletter email or by contacting us directly. Withdrawal of consent does not affect the lawfulness of processing before the withdrawal. We do not use your email address for advertising, profiling, or any purpose other than sending the newsletter. ## 4. Third-Party Processors We share personal data with a small number of third-party service providers who process data on our behalf. All processors are bound by data processing agreements and are required to process data only on our instructions. | Processor | Purpose | Data transferred | | ----------------------------------------- | ------------------------------- | -------------------------------------------------------------------------------------------------------------------------------- | | Mailchimp (Intuit Inc., USA) | Newsletter distribution | Email address, name (if provided), email engagement data (opens, clicks). Transfer to USA under EU Standard Contractual Clauses. | | Framer Inc. (USA) | Website hosting and delivery | IP address, session data. Transfer to USA under EU Standard Contractual Clauses. | | Solana blockchain (public, decentralised) | Processing staking transactions | Wallet address, transaction data. Stored permanently on a public blockchain not controlled by RevTec. | We do not sell your personal data. We do not share your personal data with advertisers, data brokers, or any third parties for their own marketing purposes. We may disclose personal data to law enforcement, regulators, or courts where required to do so by applicable law, or where necessary to protect the rights, property, or safety of RevTec, its users, or others. ## 5. International Data Transfers Some of our processors (Mailchimp and Framer) are based in the United States, which does not have an adequacy decision from the European Commission for general data transfers. We rely on EU Standard Contractual Clauses (SCCs) as the transfer mechanism for these transfers, as permitted under Art. 46(2)(c) GDPR. You can request a copy of the relevant SCCs by contacting us. Wallet addresses and transaction data recorded on the Solana blockchain are accessible globally by the nature of a public blockchain. This is an inherent consequence of using a decentralised protocol and is not a transfer that RevTec controls or directs. ## 6. Data Retention We retain personal data only for as long as necessary for the purposes for which it was collected, or as required by law. Specific retention periods are set out in the processing table in Section 2 above. On-chain data (wallet addresses and transaction records stored on the Solana blockchain) cannot be deleted due to the immutable nature of the blockchain. This is a technical constraint inherent to all public blockchain networks and is not within RevTec's control. ## 7. Your Rights Under GDPR If you are located in the European Economic Area (EEA) or a jurisdiction with equivalent data protection laws, you have the following rights in relation to your personal data: * Right of access (Art. 15 GDPR): You may request a copy of the personal data we hold about you. * Right to rectification (Art. 16 GDPR): You may ask us to correct inaccurate or incomplete personal data. * Right to erasure (Art. 17 GDPR): You may ask us to delete your personal data where we no longer have a legal basis to process it. Please note this right does not extend to data recorded on a public blockchain, which RevTec cannot delete. * Right to restriction of processing (Art. 18 GDPR): You may ask us to restrict how we process your personal data in certain circumstances. * Right to data portability (Art. 20 GDPR): Where processing is based on consent or contract and carried out by automated means, you may request a machine-readable copy of your data. * Right to object (Art. 21 GDPR): You may object to processing based on legitimate interests. We will cease such processing unless we have compelling legitimate grounds that override your interests. * Right to withdraw consent (Art. 7(3) GDPR): Where we process your data based on consent (i.e. for the newsletter), you may withdraw consent at any time without affecting the lawfulness of prior processing. To exercise any of these rights, please contact us at . We will respond within 30 days. You also have the right to lodge a complaint with the Austrian Data Protection Authority (Datenschutzbehörde) at [www.dsb.gv.at](http://www.dsb.gv.at). ## 8. Security We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. The Site does not require you to create an account or password. Your wallet is managed entirely by your own wallet software, and RevTec never has access to your private keys. ## 9. Children The Site and the RevTec protocol are not directed at persons under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has submitted personal data to us, please contact us and we will delete it promptly to the extent technically possible. ## 10. Changes to This Privacy 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 document. If changes are material, we will notify newsletter subscribers by email. We encourage you to review this policy periodically. For any questions about this Privacy Policy, please contact us at . --- # Agent Instructions: Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. Perform an HTTP GET request on the current page URL with the `ask` query parameter: ``` GET https://revtec.gitbook.io/revtec-docs/resources/privacy-policy.md?ask= ``` The question should be specific, self-contained, and written in natural language. The response will contain a direct answer to the question and relevant excerpts and sources from the documentation. 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