Privacy Policy

This draft incorporates the changes required by counsel’s 7 June 2026 review. It remains a draft pending final attorney sign-off and a few operator details. Bracketed items are placeholders to be finalized. Until this is finalized and the noted DPAs/SCCs are executed, EU/UK personal data should not be collected (interim geo-exclusion).

Data controller

The data controller is Gov AI Solutions LLC, doing business as TopSolanaMeme.com, [registered address]. Privacy contact: privacy@topsolanameme.com.

Which laws apply

Applicable rules depend on where you are: GDPR (EU/EEA), UK GDPR / DPA 2018 (UK), and CCPA/CPRA (California) may apply. We aim to honor these rights for all users.

Information we collect

• Submission details (public): token name, ticker, contract address, links, description, logo.
• Contact details (private): the email and/or Telegram you provide.
• Inquiry details from featured/sponsorship/contact forms.
• Technical data: IP address, used only for anti-spam rate limiting and security.
• Usage events (e.g., page views, clicks) only if analytics is enabled, in aggregate.

How we use it & our lawful bases (GDPR Art. 6)

• Review and publish submissions; operate rankings/listings — performance of a contract / legitimate interests.
• Contact you about a submission, inquiry, or paid placement — contract / legitimate interests.
• Anti-spam IP rate limiting and security — legitimate interests.
• Aggregate analytics, if enabled — legitimate interests or consent, depending on jurisdiction.

Cookies

• tsm_admin — admin login session. First-party, httpOnly, ~7 days. Administrators only; strictly functional.
• tsm_voted — prevents duplicate community votes. First-party, httpOnly, ~1 year; strictly functional.

We use only strictly-necessary / functional cookies. We do not use performance, analytics, or targeting/advertising cookies, and we do not combine or link your data with third-party data for targeted advertising. Because these cookies are strictly functional, no cookie-consent banner is required. If analytics is enabled later, the specific provider will be named here and covered by a data processing agreement.

Service providers (sub-processors)

We use the following processors and maintain (or will execute) data processing agreements with each under GDPR Art. 28: Vercel (US — hosting), Supabase (US — database), Cloudflare (DNS). DexScreener supplies read-only market data. We do not sell personal information. [DPAs to be executed before EU/UK personal data is processed.]

International transfers

We serve a global audience, and your information may be processed in the United States or other countries. Where EU/UK personal data is transferred to the US, such transfers are protected by Standard Contractual Clauses (SCCs). [SCCs to be executed and referenced here before EU/UK data is processed.]

Blockchain transparency

Token contract addresses we display, and any SOL payment you make to our wallet, exist on the public Solana blockchain. Blockchain records are public and permanent — we cannot change, hide, or erase on-chain data, including a wallet address or transaction you choose to share with us.

Retention

• Token submissions/listings: for the life of the listing plus 1 year.
• Inquiry/contact data: up to 2 years.
• IP logs (anti-spam): about 30 days.

Your rights

Depending on your location, you may have rights to access, correct, delete, restrict, object to, or port your personal information. To exercise them, email privacy@topsolanameme.com; we aim to respond within 30 days. If you are in the EU/EEA or UK, you may also lodge a complaint with your local data-protection supervisory authority.

California (CCPA/CPRA): you may request the categories and specific pieces of personal information we hold, request deletion, and we confirm we do not sell your personal information.

IP logging

IP addresses are used exclusively for anti-spam rate limiting and security, retained for about 30 days, on the basis of our legitimate interest in preventing abuse.

Children

The Platform is not directed to anyone under 18, and we do not knowingly collect their data.

Changes & contact

We may update this policy; material changes will be posted here. Contact privacy@topsolanameme.com for any privacy question. This is a draft pending final legal review and does not yet constitute a complete, jurisdiction-specific privacy policy.