1. Overview
Kestrel Labs Inc., a corporation organized under the laws of the Republic of Panama, registration number 155787958 ("Kestrel," "we," "us," or "our"), is responsible for personal information processed through the Kestrel-controlled Services described in this Policy. This Privacy Policy explains how we collect, use, disclose, and protect information when you access or use our website, application, interfaces, documentation, and related services (collectively, the "Services").
This Policy applies to information processed by Kestrel Labs Inc. through Kestrel-controlled Services. If you access a Kestrel product through a third-party interface, that third party may process information under its own privacy policy. This Policy applies only to information that Kestrel itself receives or processes.
Kestrel is a non-custodial interface to smart contracts on the Solana blockchain. We do not create password-based user accounts, custody digital assets, hold private keys, or control blockchain networks. However, your use of the Services may involve your public wallet address, on-chain transactions, requests to our backend to display your holdings and activity, technical logs, analytics, and third-party service providers.
2. Information we may collect
Wallet information: when you connect a wallet, we may process your public wallet address, connected network, wallet provider, token balances, transaction status, signatures, and other public blockchain data needed to display the interface and help you build and submit transactions. When you connect a wallet or view your portfolio, we may send your public wallet address to our backend and to data providers to return your holdings, positions, yields, prices, and transaction history. We do not receive or store your private keys or seed phrase.
On-chain data: Solana transactions, wallet addresses, token mints, balances, signatures, block times, and smart-contract interactions are publicly available on the network. We may read, index, cache, or display that public data.
Usage and device information: we may collect pages viewed, links clicked, referring URLs, approximate location derived from IP address, browser type, device type, operating system, screen size, language settings, session timestamps, diagnostic events, error logs, and performance metrics.
Communications: if you contact us, submit feedback, join a waitlist, request support, or communicate with us through official channels, we may collect the information you choose to provide, such as your name, contact details, wallet address, message contents, and related metadata.
Cookies and similar technologies: we may use cookies, local storage, pixels, or similar technologies to remember preferences, support site functionality, measure usage, detect abuse, and improve the Services.
Compliance information: to meet sanctions, anti-money-laundering, and geographic-restriction obligations, we may process public wallet addresses and their on-chain transaction history, wallet-risk classifications and sanctions-screening results from blockchain analytics providers, IP address and approximate location, VPN or proxy indicators, device and request data, and any information you supply in response to additional compliance checks.
3. How we use information
We use information to operate, provide, maintain, secure, and improve the Services; display balances, positions, yields, prices, transaction states, and other app data; route transactions through wallets and blockchain networks; troubleshoot bugs; monitor performance; detect abuse, fraud, and security incidents; understand aggregate usage patterns; respond to support requests; and comply with legal obligations.
We also use compliance information to comply with sanctions and anti-money-laundering obligations, detect illicit or high-risk wallet activity, enforce geographic restrictions, prevent fraud and abuse, respond to lawful requests from authorities, and protect users and the Protocol.
We may also use aggregated or de-identified information to analyze product usage, publish protocol statistics, improve reliability, and develop new features.
We do not sell your personal information. We do not use your private keys or seed phrase because we never receive them.
4. On-chain data
Public blockchains are transparent and immutable. Transactions you sign and submit may reveal wallet addresses, token balances, transaction amounts, counterparties, smart contract interactions, timestamps, and related activity. This information may be visible to anyone and may be copied, analyzed, indexed, or combined with other data by third parties.
We do not control public blockchain networks and cannot delete, modify, or hide on-chain records. Disconnecting your wallet from the Services does not delete public blockchain data.
5. Legal bases for processing
Where privacy laws require a legal basis for processing, we process information as necessary to provide the Services, based on our legitimate interests in operating, securing, improving, and measuring the Services, to comply with legal obligations, and with your consent where consent is required.
You may withdraw consent where processing is based on consent, but doing so may affect the availability or functionality of some features.
6. How we share information
We may share information with service providers that help us operate the Services, including hosting providers, content delivery networks, RPC providers, indexers, analytics providers, monitoring and error tracking tools, security vendors, wallet connection tools, communication tools, and customer support tools.
We may share information when required by law, subpoena, court order, legal process, or governmental request; to enforce our terms; to protect the rights, property, safety, or security of Kestrel, users, or others; or in connection with a merger, acquisition, financing, reorganization, or transfer of assets.
Because blockchain data is public, wallet addresses and transaction activity may be available to blockchain explorers, analytics companies, validators, RPC providers, counterparties, and anyone else who accesses the relevant network.
7. Third-party services
The Services may integrate with or link to third-party services, including wallet providers, wallet adapters, RPC providers, price and yield data providers, analytics tools, block explorers, decentralized protocols, bridges, exchanges, social platforms, and cloud infrastructure providers.
Third-party services may collect information directly from you or your device under their own privacy policies. We are not responsible for the privacy practices, security, availability, or accuracy of third-party services.
8. Cookies, local storage, and analytics
We may use cookies, local storage, and similar technologies to keep the site functional, remember preferences, maintain session state, measure traffic, understand feature usage, and improve performance. You can control cookies through your browser settings, but disabling them may affect functionality.
We use Google Analytics to understand aggregate usage, and monitoring tools to diagnose issues. These tools may collect technical information such as IP address, device identifiers, browser information, pages visited, click events, and error traces.
Some browsers offer "Do Not Track" signals. Because there is no uniform standard for responding to these signals, we may not respond to them.
9. Data retention
We retain information for as long as reasonably necessary to provide, secure, improve, and operate the Services, comply with legal obligations, resolve disputes, enforce agreements, and maintain appropriate business records.
Retention periods vary depending on the type of information and the purpose for which it is processed. Public blockchain data may remain available indefinitely on third-party networks and cannot be deleted by Kestrel.
10. Security
We use reasonable administrative, technical, and organizational measures designed to protect information processed through the Services. However, no online service, blockchain network, wallet, or transmission method is completely secure.
You are responsible for securing your wallet, private keys, seed phrase, devices, and accounts. We will never ask for your seed phrase or private key.
11. International transfers
The Services may be operated from, and service providers may process information in, countries other than where you live. These countries may have data protection laws that differ from those in your jurisdiction. Where required, we rely on appropriate safeguards for international transfers.
12. Children
The Services are not directed to children. Consistent with our Terms of Service, the Services may be used only by individuals who are at least 18 years old (or the age of majority in their jurisdiction, if higher), and we do not knowingly collect personal information from anyone below that age. If you believe a child has provided us personal information, please contact us so we can take appropriate action.
13. Your choices and rights
You may disconnect your wallet from the interface at any time. You may also clear cookies or local storage through your browser settings. These actions do not delete public blockchain data.
Depending on where you live, you may have rights to request access, correction, deletion, portability, restriction, objection, or withdrawal of consent with respect to personal information we process. You may also have the right to lodge a complaint with a data protection authority.
We may need to verify your request before responding. We may be unable to fulfill requests involving public blockchain data that we do not control or data we must retain for legal, security, or operational reasons.
Because Kestrel Labs Inc. is organized in the Republic of Panama, you also have the rights recognized under Panamanian data-protection law (Law 81 of 2019 and its implementing regulations): access, rectification, cancellation (deletion), opposition, and portability. To exercise these rights, contact us at info@kestrel.finance with enough information to verify that you are the person the request concerns (for example, the wallet address or contact details the request relates to). Public blockchain data generally cannot be modified or deleted by Kestrel. Where applicable, you also have the right to lodge a complaint with Panama's National Authority for Transparency and Access to Information (ANTAI).
14. California and other U.S. state privacy disclosures
Where applicable law provides additional rights, including rights to know, access, delete, correct, opt out of certain sharing, or limit certain uses of sensitive personal information, we will honor those rights as required.
We do not sell personal information. We also do not knowingly sell or share personal information of individuals under 16 years of age.
15. Changes to this policy
We may update this Privacy Policy from time to time. If we make material changes, we may provide notice by updating the "Last updated" date, posting notice through the Services, or taking other reasonable steps. Your continued use of the Services after an updated policy becomes effective means you acknowledge the updated policy.
16. Contact
Privacy questions and requests can be directed to Kestrel Labs Inc. (Republic of Panama, registration number 155787958) at info@kestrel.finance, or through official channels listed on kestrel.finance.