1. Scope and Applicability

This Notice applies to information collected or processed by SpaceHarpoon when you:

1. Visit or interact with the Orbitals website, app, or dashboard;
2. Connect a wallet (including Privy-embedded wallets);
3. Interact with on-chain features through Orbitals; or
4. Contact us for support or updates.

This Notice does not apply to third-party protocols, services, or websites accessed through Orbitals (e.g., DEXs, bridges, or other DeFi platforms). Please review their separate privacy policies before using them.

2. Information We Collect

a. Information You Provide

We collect the following when you interact directly with us:

1. Contact information: such as your name, email address, username, or social media handle when you subscribe, provide feedback, or reach out for support.
2. Communications: messages, attachments, or other materials you send us.
3. Preferences: such as marketing opt-in choices or notification settings.

If you create an embedded wallet via Privy, we may receive limited identifiers from Privy (e.g., your authentication email or passkey metadata) necessary to associate your wallet with your Orbitals account.

b. Information Collected Automatically

When you access the Services, we automatically collect certain technical and usage information:

1. Device and browser data: device type, OS version, browser type/version, IP address, language settings.
2. Usage analytics: pages viewed, interaction times, and aggregate behavior (e.g., number of unique visits, feature adoption).
3. Public blockchain data: wallet addresses, on-chain transactions, and network identifiers.
4. Cookies and telemetry: used to maintain sessions, prevent abuse, and analyze usage trends. See Section 10 (“Cookies and Tracking Technologies”) below for details.

c. Information from Third Parties

We may receive additional information from:

1. Privy (wallet authentication and recovery events);
2. Analytics and security vendors (aggregated usage or threat-detection data);
3. Blockchain data providers for compliance, fraud prevention, or network integrity.

We combine this information only as permitted by law and consistent with this Notice.

3. How We Use Information

We use collected information to:

1. Provide and operate the Services, including embedded wallets and transaction routing.

2. Maintain security and integrity, detect abuse, and comply with sanctions screening or fraud prevention obligations.

3. Communicate service-related updates or respond to inquiries.

4. Improve performance through analytics, bug-tracking, and feature development.

5. Comply with legal obligations (e.g., tax, audit, KYC/sanctions verification where applicable).

6. Enforce agreements and protect our rights and those of other users.

7. With your consent, send you marketing communications or event updates (you can unsubscribe anytime).

We may use aggregated or de-identified information for research or analytics, provided it no longer identifies you.

4. How We Share Information

We may share information under these circumstances:

1. Service providers: vendors performing hosting, analytics, security monitoring, email delivery, and Privy wallet infrastructure.
2. Corporate transactions: if SpaceHarpoon undergoes a merger, acquisition, or asset transfer, your information may transfer as part of that process.
3. Legal obligations: to comply with subpoenas, court orders, or lawful regulatory requests, or to protect the rights and safety of users.
4. Your direction: when you explicitly authorize us to share information (e.g., integrations or linked accounts).

We do not sell personal information or share it for cross-context behavioral advertising as defined under California law.

5. Location and Transfers of Information

We operate primarily in the United States. Information may be stored or processed in the U.S. and other jurisdictions where our vendors operate. For transfers from the EEA, UK, or Switzerland, we rely on appropriate safeguards such as the EU Standard Contractual Clauses or the UK Addendum.

6. Access, Deletion, and Choices

You may exercise privacy rights applicable in your jurisdiction:

1. Access / Portability: request a copy of personal data we maintain.
2. Correction / Deletion: request updates or removal of certain data.
3. Restriction / Objection: limit or object to certain processing activities.
4. Opt-Out: unsubscribe from marketing emails by clicking “unsubscribe” or emailing support@spaceharpoon.com..

You can disable cookies in your browser or adjust settings in the app; however, certain functions may not work properly without them.

To make a rights request, contact privacy@spaceharpoon.com. We will verify your identity before fulfilling any request.

8. Retention of Information

We retain personal information as long as necessary to:

1. Provide the Services,
2. Comply with legal obligations,
3. Resolve disputes, or
4. Enforce agreements.

We may retain aggregated or anonymized data that cannot reasonably identify you for analytics or research.