Terms of Service and Privacy Notice

These Terms of Service and Privacy Notice (“Terms”) govern access to and use of the “Zela” service operated by RockawayX Infra s.r.o., a company incorporated under the laws of the Czech Republic, with its registered seat in Prague, Generála Píky 430/26, Dejvice, 160 00, registration number 21040745 (“RockawayX”, “we”, “us”, “our”).

By creating an account, accessing or using “Zela”, you agree to be bound by these Terms on behalf of the business or organisation you represent (“Customer”, “you”). If you do not agree, you must not use “Zela”.

“Zela” is intended exclusively for business and professional use (B2B). You confirm that you are not using the service as a consumer.

Version 1.00, January 30, 2026

Part A: TERMS OF SERVICE

1. Service description and beta status

“Zela” is an infrastructure service that allows Customers to execute custom procedures in close proximity to Solana block production (“Service”). It is designed to help developers and businesses run latency-sensitive, multi-step workflows on the Solana blockchain.

At this stage, “Zela” is provided as an experimental beta service, free of charge. Functionality, performance, and availability may change at any time, and features may be added, modified, or removed without notice. We do not provide any guaranteed uptime, response time, or feature set.

Note that these Terms set forth the baseline legal framework governing the current free beta version of the Service. Additional commercial terms, including paid subscription plans, service level agreements (SLAs), and related pricing conditions, may be introduced in the future by updating these Terms or by means of separate addenda. Before we begin charging fees, we will inform you in advance and may require you to accept updated terms.

2. Eligibility and B2B use

The Service is intended only for business users acting in the context of a business, trade, craft or profession.

By accepting these Terms you acknowledge and agree that you will use the service for business purposes, and not for personal, family, household or consumer purposes.

We may, where required by law or in our sole discretion, refuse registration, suspend or terminate your account, and deny access to the Service if we reasonably believe that the Service is being misused, including where you are not a business user as described herein, without any liability to you.

3. Representations and Warranties of Customer

You hereby represent and warrant to RockawayX, as of the date of entering into these Terms and as of each time that you use the Services:

  1. If the Customer is an individual, the Customer is of legal age in the jurisdiction in which the Customer resides. If the Customer is a legal entity, the Customer is duly organized, validly existing and in good standing under the laws of the jurisdiction in which it is organized, and has all requisite power and authority for a business entity of its type to carry on its business as now conducted.
  2. The Customer has all requisite capacity, power, and authority to accept the terms and conditions of these Terms and to carry out and perform its obligations under these Terms. These Terms constitute a legal, valid and binding obligation of the Customer enforceable against the Customer in accordance with its terms.
  3. The Customer entering into these Terms and the Customer’s use of the Service do not constitute, and would not reasonably be expected to result in (with or without notice, lapse of time, or both) a breach, default, contravention or violation of any Law, regulation, decree or legal restriction, tax regulation or obligation, or any order or judgment of any court or other agency of government applicable to the Customer, or contract or agreement to which the Customer is a party or by which the Customer is bound. The Customer confirms in particular that it will fully comply with all applicable laws and regulations.
  4. The Customer is not, and is not owned or controlled by, or acting on behalf of, any other person who is, identified on any list of prohibited parties under any law or by any governmental authorities, such as, for example, the lists maintained by the United Nations Security Council, the U.S. government (including the U.S. Treasury Department’s Specially Designated Nationals list and Foreign Sanctions Evaders list), the European Union (EU) or its member states, and the government of the Customer’s home country. The Customer is not, and is not owned or controlled by, or acting on behalf of, any other person who is, located, ordinarily resident, organized, established, or domiciled in Cuba, Iran, North Korea, Sudan, Syria, the Crimea region (including Sevastopol) or any other country or jurisdiction against which the U.S., the EU or Switzerland maintain economic sanctions or an arms embargo. The Customer’s funds used to pay for the Service are not derived from, and do not otherwise represent the proceeds of, any activities done in violation or contravention of any law.
  5. The Customer is not a politically exposed person and is not a relative or associate, with a person who holds or held a public position during the last 12 months. 
  6. RockawayX’s provision of Services hereunder does not: (a) provide the Customer with any ownership interest, equity, security, or right to or interest in the assets, rights, properties, revenues or profits of, or voting rights whatsoever in, RockawayX; or (b) create or imply any fiduciary or other agency relationship between RockawayX or any of its directors, officers, employees, agents or affiliates and the Customer or entitle the Customer to any fiduciary duty or similar duty on the part any of the foregoing persons.
  7. The Customer is knowledgeable, experienced and sophisticated in using and evaluating the RPC node services, blockchain technology, staking, bonding, delegating, private and public keys and similar technologies. The Customer has conducted its own thorough independent investigation and analysis of the “Zela” and the other matters contemplated by these Terms in determining to use the Service and enter into these Terms, and has not relied upon any information, statement, omission, representation or warranty, express or implied, written or oral, made by or on behalf of RockawayX in connection therewith.
  8. The Customer has sufficient understanding of the functionality, usage, storage, transmission mechanisms, risks and intricacies associated with blockchains and blockchain-based software systems.
  9. The Customer shall not use any Services to finance, engage in, or otherwise support any unlawful activities.
  10. The Customer is responsible for any and all damages caused, and all liability actions brought against us for any breach infringement of these Terms or of any third-party rights or violation of any applicable laws.

4. Accounts and access

To use the Service you may be required to create an account or obtain API credentials.

You agree to:

You are responsible for all activities that occur under your account or using your credentials, whether authorised by you or not.

You must not share private keys or other highly sensitive secrets with “Zela” unless this is clearly necessary and you fully understand the risks. You remain solely responsible for protecting your blockchain keys and wallets.

We may suspend or terminate your account at any time if we reasonably believe that you have breached these Terms, that your use threatens the security or stability of the Service, or where required by law.

5. Licence and permitted use

Subject to these Terms, we grant you a limited, revocable, non-exclusive, non-transferable right to access and use “Zela” for your internal business purposes.

You must not:

You remain solely responsible for:

6. Customer workloads and data

You may use “Zela” to run your own procedures and workflows. As between you and us:

We do not claim ownership of your smart contracts, repositories, or application logic. You are responsible for ensuring that your use of any third-party code respects applicable licences.

You agree not to use the Service to process categories of data that are subject to special legal protection (such as sensitive personal data, health data, or data of children) unless this is permitted under applicable data protection law and you have agreed with us in writing on any additional safeguards that may be required.

7. Data protection and processing on behalf of Customer

For the purposes of EU data protection law, the roles of us and you are as follows:

(a) RockawayX acts as an independent controller with respect to personal data that it collects and processes for its own purposes in connection with operating “Zela”, as described in Part B (Privacy Notice) of these Terms (for example account data, contact details, security and usage logs, and support records).

(b) To the extent that RockawayX processes personal data included in Customer Data on behalf of Customer in order to provide the Service (“Customer Personal Data”), Customer is the controller (or, where applicable, a processor acting on behalf of its own customer) and RockawayX acts as Customer’s processor.

When RockawayX acts as a processor of Customer Personal Data, the following terms apply:

(i) Scope and instructions. RockawayX shall process Customer Personal Data only on documented instructions from Customer and solely for the purposes of providing, operating, maintaining, securing and supporting the Service, as further described in these Terms, unless otherwise required to do so by applicable law. In such case, RockawayX will inform Customer of that legal requirement before processing, unless the law prohibits such information.

(ii) Confidentiality. RockawayX shall ensure that persons authorised to process Customer Personal Data are bound by appropriate confidentiality obligations.

(iii) Security. Taking into account the state of the art, the costs of implementation, and the nature, scope, context and purposes of processing, as well as the risks to data subjects, RockawayX shall implement and maintain appropriate technical and organisational measures to protect Customer Personal Data against unauthorised or unlawful processing and against accidental loss, destruction or damage, as described in the “Security” section of the Privacy Notice, as updated from time to time.

(iv) Sub-processors. Customer hereby grants RockawayX a general authorisation to engage sub-processors for the processing of Customer Personal Data in connection with the Service. RockawayX shall ensure that any sub-processor is bound by data protection obligations that are no less protective than those set out in this section. Upon request, RockawayX will provide Customer with an overview of its current sub-processors. Customer may object on reasonable grounds to a material change in sub-processors; in such case the parties will work together in good faith to find a commercially reasonable solution.

(v) International transfers. Where RockawayX or its sub-processors transfer Customer Personal Data outside the European Economic Area, RockawayX shall ensure that such transfers are made in compliance with applicable data protection law, including by implementing appropriate transfer mechanisms such as adequacy decisions or standard contractual clauses approved by the European Commission.

(vi) Assistance. Taking into account the nature of the processing and the information available to RockawayX, RockawayX shall, where reasonably requested and to the extent reasonably possible, assist Customer in fulfilling its obligations to respond to requests from data subjects and to comply with its obligations under Articles 32 to 36 of the GDPR (security of processing, personal data breaches, data protection impact assessments, and prior consultation with supervisory authorities). RockawayX may charge reasonable fees where such assistance goes beyond the standard functionality of the Service.

(vii) Personal data breaches. RockawayX shall notify Customer without undue delay after becoming aware of a personal data breach affecting Customer Personal Data. Such notification may be provided via email or through the Service interface and shall describe, to the extent reasonably possible, the nature of the breach, the categories and approximate number of data subjects and data records concerned, the likely consequences of the breach, and the measures taken or proposed to address it.

(viii) Deletion and return. Upon termination of the Service or upon Customer’s written request, RockawayX shall, at Customer’s choice and subject to any legal retention obligations, delete or return Customer Personal Data processed as Customer’s processor. RockawayX may retain copies of Customer Personal Data to the extent required by law or for the establishment, exercise or defence of legal claims, in which case RockawayX shall continue to protect such data in accordance with this section.

(ix) Audits and information. Upon reasonable request and no more than once in any 12-month period (unless required by a competent supervisory authority), RockawayX shall make available to Customer information necessary to demonstrate compliance with this section and, where this information is insufficient, shall allow for and contribute to reasonable audits, including inspections, conducted by Customer or an auditor mandated by Customer, provided that such audits (A) are subject to reasonable notice, (B) do not interfere unreasonably with RockawayX’s operations, and (C) are subject to appropriate confidentiality obligations.

8. Infrastructure and third-party providers

“Zela” is currently operated on infrastructure located in the European Union, in data centres operated by third parties such as Equinix and CE Colo, and via network and security services provided by Cloudflare and other vendors.

We may change or add infrastructure and service providers from time to time. We remain responsible for ensuring that our providers are bound by appropriate confidentiality and data protection obligations.

9. Fees and beta status

During the beta phase, “Zela” is provided free of charge. We may monitor your usage (for example request counts, resource usage, error rates) to operate and improve the Service, and to design potential future pricing.

We reserve the right to:

If we introduce paid plans or pricing, we will notify you in advance and give you a reasonable opportunity to decide whether to continue under the new commercial terms.

10. Availability, support and changes

The Service is provided on a best-effort basis:

Support is provided informally via:

We aim to respond in a reasonable time but do not commit to specific response times or resolutions.

11. Intellectual property

All rights, title, and interest in and to “Zela”, including its design, software, documentation, and underlying technology, are and remain the exclusive property of RockawayX and its licensors (“Zela” IP”).

Except for the limited licence expressly granted in these Terms, no rights are granted to you, whether by implication or otherwise.

If you choose to provide feedback, ideas, or suggestions about “Zela” (“Feedback”), you grant us a perpetual, irrevocable, worldwide, royalty-free licence to use that Feedback in any manner, without any obligation to you.

12. Warranties and disclaimers

You use “Zela” at your own risk.

To the maximum extent permitted by applicable law, RockawayX provides “Zela” and “Zela” IP “as is” and “as available”, without any express or implied warranties or conditions of any kind, including but not limited to:

We do not control the Solana network or any other blockchain, and we are not responsible for network behaviour, forks, reorgs, congestion, transaction inclusion, or finality.

You are solely responsible for verifying and validating any results produced using the Service and for the design and security of your own applications, wallets, and infrastructure.

Nothing in these Terms excludes any warranties or rights that cannot be excluded under applicable law.

13. Limitation of liability

To the maximum extent permitted by applicable law:

These limitations apply to all theories of liability (contract, tort, negligence, statutory, or otherwise), and to the fullest extent permitted by law.

Nothing in these Terms limits or excludes liability that cannot be limited or excluded under applicable law (for example liability for death or personal injury caused by gross negligence, or for intentional misconduct).

14. Indemnification

You agree to indemnify, defend, and hold harmless RockawayX, its affiliates, officers, directors, employees, contractors, agents, and licensors (collectively, the “Indemnified Parties”) from and against any and all claims, liabilities, damages, losses, costs, and expenses (including reasonable attorneys’ fees) arising out of or related to:

You agree that the Indemnified Parties may assume the exclusive defense and control of any matter subject to indemnification, and you agree to cooperate with their defense.

15. Term and termination

These Terms apply from the moment you first access or use “Zela” and continue until terminated.

You may stop using “Zela” at any time. If you wish to close your account, you may do so via the interface or by contacting us.

We may, without any prior notice, suspend or terminate your access to the Service (in whole or in part) if:

Upon termination:

Sections that by their nature should survive termination (including intellectual property, warranty disclaimers, limitation of liability, governing law, and privacy-related clauses) will continue to apply.

16. Governing law and jurisdiction

These Terms and any dispute arising out of or in connection with them, or with the Service, are governed by the laws of the Czech Republic, without regard to its conflict of law rules.

The courts of the Czech Republic, with local jurisdiction in Prague, will have exclusive jurisdiction to resolve any dispute arising out of or in connection with these Terms or the Service, unless mandatory law provides otherwise.

17. Changes to the Service and to these Terms

We may update these Terms from time to time, for example to reflect changes in the Service, in law, or in our business.

When we make material changes, we will take reasonable steps to notify you, for example by posting the updated Terms on our website, via the Service interface, or by email to the address associated with your account. The “Last updated” date at the top of this document indicates when the Terms were last changed.

If you continue to use the Service after updated Terms become effective, you are deemed to have accepted them. If you do not agree with the changes, you should stop using the Service.

We may also modify, suspend, or discontinue the Service (or any part of it) at any time. Where reasonably possible, we will provide notice of significant changes or discontinuation.

18. Miscellaneous

If any provision of these Terms is held to be invalid or unenforceable, the remaining provisions will remain in full force and effect.

Our failure to enforce any provision will not constitute a waiver of that provision.

You may not assign or transfer your rights or obligations under these Terms without our prior written consent. We may assign our rights and obligations to an affiliate or in connection with a merger, acquisition, or sale of assets.

Part B: PRIVACY NOTICE

This Privacy Notice explains how RockawayX processes personal data in connection with “Zela”.

For the purposes of EU data protection law (including the GDPR), RockawayX is the controller of personal data it collects and uses for its own purposes in connection with “Zela”, as described in this section (for example account data, contact details, security and usage logs, and support records), unless stated otherwise.

To the extent that we process personal data contained in Customer Data solely on behalf of a Customer in order to provide the “Zela” Service, we act as a processor and the Customer is responsible for providing appropriate privacy information to data subjects and for ensuring a valid legal basis for such processing. The corresponding data processing terms are set out in Part A of these Terms.

1. What data we collect

In connection with “Zela” we may process the following categories of data:

  1. Account and contact data
    • name, business email address, organisation;
    • login identifiers, authentication data;
    • API keys and credentials associated with your account, which may constitute personal data if linked to an identifiable individual;
  2. Service usage and technical data
    • IP address, timestamps, request identifiers;
    • API calls and routing information;
    • performance metrics, error logs, and operational events related to your use of “Zela”;
    • limited metadata about the procedures and transactions executed through the Service (for example identifiers, status codes, resource usage).

We do not intentionally inspect or persist the full business meaning of your on-chain data beyond what is necessary to deliver and monitor the Service. However, depending on how you design your workflows, some personal data may be included in requests or logs.

Service usage and technical data is processed by RockawayX as an independent controller, as it is necessary for operating, securing, maintaining and monitoring the “Zela” Service.

Depending on your implementation, certain identifiers associated with your blockchain interactions (such as wallet addresses or transaction hashes) may also be processed. We treat these identifiers as personal data where they relate to an identifiable person.

  1. Support and communication data
    • information you submit via our support form or other communication channels;
    • records of tickets and correspondence.
  2. Website and interface data
    • basic usage information about how you interact with our website and dashboard;
    • cookies or similar technologies used for essential functionality, security, and aggregated analytics.

We use only strictly necessary cookies that enable the website and dashboard to function securely (such as session management, authentication, and load-balancing cookies).

Where we use analytics, they are implemented in a way that does not store identifiers on your device and do not collect personal data (for example, IP addresses are truncated).We do not use advertising or profiling cookies. If this changes, we will update this notice and request consent where required.

2. For what purposes we use personal data

We process the data described above for the following purposes:

  1. Provision of the Service
    • creating and managing accounts;
    • authenticating users;
    • routing, executing and returning your “Zela” requests;
    • ensuring compatibility and maintaining the Service.
  2. Security and abuse prevention
    • protecting the Service and infrastructure from attacks and misuse;
    • detecting, investigating, and mitigating technical issues, abuse, or fraud;
    • enforcing these Terms.
  3. Operations and improvement
    • monitoring performance and reliability;
    • developing new features and improving existing ones;
    • producing aggregated or anonymised statistics for internal reporting.

Where we use personal data to analyse or improve the Service, we do so only in an aggregated or anonymised form that does not identify any Customer or data subject.

  1. Support and communication
    • responding to your questions and support requests;
    • notifying you about important changes to the Service or these Terms;
    • sending technical, security, or operational messages.
  2. Legal and regulatory compliance
    • complying with applicable laws and regulations;
    • responding to lawful requests from authorities;
    • protecting our legal rights and resolving disputes.

Where EU or Czech data protection law applies, we rely on the following legal bases:

If we ever process personal data based on your consent (for example for certain optional communications), you can withdraw that consent at any time, without affecting the lawfulness of processing prior to withdrawal.

4. Where we process data and how we share it

We primarily process personal data in the European Union, using infrastructure and providers as described above (including data centres operated by Equinix and CE Colo, and network/security providers such as Cloudflare).

We may share personal data with:

We do not sell personal data.

If we transfer personal data outside the European Economic Area, we will ensure that an adequate level of protection is provided, for example by relying on an adequacy decision or standard contractual clauses approved by the European Commission together with supplementary measures such as encryption, access controls, and minimization, to ensure an equivalent level of protection.

5. Security

We implement technical and organisational measures designed to protect personal data and Customer Data against unauthorised access, loss, or misuse, including:

No system can be perfectly secure. You are responsible for maintaining the security of your own systems, keys, wallets, and applications that interact with “Zela”.

6. Retention

We retain personal data only for as long as reasonably necessary for the purposes described above, and as required by law.

In particular:

After the applicable retention period, we will either delete the data or anonymise it so that it can no longer be linked to an identifiable person.

Any extended retention for security or legal purposes is subject to strict access controls and reviewed regularly.

7. Your rights

Where EU or Czech data protection law applies, you have the following rights in relation to your personal data, subject to conditions and limitations in the law:

To exercise your rights, please contact us using the details below. We may need to verify your identity before fulfilling your request.

You also have the right to lodge a complaint with your local data protection authority. In the Czech Republic, this is the Úřad pro ochranu osobních údajů (Office for Personal Data Protection).

8. Cookies and similar technologies

When you use the “Zela” website or dashboard, we may use cookies or similar technologies that are necessary for:

We do not currently use cookies for third-party advertising. If this changes, we will update this notice and, where required, obtain your consent.

9. Contact

For questions about these Terms or about how we process personal data, or to exercise your rights, you can contact:

RockawayX Infra s.r.o.

Attn: “Zela” / Privacy

E-mail: david.simunek@rockawayx.com

Address: Generála Píky 26, 160 00 Prague 6

You can also reach us via the support form available within the “Zela” interface, which creates a ticket in our internal service desk.

10. Updates to this Privacy Notice

We may update this Privacy Notice from time to time, for example to reflect changes in the Service, in our processing activities, or in applicable law. We will indicate the date of the last update at the top of this document and, where changes are material, take reasonable steps to notify you.

Your continued use of “Zela” after an updated version of this Privacy Notice becomes effective will constitute your acknowledgement of the changes.