Privacy Policy

Your privacy is important to us. WalletConnect respects your privacy and complies with applicable laws and regulations regarding personal information we may collect about you, including across our website, https://walletconnect.com, and other sites we own and operate.

Personal information refers to any information about you that can be used to identify you. Personal information includes information about you as a person (such as name, address, and date of birth), your devices, payment details, and information about how you use a website or online service.

Where our website and services contain links to or involve third-party websites and services, please be aware that those websites and services have their own privacy policies. When using a third-party website or service, you should read their posted privacy policy information about how they collect and use personal information. This Privacy Policy does not apply to websites and services of third parties.

Last updated: 5 July 2024

1. The Types of Information We Collect and How We Collect Information  (referred to, collectively as “Collected Data”)

The types of information we collect include:

• Personal Information: We may ask for, or may automatically collect, personal information, for example, when you use our services, subscribe to our newsletter or when you contact us. Personal information may include your email, IP and wallet addresses and information about your location.
• User-Generated Content: User-generated content refers to materials (text, images, and/or video content) voluntarily supplied to us by our users for the purpose of publication, processing, or usage on our platform. This content is associated with the account or email address used to submit it.
• Transaction Data: Transaction data refers to data that accumulates over the normal course of operation on our platform. These data may include transaction records, stored files, user profiles, analytics data, and other metrics, created or generated as users interact with our services. 

We collect information several ways:.

• Voluntarily provided information refers to any information you knowingly and actively provide us when using or participating in any of our services and promotion, including your name and email address.
• Automatically collected information refers to any information automatically sent by your devices in the course of accessing our website, products and services, including information about your location, IP and wallet address.
• Information collected from other sources includes information that is or has already been written to a blockchain, other publicly available ledgers, or is otherwise in the public domain. Also, your other service providers may provide us with your name and wallet address. Advertising networks, analytics providers and search information providers may provide us with anonymized or de-identified information about you, such as confirming how you found our website. 

We may combine information collected among these several ways with other general information. For example, if you provide us with your location, we may combine your personal information with general information about the currency and language relevant to your location, to provide you with an enhanced experience with our website and services.

2. Reasons for Processing Your Personal Information

We only collect and use your personal information when we have a legitimate reason for doing so and when it is reasonably necessary to provide our services to you.

3. Use of Information

We may collect and use your personal information when you do any of the following on our website or via our services:

• Register for an account
• Sign up to receive updates via email or social media channels
• Use a mobile device or web browser to access our content
• Contact us via email, social media, or similar technologies

We may collect, hold, use, and disclose Collected Data for the following purposes, ensuring personal information will not be further processed in a manner that is incompatible with these purposes:

• To provide you with our platform’s features and services
• To understand how users use the platform, as a whole or as part of groups 

WalletConnect Cloud Infrastructure: We offer hosted infrastructure for users of the WalletConnect Cloud, consisting of components such as a relay server, load balancer, and other infrastructure that receives and transmits encrypted data between known parties. Collected Data that is processed for these purposes may include your or relevant:

• IP address 
• Full wallet address 
• Country and region
• Randomly generated client ID 
• Encrypted data payloads
• Metadata about the relevant protocol 
• User agent and version of the relevant software development kit 

4. Security of Your Personal Information

We will protect the personal information we collect and process within commercially acceptable means to prevent loss, theft, unauthorized access, disclosure, copying, use, or modification. However, please be aware that no method of electronic transmission or storage is 100% secure.

You are responsible for ensuring the security of your own information and assets within the bounds of our services. We, you and your personal information and assets can still become subjects of cyber-attacks, cybercrime, brute force, hacker attacks and further fraudulent and malicious activity including but not limited to viruses, forgeries, malfunctions, and interruptions, which are practically impossible to fully prevent. 

5. How Long We Keep Your Personal Information

We keep your personal information only for as long as necessary. This time period may depend on what we are using your information for, in accordance with this privacy policy. For example, if you have provided us with personal information as part of creating an account, we may retain this information for the duration your account exists on our system. If personal information is no longer required for this purpose, we will delete it or make it anonymous.

However, we may retain your personal information when we have a legitimate reason for doing so, for compliance with legal, accounting, or reporting obligations, for archiving purposes in the public interest, scientific, or historical research purposes, or statistical purposes.

6. Children’s Privacy

Our products and services are not directed to children, i.e., persons under the age of 18, and we do not knowingly collect personal information from children. If we learn that we have inadvertently processed personal information from a child, we will take legally permissible measures to remove that data from our records. We will require the child user to close his or her account and will not allow them to continue using our products and services. If you are a parent or guardian of a child and you become aware that a child has provided us with their personal information, please contact us.

7. Disclosure of Personal Information to Third Parties

In order to perform our contracts, fulfill our legal obligations, protect our legitimate interest and the other purposes and legal grounds, we may disclose your personal information to third parties, including:

• A parent, subsidiary, or affiliate entity of our company, and their employees and contractors
• Third-party service providers for the purpose of enabling them to provide their services that you have requested
• Our existing or potential agents or business partners, including IT service providers, data storage, hosting and server providers, error loggers, debt collectors, maintenance or problem-solving providers, marketing providers, professional advisors, and payment systems operators
• Courts, tribunals, regulatory authorities, and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or to establish, exercise, or defend our legal rights
• Third parties, including partners, agents or sub-contractors, that assist us or with which we collaborate in providing information, products, services, or direct marketing to you
• An entity that buys, or to which we transfer all or substantially all of our assets and business

8. International Transfers of Personal Information

The personal information we collect is stored and/or processed in Europe or where we or our partners, affiliates, and third-party providers maintain facilities. The countries to which we transfer your personal information may not have the same data protection laws as the country in which you initially provided the information. If we transfer your personal information to third parties in other countries, we will perform those transfers in accordance with the requirements of applicable law and protect the transferred personal information in accordance with this privacy policy.

9. Your Rights and Controlling Your Personal Information

• Your choice: You understand we will collect, hold, use, and disclose your personal information in accordance with this privacy policy. You do not have to provide personal information to us, and you may request that we no longer collect your personal information by sending a request to the address in the Contact Information section or use the opt-out facilities here https://opt-out.walletconnect.com. Note that opting-out of information collection may affect your use of our website or our services. Certain services and features may no longer function without collection and use of your personal information. 
• Information from third parties: If we receive personal information about you from a third party, we will protect that information according to this Privacy Policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have a lawful purpose to provide the personal information to us.
• Access: You may request details of the personal information that we hold about you.
• Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant, or misleading, please contact us using the details provided in this Privacy Policy. We will take reasonable steps to correct any information found to be inaccurate, out of date, incomplete, irrelevant or misleading.
• Non-discrimination: We will not discriminate against you for exercising any of your rights over your personal information. Unless your personal information is required to provide you with a particular service or offer, we will not deny you goods or services and/or charge you different prices or rates for goods or services, including granting discounts or other benefits or imposing penalties, or provide you with a different level or quality of goods or services.
• Notification of data breaches: We will comply with laws applicable to us in respect of any data breach.
• Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
• Unsubscribe: To unsubscribe from our email database or opt-out of communications, please contact us using the details provided in the Contact Information section or use the opt-out facilities here https://opt-out.walletconnect.com.

10. Use of Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer and accesses each time you visit so we can understand how you use our site. Cookies help us serve you content based on preferences you have specified.

Please refer to our Cookie Policy for more information.

11. Business Transfers

If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, Collected Data, including your personal information, would be included among the assets transferred to any parties who acquire us or our assets. You acknowledge that such transfers may occur and that any parties who acquire us may, to the extent permitted by applicable law, continue to use your personal information according to this policy, which they will be required to assume as it is the basis for any ownership or use rights we have over such information.

12. Limits of Our Policy

Our website and services may link to third-party sites and services that are not operated by us. Please be aware that we have no control over the content and policies of those sites and services and cannot accept responsibility or liability for their respective privacy practices.

By using blockchain-based services, you acknowledge that your wallet address and related transactions and other personal information are permanently and publicly stored on a blockchain and thereby available for anyone to view. Neither we, nor any third party, has any power to amend or delete such data published to a blockchain. Accordingly, certain privacy rights are not fully available or exercisable by you or us due to the technological infrastructure of the blockchain. 

13. Changes to This Policy

At our discretion, we may change our Privacy Policy to reflect updates to our business processes, current acceptable practices, or legislative or regulatory changes. If we decide to change this Privacy Policy, we will post the updated version at the same link by which you are accessing this Privacy Policy.

If the changes are significant, or if required by applicable law, we will notify you based on industry-accepted means with links to the updated Privacy Policy.

If required by law, we will obtain your permission or give you the opportunity to opt-in to or opt-out of, as applicable, any new uses of your personal information.

14. Additional Disclosures for Compliance with UK and EU General Data Protection Regulation (collectively, “GDPR”) and the California Consumer Privacy Act (as amended by the California Privacy Rights Act of 2020) (“CCPA”)

GDPR Data Controller / Data Processor

The GDPR distinguishes between organizations that process personal data for their own purposes (known as “Data Controllers”) and organizations that process personal data on behalf of other organizations (known as “Data Processors”). 

Individuals may provide us with their personal data when accessing our website and using our services. These personal data may include the following: email, IP and wallet addresses and location information.We may also use all Collected Data on those users. We are a Data Controller with respect to the personal data those users provide to us when visiting our website or using our services. 

WalletConnect also receives information about the customers of the users of our software development kits, including their customers’ dApp userbase preferences and actions. We use this information to, among other things, provide insights into the usage of wallet solutions, including email login, browser wallets, custom wallets, and hardware wallets. These data are used to provide analytics on customer engagement, based on usage behavior of those customers on our platform. WalletConnect does not make any decisions based solely on automated processing which produce legal effects concerning those customers or which significantly affect those customers. WalletConnect processes these data as the Data Processor. The users of our software development kits have the obligation to ensure that they have collected their customers’ respective consents and approval, or otherwise have a lawful purpose, to process such data in accordance with GDPR, other applicable data protection laws, and the WalletConnect General Terms and Conditions and Privacy Policy.

Lawful Purpose for Processing Your Personal Data

Under the GDPR, personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

We will collect and use your personal data only when we have a lawful purpose to do so. In which case, we will collect and use your personal data lawfully, fairly, and in a transparent manner. 

Our lawful bases depend on the services you use and how you use them. This means we use Collected Data, including your personal data, on the following grounds:

• Consent From You: You give us consent to collect and use your personal data for a specific purpose. You may withdraw your consent at any time using the methods we provide; however, withdrawal of consent will not affect any use of your personal data that has already occurred. For example, you may consent to providing your email address for the purpose of receiving marketing emails from us. While you may unsubscribe at any time, we cannot recall any email we have already sent. If you have any further inquiries about how to withdraw your consent, please feel free to inquire using the details provided in the Contact Information section of this Privacy Policy. If you are under 16 years of age, your parent or legal guardian must provide the consent to process your personal data.
• Performance of a Contract or Transaction: You have entered into a contract with us, engaged our services, or requested performance of a transaction or to take preparatory steps before entering into a contract or transaction, including, for example:
• We use your personal data, including email address, when you engage our services to create a wallet address.
• We use your personal data, including email address and wallet address, when you engage our services to securely login and access your account or wallet, including while using an application or dApp.
• Our Legitimate Interests: When we determine processing your personal data to be necessary for our legitimate interests, including, for example:
• Research, development and analyzing data to understand our users, so that we can improve and develop our services
• Marketing and promoting our services. We may apply labels and categories to users so that we can provide relevant, more tailored communications and marketing to users
• Provide anonymized-aggregated data to partners so that they are better positioned to provide and design services tailored to their users
• Identifying methods to limit the volume of spam and fraud 
• Identifying constructive, active users of our services and related protocols and networks, for potential offering of rewards, including reward programs offered by third parties using the WalletConnect protocol.
• Compliance with Law: In some cases, we may have a legal obligation to use or keep your personal data. Such cases may include (but are not limited to) court orders, criminal investigations, government requests, and regulatory obligations. If you have any further inquiries about how we retain personal data to comply with the law, please feel free to inquire using the details provided in the Contact Us section of this privacy policy.

International Transfers Outside of the United Kingdom and European Economic Area (EEA)

We may transfer your personal data outside the UK or the EEA, as applicable, to our affiliates, service providers and business partners. Transfers outside of the UK and the EEA are in accordance with lawful transfer mechanisms. If personal data is transferred to a country which has been found by the European Commission to have an essentially equivalent standard of data protection to the UK or EEA, then we may rely on an “adequacy decision” to transfer that personal data. If personal data is transferred from the EEA or UK to the U.S., we may rely on standard contractual clauses. 

15. Your Rights and Controlling Your Personal Data

You have certain rights regarding your personal data, including the right to access, correct, delete, and restrict the processing of your data. You can also object to the processing of your data and request data portability. To exercise these rights, please contact us using the details provided in the Contact Information section.

Access: You can ask us to confirm whether we are processing your personal data and, if so, what information we process and to provide you with a copy of that information. Residents of the State of California may request a list of all third parties to which we have disclosed certain personal data during the preceding year for those third parties’ direct marketing purposes.

Rectification: If the personal data we hold about you is inaccurate or incomplete, you are entitled to have it rectified. If we have disclosed your personal data to others, we will let them know about the rectification, if possible.

Erasure: You can ask us to delete or remove your personal data in certain circumstances. Such requests may be subject to any retention limits we are required to comply with under applicable laws and regulations. 

Processing Restrictions: You can ask us to block or suppress the processing of your personal data in certain circumstances such as if you contest the accuracy of that personal data or object to us processing it.

Data Portability: In certain circumstances, you may have the right to obtain personal data you have provided to us, in a structured, commonly used, and machine-readable format, and to re-use it elsewhere or ask us to transfer that personal data to a third party of your choice, where technically feasible.

Objection: You can ask us to stop processing your personal data, and we will do so, if we are: 

• Relying on our own or someone else’s legitimate interests to process your personal data except if we can demonstrate compelling legal grounds for the processing or for the establishment, exercise or defense of legal claims;
• Processing your personal data for direct marketing; or
• Processing your personal data for research unless we reasonably believe such processing is necessary for the performance of a task carried out for reasons of public interest (such as by a regulatory or enforcement agency).

Complaints: You have the right to complain to a competent data protection authority. We ask that you first contact us to give us an opportunity to address any concerns.

Withdraw Consent: If we are processing your data based on your consent, you have the right to withdraw consent at any time. Note that withdrawal of consent will not affect the lawfulness of processing prior to that withdrawal or on grounds where consent is not required.

16. Contact Information

Any questions, complaints, comments, and requests regarding this Privacy Privacy are welcome and should be addressed to legal.support@walletconnect.com. 

To help protect your and others privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. We may require you to provide any of the following information: your name, the email associated with your account, or to authenticate your control over a relevant wallet address.