Privacy Policy · Weft

Who we are

"Weft" is the operator of the MCP payment hub service at weftpay.xyz.

Operating entity: pre-incorporation. Operator and data controller information will be published after formal incorporation.

Until incorporation, all data protection requests should be directed via GitHub Issues: github.com/holasergio/weft/issues.

Scope

This policy covers the processing of personal data on the Weft platform — for tenants (devs/operators) and end-users of services via Weft.

What data we process

Category	Examples	Source	Why
Account identifiers	Bearer token, tenant alias, optional Telegram chat_id	At sign-up	Auth, notifications
Service usage logs	tenant + service id + amount + timestamp + request id	On each call	Billing, audit, fraud
On-chain addresses	HD-derived deposit/withdraw addresses	Derived from operator mnemonic + alias	Settlement on Base
Webhook delivery logs	tenant + URL + status	On webhook event	Visibility
Service provider metadata	service id, title, description, endpoint, owner, price	At registration	Public registry

We do not collect:

Real names, physical addresses, bank cards (no fiat in V0.x).
Cookies (no website tracking).
Email content or conversations.
Browser fingerprints, behavioral analytics.

Legal basis (GDPR Art. 6)

Account creation, authentication: Performance of contract (6.1.b)
Usage logs, billing: Performance of contract (6.1.b)
Audit trails, fraud prevention: Legitimate interest (6.1.f)
Operational notifications via Telegram: Consent (6.1.a) — opt-in only
Webhook delivery: Performance of contract (6.1.b)

Retention

Tenant balance state — until 1 year after account closure
Ledger entries — 7 years (financial audit)
On-chain transaction records — permanent (blockchain immutable)
Webhook delivery logs — 90 days
Backups (encrypted) — daily 14d, weekly 6mo, monthly 7y

Sharing

We share data with:

Blockchain network operators (Base, Ethereum) — implicit by nature of public blockchain.
RPC providers (Alchemy, Infura, public Base RPC) — to read/write blockchain.
Cloud infrastructure (Hetzner, EU/Germany) — server hosting. Hetzner is GDPR-compliant.
Webhook destinations — chosen by you as a tenant.
Telegram — only if you opt in via subscribe_telegram.

We do not sell user data.

International transfers

If you are in the EU, your data is processed primarily in Germany (Hetzner Nürnberg). On-chain operations involve global blockchain infrastructure that crosses jurisdictions. RPC providers may have US presence.

For EU-to-US: standard contractual clauses (SCCs) apply where applicable.

Your rights (GDPR Art. 15-22)

You may:

Access — request a copy of your tenant data via GitHub Issue: open an issue
Rectify — correct inaccurate data
Erase — close your account; on-chain records remain by nature of blockchain (we cannot delete from the chain)
Restrict — pause processing
Portability — receive data in machine-readable JSON
Object — object to legitimate-interest processing
Lodge a complaint — with your local data protection authority

Response within 30 days.

Security

Bearer tokens hashed (V1 roadmap); currently demo mode plaintext per-tenant
HD master mnemonic — file mode 0600, server-side, never transmitted over the wire
HTTPS via Let's Encrypt (TLS 1.3)
Rate limiting (60 req/min/IP)
Daily encrypted backups (AES-256 GPG symmetric)
SOC 2 Type 1 audit: planned within 3 months of incorporation

10.

Smart contract caveat

Funds deposited into the WeftEscrow contract are governed by contract code, not our policy. The contract is open-source and externally auditable. We have admin privileges to (a) charge user balances on calls, (b) rotate operator key — but cannot withdraw user funds to ourselves or beyond the routes encoded in the contract.

11.

Changes

Material changes are announced via:

Email to all tenants
Telegram channel announcement
GitHub repository changelog

12.

Contact

Data protection requests: GitHub Issue
All security incidents: Security advisory
A DPO will be appointed post-incorporation.