Legal
Privacy Policy
Last updated: January 2026
1. Overview
Arca is entropy infrastructure. We collect human-generated randomness and deliver it to applications that need verified randomness. This policy explains what data we collect, how we protect it, and what rights you have.
The short version: We collect interaction data (timing, motion) to extract entropy. We keep that data private. Consumers of our entropy never see who generated it or how.
2. Who This Policy Applies To
| Role | Description |
|---|---|
| Contributors | People who generate entropy through Arca-integrated apps |
| Suppliers | Businesses that integrate Arca SDK (e.g., Gambino) |
| Consumers | Enterprises that purchase verified entropy |
If you're a Contributor using an app like Gambino, their privacy policy also applies to you. This policy covers what Arca specifically does with your data.
3. The Two-World Model
Arca's architecture separates data into two isolated systems:
Attribution World (Private)
- Your identity
- Session history
- Timing and motion data
- Contribution stats
- Reward tracking
Only you + Supplier + Arca can access this
Entropy World (Public)
- Aggregated statistics
- Verified random bits
- Merkle proofs
- Hedera anchors
- Quality scores
Consumers see this (no user data here)
This separation is architectural. The Entropy World literally doesn't contain user identifiers or input patterns. There's no "opt-out" needed because the data simply isn't there.
4. What We Collect
4.1 From Contributors
| Data Type | Purpose | Retention |
|---|---|---|
| Interaction timing | Entropy extraction | Until batch creation, then deleted |
| Device motion | Entropy extraction | Until batch creation, then deleted |
| Session metadata | Attribution, quality scoring | Duration of account + 30 days |
| Contribution statistics | Reward calculation, user dashboard | Duration of account |
| Device public key | Account identity (if device-bound) | Duration of account |
| Recovery/sync (optional) | Until you remove it |
4.2 From Suppliers
| Data Type | Purpose | Retention |
|---|---|---|
| Business information | Registration, compliance | Duration of relationship + 7 years |
| API credentials | Authentication | Until revoked |
| Integration logs | Debugging, abuse prevention | 90 days |
4.3 From Consumers
| Data Type | Purpose | Retention |
|---|---|---|
| Business information | Registration, billing | Duration of relationship + 7 years |
| API usage logs | Billing, rate limiting | 90 days |
| Entropy draw requests | Service delivery | 30 days |
5. What We Don't Collect
- Real names (unless required by Supplier for KYC)
- Government IDs (Suppliers handle identity verification)
- Location data (beyond what device sensors provide for entropy)
- Browsing history
- Contacts or phone data
- Financial account information
6. How Interaction Data Becomes Entropy
This is the core of our privacy model:
Raw Trace (Sensitive)
tap1: 0ms, tap2: 127ms, tap3: 289ms...
motion: [{ax: 0.12, ay: -0.98}, ...]This pattern can fingerprint a user.
Entropy Bits (Safe)
Inter-tap deltas → quantized → min-entropy
Motion variance → mixed in
Output: 15.5 verified random bitsFinal Output
Hash(batch_entropy || nonce) → random streamNo way to reverse to original timing patterns. No way to identify the contributor.
After entropy extraction:
- Raw traces are deleted
- Only the entropy bits remain
- Bits are mixed with thousands of other contributions
- The final output is cryptographically unlinkable
7. Data Sharing
We Share With:
| Recipient | Data Shared | Purpose |
|---|---|---|
| Suppliers | Contributor stats (their users only) | User dashboards, rewards |
| Consumers | Anonymized entropy batches only | Service delivery |
| Hedera network | Merkle roots, timestamps | Immutable anchoring |
| Service providers | Operational data as needed | Infrastructure (hosting, etc.) |
| Legal authorities | As required by law | Compliance |
We Never Share:
- Raw timing and motion data with anyone
- Contributor identity with Consumers
- Cross-Supplier user data
- Data for advertising purposes
8. Data Storage and Security
Where Data Lives
- Attribution data: Encrypted at rest, access-controlled databases
- Entropy batches: Public blockchain anchors (Hedera), no PII
- Backups: Encrypted, geographically distributed
Security Measures
- TLS 1.3 for all data in transit
- AES-256 encryption at rest
- Ed25519 signatures for authentication
- Regular security audits
- Access logging and monitoring
Breach Response
If we discover unauthorized access to personal data:
- We will notify affected Suppliers within 72 hours
- Suppliers are responsible for notifying their users
- We will take immediate remediation steps
9. Your Rights
All Contributors Have The Right To:
| Right | How To Exercise |
|---|---|
| Access | Request your contribution history through your Supplier |
| Correction | Update inaccurate information through your Supplier |
| Deletion | Request account deletion (see Section 10) |
| Portability | Export your device keys and contribution data |
| Object | Stop contributing at any time |
| Withdraw consent | Revoke optional features (email sync, etc.) |
For Direct Arca Users (Mobile)
If you use Arca directly (not through a Supplier):
- Access your data at your dashboard
- Delete your account through the app or by emailing us
- Export your account for device migration
For Supplier/Consumer Businesses
- Access your organization's data through your admin dashboard
- Request data export by contacting us
- Delete your account with 30 days notice
10. Data Deletion
What Happens When You Delete Your Account
| Data Type | Action |
|---|---|
| Account information | Deleted within 30 days |
| Session history | Deleted within 30 days |
| Raw timing and motion data | Already deleted (not retained after entropy extraction) |
| Contribution statistics | Deleted within 30 days |
| Entropy already in batches | Remains (but unlinkable to you) |
| Blockchain anchors | Permanent (public, no PII) |
Important: Entropy you contributed that's already been batched and delivered cannot be "uncontributed." However, there's no link between that entropy and your identity—it's just random bits in a pool.
Legal Retention
Some data may be retained beyond deletion if required for:
- Legal compliance
- Fraud prevention
- Dispute resolution
11. Children's Privacy
Arca services are not intended for children under 18. We do not knowingly collect data from minors.
- Suppliers are responsible for age verification
- If we learn a Contributor is under 18, we will delete their data
- Parents/guardians may contact us to request deletion
12. International Data
Arca operates globally. Your data may be processed in:
- United States
- Other countries where our infrastructure operates
We apply consistent privacy protections regardless of location. For EU/UK users, our legal basis for processing is:
- Legitimate interest (entropy extraction, service delivery)
- Consent (optional features like email sync)
- Contract (for Suppliers and Consumers)
13. Cookies and Tracking
Arca Infrastructure
We use minimal cookies for:
- Session management (if you have a direct Arca account)
- Security (CSRF protection)
We do not use:
- Advertising cookies
- Third-party tracking
- Cross-site tracking
Supplier Applications
Suppliers may use their own cookies and tracking. See their privacy policies.
14. Changes to This Policy
We may update this policy as:
- The protocol evolves
- Regulations change
- We expand services
Material changes will be announced:
- On our website
- Via email to registered Suppliers/Consumers
- Through Supplier notifications to Contributors
15. Contact
For privacy questions or requests:
Email: privacy@arca.io
For Suppliers and Consumers:
Contact your account representative or use the admin dashboard.
For Contributors:
Contact your Supplier first (e.g., Gambino support). If your issue is specifically about Arca's data handling, contact us directly.
16. Summary
| Question | Answer |
|---|---|
| What do you collect? | Interaction data (timing, motion) for entropy extraction |
| Who sees my data? | You, your Supplier, Arca (not Consumers) |
| Can Consumers identify me? | No, architecturally impossible |
| How long do you keep data? | Raw traces: deleted after extraction. Stats: until you delete account |
| Can I delete my data? | Yes, except entropy already in public batches (but that's unlinkable) |
| Do you sell my data? | No |
| Do you use it for ads? | No |
Arca is infrastructure. We extract randomness from your actions, protect your input patterns, and deliver anonymous entropy to applications. Your identity stays with you and your Supplier—it never reaches Consumers.