1 Who we are
The InRange Interface, hosted at in-range.app, is operated by InRange Cripto LLC, to be formed in Wyoming, United States, registration [NUMBER], business address [FULL ADDRESS], acting as controller of the processing described in this Policy. Privacy contact: [EMAIL]. [Data protection officer or representative: identify where required and provide the applicable channel.]
This Policy accompanies the Terms of Use and explains data processing. Presenting it does not constitute consent to every purpose. Each processing activity requires its own basis under applicable law.
2 Wallet-based access and data minimization
The standard access flow does not require registration with a name, CPF number, identity document, password or payment card. The public wallet address is the operational reference. Alert contacts are optional when that feature is available.
Wallet addresses, transaction history, positions and IP addresses may identify or be linked to a person, including when combined with other information. We treat them as personal data when related to an identified or identifiable person. They are not considered anonymous merely because they lack a name or are publicly available on a blockchain.
Additional data needed to handle requests or comply with a legal obligation will be limited to the purpose and disclosed through the relevant channel. We do not request private keys or recovery phrases.
3 Data processed and purposes
The legal bases below refer to the LGPD where applicable. Retention will be limited to the purpose, statutory periods and the exercise of legal rights. Specific bracketed periods require validation and configuration before publication.
This version has no proprietary database. Positions, history and the fee ledger are read from the Solana network on each access, and nothing is stored on an InRange server. The retention periods described below will apply if and when proprietary storage is implemented, which will require updating this Policy before processing begins.
| Category and source | Purpose | Proposed legal basis |
|---|---|---|
| Wallet provided on connection | Display positions, associate fees and benefits | Performance of a contract |
| Positions and operations read from the network | Display requested dashboard and history | Performance of a contract; public availability is not a separate legal basis |
| Fees and confirmed transactions | History, benefits and accounting | Performance of a contract; legal obligation where applicable |
| Referral code and relationship | Apply discounts and calculate rewards | Performance of a contract |
| Terms version and date confirmed by the user | Record which version was accepted | Performance of a contract; in this version the confirmation stays in the browser and is not stored by InRange |
| Assistant: the question, the last messages in the conversation, the chosen nickname and a summary of positions without the wallet address | Generate the assistant's answer | Performance of a contract at the user's request; the nickname is freely chosen, is not verified and need not be a name |
| Optional email or Telegram contact | Send requested alerts | Revocable consent |
| IP, browser, system, access and security records | Security, diagnostics, abuse prevention and compliance with restrictions | Legitimate interest following assessment; legal obligation where applicable |
| Stored in the browser: language (cookie), last connected wallet, assistant nickname and conversation | Keep the user's choices between visits | Performance of the requested service or legitimate interest, depending on purpose |
Retention. Operational wallet data and history will be retained as needed for contracted functions, with review after [INACTIVITY PERIOD]. Fee records follow [APPLICABLE ACCOUNTING AND TAX PERIODS]; referral relationships follow the benefit period and [EVIDENCE PERIOD]; acceptance evidence follows [CONTRACTUAL AND LIMITATION PERIOD]. We do not use the Interface's indefinite lifespan as a general retention period.
Alert contacts will be deleted or unlinked following withdrawal of consent or termination, subject to justified minimum retention. Logs follow [PERIOD BY RECORD TYPE], considering security and any mandatory access-log retention. Local preferences remain on the device until cleared through the browser. Backups follow [PURGE CYCLE], with restricted access.
Other processing. If sanctions controls, referrer identification, support or data-subject requests require data, the company must disclose categories, purpose, legal basis, sharing and retention before starting that flow. The current description does not assert that these controls have already been implemented.
Described service practices. We do not sell data or use it for personalized advertising or cross-site tracking. The described version does not use profiling for solely automated decisions with legal effects; any implementation must be assessed and disclosed. Standard access does not request sensitive data or children's data.
4 Public network records
User-approved transactions may publicly record addresses, amounts, fees and recipients on Solana. This visibility may enable correlation and identification. InRange does not control the blockchain and cannot delete or reverse confirmed records.
Deletion requests will be assessed for data under our control and lawful retention grounds, including organized copies in our systems. Blockchain immutability does not remove duties concerning those copies. Internal acceptance records and contact details will not be published on-chain by the described acceptance flow.
5 Parties with whom we share data
We use providers for the functions below. Their classification as processors or independent controllers depends on services, purposes and contracts; we do not assume all act solely under our instructions. The provider and region inventory must reflect actual configuration.
| Provider | Data received | Location |
|---|---|---|
| Vercel (website and server hosting) | IP address and access data; cookieless usage statistics | U.S. in the supplied design; confirm region and subprocessors |
| Helius (Solana network access) | Wallet address and queried or submitted operations; in the server-mediated flow, no direct user IP; verify direct calls, headers and logs | U.S. in the supplied design; confirm region and subprocessors |
| Jupiter (swap routing, depending on enabled module) | Wallet address and swap parameters when a quote is requested | [verify] |
| Orca public API | Public position identifiers to check values | [verify] |
| Email / Telegram provider (alerts) | Supplied contact and alert text | [to be determined] |
| Vercel AI Gateway and the artificial-intelligence model provider (assistant) | the question, the last messages, the nickname and the position summary without the wallet address and without the user's IP address; our server mediates the call | [verify the region and retention of the chosen model provider] |
This version does not use a database provider. There is no proprietary storage of user data, so no provider receives wallets, positions, fees or referrals for storage. Adding a database provider requires updating this section before the flow begins.
We may also share data when required by law, court order or a competent authority, or to exercise rights in proceedings. We will inform users where the law permits.
6 International transfers and access
The intended operator is a U.S. LLC. The technical design uses providers with U.S. infrastructure and may involve administrative access from Paraguay and authorized support from Brazil. The assistant adds a transfer to an artificial-intelligence model provider, mediated by our server, which must also appear in the flow map. A provider's incorporation country is not necessarily the location of all processing; hosting, support and subprocessor regions must be identified.
Outstanding requirement blocking publication of this section: complete the flow map and determine, for each transfer subject to the LGPD, the countries, recipients, purposes and valid mechanism under law and ANPD regulations. Where contracts are used, execute applicable instruments and check coverage before the flow begins. A generic provider contract alone does not establish adoption of valid clauses for this case.
Text to complete after implementation: “For transfers to [RECIPIENTS AND COUNTRIES] for [PURPOSES], we use [ACTUALLY APPLICABLE AND FORMALIZED MECHANISM]. Information and copies of clauses, where applicable, may be requested through [CHANNEL], subject to statutory limits.”
Processing must also follow other actually applicable laws. Choosing Wyoming law in the Terms does not displace mandatory data protection rights.
7 Cookies and similar technologies
The Interface does not use tracking or advertising cookies. It uses only:
- Browser local storage for the last connected wallet, the nickname chosen for the assistant and the recent history of the conversation with it; and a language cookie storing only the choice between Portuguese and English. All of it stays on the user's device and can be cleared through the browser.
- [Usage statistics through Vercel Analytics, if enabled and after validating configuration, technical data and aggregation measures; being cookieless does not guarantee anonymity.]
8 Security
Planned operational measures include HTTPS, role-based access control, server-side secret segregation, administrative access logging and purpose-limited collection. [Confirm implementation, backup management and administrator access from Paraguay before publication.] No system is completely secure. Incidents will be assessed and reported to authorities and affected individuals where required, within statutory deadlines, rather than at the company's discretion.
Users alone are responsible for the security of their wallet, private key and recovery phrase, which InRange never requests.
9 User rights
Under the LGPD and equivalent laws in other jurisdictions, users may request through the section 1 contact: confirmation of processing and access; correction; anonymization, blocking or deletion of unnecessary or unlawfully processed data; portability; sharing information; withdrawal of alert consent; and objection to processing based on legitimate interest.
To handle wallet-related requests, we will use verification methods proportionate to the request. In this version the Interface does not implement verification message signing; adopting it would depend on reconciling that signature with the security guidance we give users, which is never to sign a loose message. We will never request a private key or recovery phrase. Response times follow the right exercised and applicable law; LGPD confirmation and access requests follow statutory procedures and deadlines. Necessary retention will be justified by category and basis, without indiscriminate retention of the entire history.
Users may also complain to Brazil's National Data Protection Authority (ANPD).
10 Minors
The Interface is not intended for persons under 18. If we identify processing of a minor's data, we will take measures appropriate to the law and applicable best interests, including blocking or deletion where appropriate, subject to lawful retention grounds.
11 Changes to this Policy
Material changes will be communicated with appropriate advance notice, except for legal requirements or justified urgent measures. Where a purpose depends on consent, specific consent will be requested before processing. Continued use alone will not be treated as blanket consent. The current version and its date will remain accessible.
The Portuguese and English V3 versions have corresponding content and numbering and must undergo coordinated review. The language rule to be determined in the Terms will not reduce mandatory data-subject rights.
12 Contact
InRange Cripto LLC · Wyoming, United States · Registration [NUMBER] · Business address [ADDRESS] · Privacy [EMAIL] · [DATA PROTECTION OFFICER OR REPRESENTATIVE, IF APPLICABLE]