Privacy Policy

1. Overview

SurferX Learn Hub ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains what information we collect, how we use it, how we protect it, and your rights regarding your data.

This Privacy Policy applies only to learn.surferx.io and the services we provide. We are not responsible for the privacy practices of third-party websites linked from our site. Please review their privacy policies separately.

Effective Date: May 2026

2. Data We Collect

We collect data in the following ways:

A. Information You Provide

• Wallet Address: When you connect your XRPL wallet, we collect your public wallet address (e.g., "rXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX")
• Contact Information: If you contact us via email or Telegram, we may collect your email address, Telegram handle, or other contact details
• User Messages: Any messages you send to the AI guide are temporarily processed to generate responses

B. Wallet & Blockchain Data

• Token Holdings: When you verify your NFT tier, we query the XRP Ledger to count your SurferX NFTs and SRFX token holdings
• NFT Details: We retrieve publicly available NFT metadata (artwork, rarity traits, collection name) from the blockchain
• Transaction History: We may display your recent transactions with your permission

All blockchain data is publicly available on the XRP Ledger and is not private. Your wallet address is pseudonymous but can be linked to your identity if you choose to disclose it.

C. Usage Data (Automatic Collection)

• IP Address: Your device's IP address is logged when you visit the site
• Browser & Device Information: Browser type, version, operating system, device model
• Pages Visited: Which pages and sections you browse
• Time & Duration: When you visit and how long you spend on the site
• Referrer: The website you came from (if any)
• Clicks & Interactions: Which buttons, links, and features you interact with
• AI Guide Conversations: Questions you ask the AI guide (for improvement purposes)

3. Wallet Address & Holdings (Read-Only)

What We Access

When you connect your wallet to SurferX Learn Hub:

Important Clarifications

• We do NOT have your seed phrase or private keys
• We do NOT have access to your funds
• We cannot initiate transactions on your behalf
• Every transaction requires your explicit signature in your wallet app
• Your wallet address is publicly visible on the blockchain — connecting to our site does not make it private

Data Storage

We store your wallet address and associated data (holdings count, tier level, verification status) to provide personalized features such as:

• Displaying your holder tier and badge
• Showing your marketplace position on the leaderboard
• Tracking your learning progress (if applicable)
• Enabling tier-specific multipliers for rewards

4. Usage Data & Analytics

Analytics Services

We use analytics tools to understand how you interact with our site and improve the user experience. Tools may include:

• Google Analytics / Vercel Analytics: Page views, session duration, geographic location (anonymized)
• Error Tracking: Technical errors and crashes to help us fix bugs
• Heatmaps & User Behavior: Which sections of the site receive the most attention

Data Collected

Analytics services collect:

• Pages visited and time spent on each page
• Clicks and interactions with buttons and links
• Country/region (based on IP address, aggregated)
• Device type (mobile, desktop, tablet)
• Browser type and version
• UTM parameters (campaign source, if applicable)

Anonymous & Aggregated

Analytics data is typically aggregated and anonymized, meaning it cannot directly identify you. However, combined with other data, it may be possible to connect it to your wallet address.

5. Cookies & Local Storage

What Are Cookies?

Cookies are small text files stored on your device to remember information about your visit. We use cookies for:

• Session Management: Keeping you logged in and connected to your wallet
• Preferences: Remembering your language, theme, and UI preferences
• Analytics: Tracking user behavior to improve the site
• Advertising (if applicable): Serving relevant content and ads

Local Storage

We may use browser local storage to store:

• Your learning progress and preferences
• Wallet connection status and settings
• Cached data to improve performance

Cookie Control

Most browsers allow you to control or delete cookies:

• Chrome: Settings → Privacy & Security → Cookies
• Safari: Preferences → Privacy → Manage Website Data
• Firefox: Preferences → Privacy & Security → History

Disabling cookies may affect site functionality. You can also use privacy-focused browser extensions to block trackers.

6. How We Use Your Data

We use the information we collect for the following purposes:

7. Third-Party Sharing

What We Do NOT Share

What We MAY Share

We may share limited information with:

Service Providers

• Hosting & Infrastructure: Vercel, cloud providers (to keep the site running)
• Analytics Providers: Google Analytics, Vercel Analytics (to understand traffic)
• Error Tracking: Sentry, similar services (to monitor and fix technical issues)
• Email Services: If we send you notifications or newsletters (with consent)

These service providers are contractually obligated to use your data only for the purposes we specify and to maintain confidentiality.

Blockchain Data (Public)

Your wallet address and NFT holdings are permanently recorded on the XRP Ledger, a public blockchain. This data is viewable by anyone and cannot be made private or deleted.

Legal Requirements

We may disclose your information if required by law, regulation, or court order. This includes:

• Law enforcement requests (with proper legal process)
• Compliance with financial regulations (AML/KYC)
• Prevention of fraud or illegal activity
• Protection of our rights or safety

Business Transfers

If SurferX is acquired, merged, or undergoes asset sale, your data may be transferred as part of that transaction. We will notify you of any such change and any choices you may have regarding your data.

8. Data Retention

We retain your data for as long as necessary to provide our services:

• Wallet Address & Holdings: Retained while you have an account with us. Deleted if you request deletion.
• Analytics Data: Typically retained for 12-24 months, then aggregated or deleted
• Cookies: Session cookies deleted when you close the browser; persistent cookies retained per browser settings
• AI Guide Conversations: Retained for 30-90 days for training and improvement; you can request deletion
• Contact Information: Retained only as long as needed to respond to your inquiry
• Server Logs: Typically retained for 30 days, then deleted or anonymized

9. Security

How We Protect Your Data

We implement security measures to protect your information:

• HTTPS Encryption: All data transmitted to/from our site is encrypted in transit
• Server Security: Our servers are hosted on secure, managed infrastructure with firewalls and monitoring
• Access Controls: Only authorized staff can access your data
• Regular Updates: We keep software and dependencies up-to-date to patch vulnerabilities
• Monitoring: We monitor for unauthorized access and suspicious activity

Limitations

No security measure is 100% effective. While we strive to protect your data, we cannot guarantee absolute security. Risks include:

• Hacking or unauthorized access
• Phishing attacks targeting your email or wallet
• Data breaches at third-party service providers
• Loss of access to your wallet due to forgotten passwords or seed phrases

Your Responsibility

You are responsible for:

• Protecting your wallet seed phrase and private keys
• Keeping your device and passwords secure
• Using strong, unique passwords
• Not sharing your wallet connection details
• Verifying URLs before entering sensitive information

10. Your Rights

Access & Portability

You have the right to request access to the personal data we hold about you and to receive a copy in a portable format.

Correction

You can request that we correct inaccurate or incomplete information about you.

Deletion ("Right to Be Forgotten")

You can request that we delete your personal data, subject to certain exceptions (e.g., legal obligations, legitimate business interests). Note:

• Blockchain data cannot be deleted (it's permanent and public)
• Some data may be retained for legal/tax compliance
• Aggregated and anonymized data may be retained

Withdraw Consent

If we use your data based on consent, you can withdraw that consent at any time. This does not affect the legality of processing based on consent before withdrawal.

Objection

You can object to processing of your data for marketing or profiling purposes.

How to Exercise Your Rights

To exercise any of these rights, contact us at:

• 📧 Email: support@surferx.io (if available)
• 📱 Telegram: t.me/SurferX_Official
• 🌐 Website: surferx.io

We will respond to your request within 30 days. We may request identification to verify your request.

11. Children's Privacy

SurferX Learn Hub is not intended for children under 18 years of age (or the age of majority in your jurisdiction). We do not knowingly collect personal information from children.

If we become aware that a child has provided us with personal information, we will take steps to delete such information and terminate the child's account. If you believe a child has provided us with information, please contact us immediately.

Parents/Guardians: If you are a parent or guardian and believe your child is using this site, please monitor their activity and contact us with any concerns.

12. Contact Us

If you have questions about this Privacy Policy or our privacy practices, please contact us:

Response Time

We aim to respond to all inquiries within 30 days. Please provide as much detail as possible about your concern.

Escalation

If you are not satisfied with our response, you may have the right to lodge a complaint with your local data protection authority (if applicable in your jurisdiction).