Privacy Policy

Last Updated: October 23, 2025
Effective Date: October 23, 2025

1. Introduction

Redio (“we,” “us,” “our”) operates a decentralized affiliate commission payment platform on Solana. This Privacy Policy explains how we handle information when you use our Platform.

Key Point: Redio is primarily a smart contract platform. Most activity happens on-chain (public blockchain), which is permanent and transparent by design.

2. Who We Are

Platform: Redio.app
Contact: [email protected]
Type: Decentralized smart contract infrastructure

3. Information We Collect

3.1 On-Chain Data (Public & Permanent)

When you interact with the Redio smart contract, the following is recorded on Solana blockchain:

For Merchants:

Wallet address
Merchant pool address (derived from your wallet)
USDC mint address
Commission rate settings
Escrow deposit/withdrawal amounts
Total volume and commissions paid statistics
Transaction timestamps

For Affiliates:

Wallet address
Affiliate account address (derived from wallet + pool)
Referral code (ref_id) - WARNING: This is public and permanent
Total earnings
Sales count
Active/inactive status
Creation timestamp

For All Transactions:

Transaction signatures
Sale amounts
Commission amounts
Timestamps
All event logs emitted by the smart contract

Important: Blockchain data is:

✅ Public (anyone can view)
✅ Permanent (cannot be deleted)
✅ Transparent (all transactions visible)
❌ NOT controlled by Redio (it’s decentralized)
❌ NOT deletable under “right to be forgotten”

3.2 Off-Chain Data (Optional)

We may collect the following if you use our website or create an off-chain profile:

Technical Data:

IP address
Browser type and version
Device information
Referring URL
Pages visited
Time and date of access

Profile Data (Optional):

Email address (if you provide it)
Display name
Profile picture
Social media links
Bio/description

Communication Data:

Support ticket content
Email correspondence
Telegram messages (if you contact us)

3.3 Data We DO NOT Collect

We do NOT collect:

Real names (unless you voluntarily provide them)
Physical addresses
Phone numbers
Government IDs
Financial information beyond what’s on-chain
Credit card or bank account details

4. How We Use Information

4.1 On-Chain Data

On-chain data is processed by the smart contract for:

Facilitating commission payments
Tracking affiliate statistics
Maintaining escrow balances
Creating transparent audit trails

We do not “use” on-chain data - the smart contract automatically processes it. Anyone can query this public blockchain data.

4.2 Off-Chain Data

We use off-chain data for:

Operating and improving the website
Providing customer support
Sending platform updates (if you subscribed)
Preventing fraud and abuse
Analytics (aggregated, anonymized)
Legal compliance

Legal Basis (GDPR):

Consent: When you opt-in to emails or create a profile
Legitimate Interest: Security, fraud prevention, platform improvement
Legal Obligation: Compliance with applicable laws

5.1 On-Chain Data

Blockchain data is PUBLIC. Any person or service can:

View all transactions
Query wallet balances and history
Access affiliate earnings and statistics
Build analytics on top of Redio data

This is the nature of public blockchain technology.

5.2 Off-Chain Data

We may share off-chain data with:

Service Providers:

Hosting providers (website infrastructure)
Analytics services (e.g., Google Analytics) - anonymized
Email services (if you subscribed)
Support ticket systems

Legal Requirements:

Law enforcement (if legally required)
Court orders or subpoenas
Protection of rights and safety

Business Transfers:

Mergers, acquisitions, or asset sales
Your data may transfer to new owner

We DO NOT:

Sell your personal information
Share your email with third parties for marketing
Provide off-chain data to merchants or affiliates

5.3 Merchant-Affiliate Relationships

If a merchant adds you as an affiliate:

They know your wallet address (on-chain, public)
They may collect additional information directly from you
That relationship is governed by their privacy policy, not ours
We are not responsible for how merchants handle your data

6. Cookies and Tracking

6.1 Cookies We Use

Essential Cookies:

Session management
Security features
Remember wallet connection

Analytics Cookies (Optional):

Google Analytics (anonymized)
Usage patterns
Performance monitoring

6.2 Your Choices

You can:

Disable cookies in your browser (may affect functionality)
Opt-out of Google Analytics: https://tools.google.com/dlpage/gaoptout

EU/UK Users: We display a cookie consent banner. You can withdraw consent anytime.

7. Your Rights

7.1 On-Chain Data Rights

Important Limitation: Blockchain data is permanent and public. We cannot:

Delete your wallet address from blockchain
Remove transaction history
Edit commission records
Hide on-chain activity

This is a fundamental characteristic of blockchain technology, not a limitation of Redio.

7.2 Off-Chain Data Rights

For off-chain data you provided (email, profile, etc.), you have the right to:

Access: Request a copy of your data
Correction: Update inaccurate information
Deletion: Request deletion of your off-chain profile
Portability: Export your data in machine-readable format
Object: Object to certain data processing
Restrict: Request processing restrictions
Withdraw Consent: Stop marketing emails anytime

To exercise these rights: Email [email protected]

Response Time: Within 30 days (GDPR, CCPA)

7.3 California Residents (CCPA/CPRA)

You have the right to:

Know what personal information we collect
Know if we sell or share your information (we don’t)
Access your information
Delete your information
Opt-out of sale (not applicable - we don’t sell)
Non-discrimination for exercising rights

Verification: We may ask for verification before fulfilling requests.

You have additional rights:

Lodge a complaint with your data protection authority
Data portability
Object to automated decision-making (we don’t use it)

Supervisory Authority: Contact your local DPA if you believe we’ve violated GDPR.

8. Data Security

8.1 On-Chain Security

On-chain data is secured by:

Solana blockchain cryptography
Smart contract security measures
Immutability (cannot be altered)

8.2 Off-Chain Security

We protect off-chain data with:

Encryption in transit (HTTPS/TLS)
Encryption at rest for sensitive data
Access controls and authentication
Regular security assessments
Monitoring for breaches

However: No system is 100% secure. We cannot guarantee absolute security.

8.3 Your Responsibility

You are responsible for:

Securing your wallet and private keys
Keeping your login credentials safe
Using strong passwords
Not sharing account access

9. Data Retention

9.1 On-Chain Data

Blockchain data is permanent. It exists as long as the Solana blockchain exists.

9.2 Off-Chain Data

Active Accounts:

Profile data: Retained while account is active
Emails: Retained for 2 years or until you unsubscribe
Support tickets: Retained for 5 years (legal compliance)

Deleted Accounts:

Profile data: Deleted within 30 days of request
Backups: May persist in backups for up to 90 days
Legal records: Retained if required by law (e.g., tax records for 7 years)

10. International Data Transfers

Redio operates globally. Your data may be transferred to and processed in:

United States
Other countries where our service providers operate

EU/UK Users: Transfers are protected by:

Standard Contractual Clauses (SCCs)
Appropriate safeguards under GDPR

By using Redio, you consent to these transfers.

11. Children’s Privacy

Redio is not intended for users under 18. We do not knowingly collect data from children.

If you believe a child provided data to us, contact [email protected] and we’ll delete it promptly.

12. Third-Party Links

Our website may link to third-party sites:

Solana Explorer
USDC information
Social media
Merchant websites

We are not responsible for their privacy practices. Review their privacy policies separately.

13. Blockchain-Specific Privacy Considerations

13.1 Wallet Address Pseudonymity

Wallet addresses are pseudonymous, not anonymous:

✅ No name directly attached
❌ Can be linked to your identity through:
- Exchange KYC
- On-chain analysis
- IP address correlation
- Off-chain data you provide

13.2 Referral Code Privacy Risk

WARNING: If you choose (or a merchant assigns) a referral code containing personal information (e.g., “JOHN_DOE_123”), this becomes public and permanent on blockchain.

We strongly recommend: Use anonymous codes only.

Responsibility: You and the merchant are responsible for referral code privacy implications, not Redio.

13.3 Transaction Graph Analysis

Anyone can analyze blockchain transactions to:

Track your earnings over time
See which merchants you work with
Correlate your wallet with other activities
Build profiles based on on-chain behavior

This is inherent to public blockchain technology.

14. Changes to This Policy

We may update this Privacy Policy to reflect:

Changes in our practices
Legal requirements
Platform updates

Material Changes:

Posted on website at least 30 days before taking effect
Email notification (if you provided email)

Continued Use: Using the Platform after changes constitutes acceptance.

15. Contact Us

Privacy Questions:

Email: [email protected]
Telegram: @redio_daw

Data Rights Requests:

Email: [email protected]
Subject: “Privacy Rights Request - [Your Request Type]”

Response Time: Within 30 days

16. Region-Specific Information

For EU/UK Users:

Data Controller: Redio
Legal Basis: Consent, Legitimate Interest, Legal Obligation
DPO: Contact [email protected]
Supervisory Authority: Your local data protection authority

For California Users:

Categories of PI Collected: Identifiers, internet activity, inferences
Business Purpose: Operating platform, analytics, support
No Sale: We do not sell personal information
Shine the Light: We don’t share for third-party direct marketing

For Canadian Users:

PIPEDA Compliance: We follow PIPEDA principles
Privacy Commissioner: You may file complaints with the OPC

17. Summary of Key Points

What data is public:

✅ All blockchain data (wallet addresses, transactions, earnings, referral codes)

What data is private:

🔒 Off-chain profile data (email, display name) - controllable by you

Your rights:

✅ Access, correct, delete off-chain data
❌ Cannot delete on-chain blockchain data

Our commitment:

We minimize data collection
We don’t sell your information
We provide transparency about blockchain’s public nature
We protect off-chain data with security measures

Your responsibility:

Secure your wallet and keys
Use anonymous referral codes
Understand blockchain is public and permanent

By using Redio, you acknowledge you’ve read and understood this Privacy Policy, including the public and permanent nature of blockchain data.

Last Updated: October 23, 2025
Policy Version: 1.0