Privacy Policy

Last Updated: April 14, 2025

1. INTRODUCTION

Cold Wallet ("we," "our," or "us") is committed to protecting your privacy and the personal information that you provide to us. This Privacy Policy explains how we collect, use, disclose, transfer, store, retain and safeguard your information when you use our crypto wallet application, visit our website at coldwallet.com, interact with our social media platforms, participate in our pre-sale or token offerings, or engage with any of our other services (collectively, the "Services").

We understand the importance of data privacy, particularly in the cryptocurrency space where security and confidentiality are paramount concerns. This Privacy Policy is designed to help you understand our practices regarding your information and how we work to keep it secure in compliance with applicable data protection laws worldwide.

Please read this Privacy Policy carefully. By accessing or using our Services, you acknowledge that you have read, understood, and agree to be bound by this Privacy Policy. If you do not agree with our policies and practices, please do not use our Services. This Privacy Policy may change from time to time; continued use of our Services after any revisions indicates your acceptance of the changes.

2. INFORMATION WE COLLECT

2.1 Personal Information

We may collect personal information that you voluntarily provide to us when you:

Create an account or user profile
Subscribe to our newsletter or marketing communications
Participate in the token pre-sale or purchase $CWT tokens
Contact our customer support team
Participate in our community platforms (such as Telegram, Discord, or X)
Respond to surveys or questionnaires
Register for webinars, events, or promotional activities
Submit information through our "Contact Us" forms
Engage with our social media accounts
Apply for employment or partnership opportunities

This information may include:

Full name
Email address
Phone number
Wallet addresses
Transaction data and history
Communication records and preferences
Social media handles or usernames
Employment information (for job applicants)
Know Your Customer (KYC) and Anti-Money Laundering (AML) information where required by law
Any other information you choose to provide

2.2 Automatically Collected Information

When you access or use our Services, we may automatically collect certain information, including:

Device information (including device type, operating system, browser type, mobile network information)
IP address and approximate location derived from IP address
Browsing actions and patterns
Token holdings and transaction history within our platform
App usage data and interaction with our wallet features
Time spent on various pages or features
Referring websites or sources
Performance and error data
The date and time of your visit
Technical information about your connection to our Services
Log data and diagnostic information

2.3 Blockchain Information

Due to the nature of blockchain technology, certain information related to your cryptocurrency transactions is publicly available on the blockchain, including:

Wallet addresses (public keys)
Transaction amounts
Transaction timestamps
Transaction hashes
Smart contract interactions
Gas fees and transaction costs
Token transfers and holdings
Blockchain metadata

2.4 Cookies and Similar Technologies

We and our third-party service providers may use cookies, web beacons, pixel tags, local storage, and other tracking technologies to collect information about your browsing activities on our website. Please refer to our Cookie Policy for more information on how we use these technologies and how you can manage your preferences.

2.5 Information from Third Parties

We may receive information about you from third parties, including:

Business partners with whom we offer co-branded services or engage in joint marketing activities
Blockchain analytics providers
Identity verification service providers
Social media platforms when you connect to our Services through such platforms
Publicly available sources

2.6 Special Categories of Personal Information

We do not intentionally collect any special categories of personal information (such as details about your race, ethnicity, religious beliefs, health data, biometric data, or criminal records) unless required for compliance with applicable laws and regulations, such as KYC/AML requirements in certain jurisdictions.

3. HOW WE USE YOUR INFORMATION

We may use the information we collect for various purposes, including to:

3.1 Provide and Maintain Our Services

Create and manage your account
Provide the functionality of our crypto wallet services
Process transactions and send notices about your transactions
Enable interaction with blockchain networks
Facilitate staking, swapping, and other DeFi activities
Implement security features and protections
Personalize your experience with our Services
Enable multi-chain compatibility and cross-chain functionality

3.2 Customer Support and Communications

Respond to your inquiries, comments, questions, and requests
Provide customer support and troubleshooting assistance
Send administrative information, including updates to our terms, policies, and security alerts
Communicate with you about your account and transactions
Resolve disputes and address concerns

3.3 Improvement and Development

Monitor and analyze usage trends and preferences
Conduct research and analytics to improve our Services
Develop new products, services, and features
Test and improve the performance of our Services
Debug and fix technical issues
Generate anonymized, aggregated data for analytical purposes

3.4 Marketing and Promotional Activities

Send promotional communications, such as special offers, token sale information, or new feature announcements
Administer rewards, surveys, contests, or other promotional activities
Measure the effectiveness of our marketing and promotional campaigns
Provide personalized content and information

3.5 Security and Protection

Detect, prevent, and address technical issues
Protect against fraud, unauthorized transactions, and other harmful activity
Verify your identity when required
Enforce our Terms and Conditions and other policies
Protect the rights, property, or safety of our users and the public

3.6 Legal Compliance

Comply with applicable laws, regulations, and legal processes
Respond to lawful requests from public and governmental authorities
Enforce our legal rights and remedies
Defend against legal claims

We process your personal information for these purposes based on the following legal bases:

Performance of a contract when we provide you with our Services
Our legitimate interests, which do not override your fundamental rights and freedoms
Your consent, where required by law
Compliance with legal obligations

4. DISCLOSURE OF YOUR INFORMATION

We may share your information in the following situations:

4.1 Service Providers

We may share your information with third-party service providers who perform services on our behalf, such as:

Cloud storage providers
Payment processors
Analytics companies
Customer support services
Marketing and advertising partners
Email service providers
Identity verification services
Security and fraud prevention providers
Software development contractors

These service providers are only authorized to use your information as necessary to provide services to us and are contractually obligated to maintain the confidentiality and security of your information.

4.2 Business Partners

We may share your information with business partners with whom we jointly offer products or services, or who provide services that can be integrated with our wallet (e.g., DeFi protocols, exchanges, or staking services).

4.3 Legal Requirements

We may disclose your information if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This may include:

Responding to legal process such as subpoenas or court orders
Complying with applicable laws and regulations
Cooperating with law enforcement investigations
Protecting against fraud or other illegal activity

4.4 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your information may be transferred as part of that transaction. We will notify you of any change in ownership or uses of your personal information via email and/or a prominent notice on our website.

4.5 With Your Consent

We may share your information with third parties when you have given us your consent to do so.

4.6 Aggregated or De-identified Information

We may share aggregated or de-identified information that cannot reasonably be used to identify you with third parties for various purposes, including to improve our Services and for business development, marketing, and research purposes.

We do not sell your personal information to third parties for monetary consideration. However, certain jurisdictions may define "sale" broadly to include any sharing of information for value, including targeted advertising or analytics services. If you are resident in such a jurisdiction, you may have additional rights as described in the relevant section below.

5. DATA SECURITY

We implement reasonable and appropriate technical, administrative, and physical security measures designed to protect your personal information from unauthorized access, disclosure, and destruction. These measures include:

Encryption of sensitive data both in transit and at rest
Regular security assessments and audits
Access controls and authentication procedures
Secure development practices
Employee training on data privacy and security
Physical security measures for our facilities
Incident response plans

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the secrecy of your unique password and account information and for controlling access to your email communications.

In the event of a data breach that affects your personal information, we will notify you in compliance with applicable laws and regulations.

6. DATA RETENTION

We retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, resolving disputes, enforcing our agreements, or as otherwise required by law.

To determine the appropriate retention period for personal information, we consider:

The amount, nature, and sensitivity of the personal information
The potential risk of harm from unauthorized use or disclosure
The purposes for which we process the information and whether we can achieve those purposes through other means
The applicable legal, regulatory, tax, accounting, or other requirements

When we no longer need your personal information, we will securely delete or anonymize it. In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. YOUR RIGHTS AND CHOICES

Depending on your location, you may have certain rights regarding your personal information, including:

7.1 Access and Portability

You may have the right to request a copy of the personal information we hold about you and to receive it in a structured, commonly used, and machine-readable format.

7.2 Correction

You may have the right to request correction of any inaccurate or incomplete personal information that we hold about you.

7.3 Deletion

You may have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected.

7.4 Restriction and Objection

You may have the right to request that we restrict or cease processing of your personal information in certain circumstances, such as when you contest the accuracy of the data. You may also have the right to object to our processing of your personal information where we are relying on a legitimate interest.

7.5 Withdraw Consent

Where we process your personal information based on your consent, you have the right to withdraw that consent at any time.

7.6 Opt-out of Marketing Communications

You can opt out of receiving marketing communications from us by following the unsubscribe instructions included in each marketing email or by contacting us using the contact information below.

7.7 Do Not Track

Some browsers have a "Do Not Track" feature that signals to websites that you do not want to have your online activities tracked. Our Services do not currently respond to "Do Not Track" signals.

To exercise these rights, please contact us using the information provided in the "Contact Us" section below. We may need to verify your identity before responding to your request. We will respond to your request within the timeframe required by applicable law.

Please note that there may be circumstances where we are not legally required to comply with your request, or where we may keep certain information for legitimate business, legal, or compliance purposes.

8. INTERNATIONAL DATA TRANSFERS

Cold Wallet operates globally, which means your information may be transferred to, stored, and processed in countries other than the country in which you reside. These countries may have different data protection laws than your country of residence.

When we transfer your information to other countries, we will protect that information as described in this Privacy Policy and in accordance with applicable law. We implement appropriate safeguards for cross-border transfers of personal information, including:

Data transfer agreements incorporating standard contractual clauses approved by the European Commission or other relevant authorities
Certification to privacy frameworks that recognize the adequacy of protection for transferred data
Obtaining your consent for the transfer where required by law
Transferring data to countries that have been deemed to provide an adequate level of protection

By using our Services, you consent to the transfer of your information to these countries for the purposes described in this Privacy Policy.

9. THIRD-PARTY WEBSITES AND SERVICES

Our Services may contain links to third-party websites and services, including decentralized applications (DApps), exchanges, and social media platforms. When you click on these links, you will be directed away from our Services. We are not responsible for the privacy practices of these third-party websites or services.

This Privacy Policy does not apply to third-party websites, services, or applications, even if they are accessible through our Services. We encourage you to read the privacy policies of every website you visit and service you use. We also do not control and are not responsible for any information collected by blockchain networks on which transactions are processed.

10. CHILDREN'S PRIVACY

Our Services are not intended for children under the age of 18. We do not knowingly collect personal information from children under 18. If we learn we have collected or received personal information from a child under 18, we will delete that information unless a parent or guardian provides verifiable consent.

If you believe we might have any information from or about a child under 18, please contact us using the contact information provided below.

11. MARKETING COMMUNICATIONS

With your consent, we may send you marketing communications about our products, services, and promotions. You can opt out of these communications at any time by:

Following the unsubscribe instructions contained in the emails
Texting STOP in response to any SMS message
Contacting us using the contact information provided below
Adjusting your communication preferences in your account settings

Even if you opt out of marketing communications, we may still send you non-promotional communications, such as those about your account, transactions, or our ongoing business relationship.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. If we make material changes, we will notify you as required by applicable law, which may include posting the revised Privacy Policy on our website with an updated effective date, sending you an email or other notification, or displaying a notice within our Services.

We encourage you to review the Privacy Policy whenever you access our Services to stay informed about our information practices and your choices. Your continued use of our Services after we make changes is deemed to be acceptance of those changes.

13. CONTACT US

If you have any questions, concerns, or feedback about this Privacy Policy or our privacy practices, please contact our Data Protection Officer or privacy team at:

Email: [email protected]

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy.

14. ADDITIONAL INFORMATION FOR RESIDENTS OF SPECIFIC JURISDICTIONS

14.1 European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, the following additional information applies:

Data Controller: Cold Wallet is the data controller responsible for your personal information.
Legal Basis for Processing: Our processing of your personal information is based on the following legal grounds:
- Performance of a contract when we provide you with our Services
- Our legitimate interests, which do not override your fundamental rights and freedoms
- Your consent, where required
- Compliance with legal obligations
International Transfers: When we transfer your information outside the EEA, UK, or Switzerland to countries not deemed to provide an adequate level of data protection, we use Standard Contractual Clauses approved by the European Commission or other appropriate safeguards to protect your personal information.
Supervisory Authority: You have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law. The supervisory authority will be the one in the country where you live or work, or where the alleged infringement took place.

14.2 California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA) provide you with specific rights regarding your personal information, including:

Right to Know: You have the right to request that we disclose certain information about our collection, use, disclosure, and sale of your personal information over the past 12 months.
Right to Delete: You have the right to request that we delete your personal information, subject to certain exceptions.
Right to Correct: You have the right to request that we correct inaccurate personal information.
Right to Opt-Out of Sale or Sharing: We do not sell your personal information for monetary consideration. However, if our sharing of your information with certain third parties is considered a "sale" or "sharing" under California law, you have the right to opt out.
Right to Limit Use of Sensitive Personal Information: You have the right to request that we limit the use of your sensitive personal information.
Non-Discrimination: We will not discriminate against you for exercising any of your CCPA/CPRA rights.

To exercise your CCPA/CPRA rights, please contact us using the information in the "Contact Us" section. You may also authorize an agent to submit a request on your behalf, provided you give the authorized agent written permission to do so and verify your identity with us.

14.3 Other Jurisdictions

Additional privacy rights and obligations may apply to residents of other jurisdictions. Please contact us for more information about your specific rights under local law.

15. BLOCKCHAIN-SPECIFIC PRIVACY CONSIDERATIONS

15.1 Public Nature of Blockchain Data

Blockchain networks are inherently public and transparent. When you conduct transactions on a blockchain, information such as your public wallet address, transaction amounts, and timestamps become permanently recorded on a public ledger that anyone can view. While your public address does not directly identify you, it can potentially be linked to your identity through various means.

15.2 Immutability of Blockchain Data

Once information is recorded on a blockchain, it typically cannot be altered or deleted due to the immutable nature of blockchain technology. This means that transactions and associated data generally cannot be removed or modified, even if they contain errors or personal information.

15.3 Cross-Border Nature of Blockchain Networks

Blockchain networks operate across multiple jurisdictions without regard to national borders. Your transaction data may be processed and stored by nodes (computers) located in various countries worldwide, which may have different data protection standards.

15.4 Wallet Connection Privacy

When you connect your wallet to our Services, we may receive your public wallet address and transaction history associated with that address. We use this information to provide our Services, but we do not have access to your private keys or the ability to initiate transactions without your explicit authorization.

15.5 Privacy-Enhancing Options

We may offer features designed to enhance your privacy when using our Services, such as:

Support for privacy-focused cryptocurrencies or protocols
Options to disconnect your wallet when not in use
Educational resources about blockchain privacy best practices

We encourage you to learn about blockchain privacy implications and take appropriate steps to protect your privacy when using our Services.