Privacy Policy

Effective date: 13.01.2026

1. Introduction

Welcome to Wigwam.

Wigwam (“we”, “us” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website at https://wigwam.app (the “Site”) and the services available through our Site, including any mobile applications, web applications and browser extensions (collectively, the “Services”), and how we use and disclose that information.

By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy (including any applicable changes) and an applicable Terms of Use, including its applicable limitations on damages and provisions for the resolution of disputes.

2. Definitions

SERVICES https://wigwam.app (the “Site”) and the services available through this site, including any mobile applications, web applications and browser extensions.

PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Services or from Services infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

We may collect the following categories of data depending on how you interact with our website, browser extension, and mobile/web application:

Usage & Analytics Data

  1. App and website interactions (page views, clicks, feature usage)
  2. Wallet activity (swaps, dApp usage, signed transactions)
  3. Crash logs and performance diagnostics
  4. Attribution and campaign data

Technical & Device Data

  1. IP address and network logs
  2. Device type, operating system, app version
  3. Browser type and user agent
  4. Advertising identifiers (where permitted by your device settings)

Personal Data

  1. Email address (if provided)
  2. Public wallet address
  3. In-app user identifiers
  4. Push notification tokens (used solely for delivering notifications)

Blockchain Data

  1. Public transaction information
  2. Wallet balances and related on-chain metrics

Note that blockchain data is inherently public and cannot be removed once published.

Communications

  1. Messages sent to our support team
  2. Email communications and preferences

Some of this data is collected automatically, while other data is provided voluntarily by you. We use this information to operate our services, improve performance, provide customer support, enhance security, and comply with legal obligations

5. Data Collection by Platform

We collect limited personal and technical information depending on how you interact with Wigwam (Website, Browser Extension, or Mobile/Web App). The purpose of this data collection is to provide core functionality, improve performance, ensure security, and enhance user experience.

5.1 Website (wigwam.app)

When you visit our website, we collect standard usage data through cookies and analytics tools such as Google Analytics and internal tracking systems.

This may include:

  1. IP address
  2. Browser type and version
  3. Pages visited and time spent
  4. Device and operating system information
  5. Anonymous usage metrics

Cookies and similar technologies are used to analyze website performance and improve content. You may disable cookies through your browser settings, though some features may not function properly.

If you voluntarily provide your email address (e.g., newsletter signup), we store it to communicate with you. You may unsubscribe at any time.

5.2 Wigwam Browser Extension

The Wigwam Extension collects only anonymous usage data, including:

  1. Anonymized clicks
  2. Pageview events

No personally identifiable information or wallet credentials are collected through the extension.

Wigwam Mobile & Web Application

To operate the wallet and related services, we collect limited information, including:

Personal & Wallet Data

  1. Email address (if provided)
  2. Public wallet address
  3. Signed transaction data (some of which may be publicly visible on-chain by design)

Technical & Security Data

  1. IP address and network logs (temporarily retained)
  2. Device type, operating system, app version
  3. User agents and diagnostic data

This information is used for security, fraud prevention, performance monitoring, and service reliability.

Usage & Loyalty Program Data

We collect in-app activity such as:

  1. Wallet usage (swaps, dApp interactions)
  2. Page views and crash logs
  3. Public blockchain data (balances, transactions)
  4. Internal identifiers for analytics and loyalty rewards

These insights help us improve the wallet experience and operate our loyalty program.

5.3 Mobile Analytics & Attribution

We use AppsFlyer to measure app performance and marketing effectiveness. AppsFlyer may process:

  1. Device information
  2. Advertising identifiers (where permitted)
  3. IP address (approximate location)
  4. App installs, launches, and in-app events
  5. Attribution data (campaign source)

This data is used strictly for analytics, attribution, and fraud prevention. You may opt out via your device privacy settings.

Please read detailed information about tracked data in our separate Wigwam App privacy policy agreement.

5.4 Third-Party Services

Certain features inside the Wigwam Extension and Wigwam App are provided by independent partners:

5.4.1 Swap functionality is powered by LI.FI

When you use the swap functionality in the App or Extension, the underlying routing and execution are powered by Li.Fi, an external service provider. Your use of the swap functionality is therefore also subject to Li.Fi’s own terms and conditions (https://li.fi/legal/terms-and-conditions/) and privacy policy (https://li.fi/legal/privacy-policy/). Wigwam only provides an interface to Li.Fi’s service and does not control, operate, or assume responsibility for Li.Fi’s processing of your data or any risks associated with swaps executed through Li.Fi.

5.4.2 Fiat on/off-ramps are provided by Transak and Mercuryo

When you use the “Buy” or “Sell” functionality in the App, including any fiat on-ramp or off-ramp services, these are provided by external partners, currently including Transak and Mercuryo. These providers act as independent service providers and may require you to complete KYC/AML checks under their own regulatory obligations. Any personal data you submit directly to these providers (including KYC information and payment details) is processed under their respective privacy policies, as published on their own websites, not this Privacy Policy. Wigwam does not control, access, or store your KYC documentation collected by these providers and is not responsible for their handling of such data.

6. Use of Data

Wigwam uses collected data for the following purposes:

  1. To provide, operate, and maintain our Services
  2. To manage your account and deliver core wallet functionality
  3. To communicate with you, including service updates, security notices, and support responses
  4. To enable interactive features when you choose to use them
  5. To provide customer support and respond to inquiries
  6. To measure and improve product performance, usability, and reliability
    To monitor usage patterns and analyze trends
  7. To track the effectiveness of advertising and promotional campaigns
  8. To detect, prevent, and resolve technical issues, fraud, and security incidents
  9. To comply with legal obligations and enforce our terms and agreements
  10. To send you marketing communications and product updates, where permitted (you may opt out at any time)
  11. To fulfill any other purpose for which you provide the information
  12. For any additional purpose with your consent

We process this data to support legitimate business interests such as improving our Services, ensuring platform security, and enhancing user experience, unless otherwise required by law.

7. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

8. Transfer of Data

Your information, including Personal Data, may be transferred to and processed on servers located outside your country or jurisdiction, where data protection laws may differ from those in your location.

By using our Services and submitting your information, you acknowledge and agree to such transfers.

Wigwam takes reasonable technical and organizational measures to ensure your data is handled securely and in accordance with this Privacy Policy. Where required by law, we rely on appropriate safeguards (such as contractual protections or standard data protection clauses) to protect your Personal Data during international transfers.

9. Disclosure of Data

We may disclose your Personal Data in the following circumstances:

  1. Business Transfers: If Wigwam or its affiliates are involved in a merger, acquisition, restructuring, or asset sale, your Personal Data may be transferred as part of that transaction.
  2. Affiliates and Service Providers: We may share information with our subsidiaries, affiliates, and trusted service providers who assist us in operating our Services, subject to confidentiality obligations.
  3. Legal Requirements: We may disclose your information where required to comply with applicable law, regulation, legal process, or governmental request.
  4. Protection of Rights: To protect the rights, property, or safety of Wigwam, our users, or others, including fraud prevention and security enforcement.

We do not sell your Personal Data.

10. Security of Data

The security of your data is important to us. We use commercially reasonable technical and organizational safeguards designed to protect your Personal Data against unauthorized access, loss, misuse, or alteration.

However, no method of transmission over the Internet or electronic storage is completely secure. While we strive to protect your information, we cannot guarantee absolute security.

11. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. - See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at info@wigwam.app. In certain circumstances, you have the following data protection rights:

  • the right to access, update or to delete the information we have on you;
  • the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
  • the right to object. You have the right to object to our processing of your Personal Data;
  • the right of restriction. You have the right to request that we restrict the processing of your personal information;
  • the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  • the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests.

Please note, we may not be able to provide Services without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

12. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. - See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/.

According to CalOPPA we agree to the following:

  • users can visit our site anonymously;
  • our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
  • users will be notified of any privacy policy changes on our Privacy Policy Page;
  • users are able to change their personal information by emailing us at info@wigwam.app.

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

13. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Services are used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

14. Analytics

We use third-party service providers to monitor and analyze usage of our website and applications in order to improve performance, usability, and marketing effectiveness.

14.1 Google Analytics on wigwam.app

Google Analytics is a web analytics service provided by Google that tracks and reports website traffic. Google uses the collected data to monitor usage of our website and may share this information with other Google services. Google may also use this data to contextualize and personalize ads within its advertising network.

For more information on Google’s privacy practices, please visit:
https://policies.google.com/privacy
You may also review Google’s data protection measures here:
https://support.google.com/analytics/answer/6004245

14.2 Amplitude in the Wigwam Application

Amplitude is a product analytics platform used to understand how users interact with the Wigwam application and to help us improve usability.

We collect anonymous usage data only, including:

  1. Anonymized clicks
  2. Pageview events

This data is used exclusively to improve the user experience.

We never track via Amplitude:

  1. Private keys
  2. Wallet addresses
  3. Transactions
  4. Balances
  5. Hashes
  6. IP addresses
  7. Any personal information

You may disable analytics tracking at any time in your wallet settings.

Amplitude’s privacy notice is available at:
https://amplitude.com/privacy

14.3 AppsFlyer in the Wigwam (Mobile/Web) Application

We use AppsFlyer for mobile analytics and attribution to understand how users discover our app, measure campaign effectiveness, and prevent fraud.

AppsFlyer may process the following information:

  1. Device information (model, OS, app version, language)
  2. Advertising identifiers (such as IDFA or Google Advertising ID, where permitted)
  3. IP address (used to derive approximate location)
  4. App installs, launches, and in-app events
  5. Attribution data (such as referral source or campaign information)

This data is used solely for analytics, attribution, performance measurement, and fraud prevention.

You may opt out of AppsFlyer data collection by adjusting your device privacy settings (e.g., limiting ad tracking on iOS or opting out of Ads Personalization on Android).

AppsFlyer’s privacy policy is available at:
https://www.appsflyer.com/privacy-policy/

15. CI/CD tools

We may use third-party Service Providers to automate the development process of our Services.

  1. GitHub
  2. GitHub is provided by GitHub, Inc.
  3. GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

16. Behavioral Remarketing

Wigwam website uses remarketing services to advertise on third party websites to you after you visited our website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our website.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/adshttp://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter (X) Remarketing

We use Twitter remarketing services to display relevant advertisements to users who have previously interacted with our Services.

You may opt out of Twitter’s interest-based advertising by following their instructions here:
https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads

For more information about how Twitter processes personal data, please review their Privacy Policy:
https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

17. Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

18. Children's Privacy

Our Services are not intended for use by children under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

19. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

20. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: info@wigwam.app.