Wigwam App privacy policy agreement 

Last Updated: 13.01.26

Thank you for choosing Wigwam, a product of Jetter App LTD (“we,” “us,” or “our”). Your privacy is important to us. This Privacy Policy explains how we collect, use, and share information when you use our crypto wallet application, Wigwam (the “App”), available on the Google Play Store and Apple App Store.

1. Definitions

  1. SERVICES: The Wigwam app (the “App”) services available through mobile and web applications.
  2. PERSONAL DATA: 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).
  3. USAGE DATA: Data collected automatically, either generated by the use of services or from the services infrastructure itself (for example, the duration of a page visit).
  4. DATA CONTROLLER: 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.
  5. DATA PROCESSORS (OR SERVICE PROVIDERS): 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.
  6. DATA SUBJECT: Any living individual who is the subject of Personal Data.
  7. THE USER: The individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data.

2. Information We Collect

In order to provide our services, we collect certain data as outlined below:

  1. Email Address: If you choose to use an email address during the wallet generation process, we collect and store this information.
  2. Public Digital Address: We collect the public digital address once your MPC (Multi-Party Computation) wallet is generated. This information is inherently public as it forms part of the blockchain system.
  3. In-App User Identifiers: We assign internal in-app identifiers to support analytics, application functionality, and our loyalty program.
  4. Push Notification Tokens: We collect push notification tokens solely for the purpose of delivering service-related or promotional notifications to your device. These tokens are not used for advertising profiling.
  5. Public Blockchain Data: We collect publicly available blockchain information, including wallet balances and transaction records, as part of providing wallet functionality and usage insights.
  6. Internal Identifiers for Analytics and Loyalty Rewards: We use internal identifiers to analyze app usage and operate our integrated loyalty program.
  7. Mathematical Proofs and Protocol Data: We collect zero-knowledge proofs, homomorphically encrypted datasets, and other mathematical proofs as part of the MPC protocol. These data points are used strictly for validation purposes and contain no personally identifiable information.
  8. Network Logs: We collect standard network logs, including IP addresses, user agents, operating system data, and other related information for security purposes. This information is retained temporarily and used to ensure the safety and reliability of our service.
  9. Transaction Data: We collect visibility into transactions that are signed via the App, which may include data in the transaction messages that a user signs. This information is propagated on-chain and therefore publicly available. In cases where transactions remain off-chain (e.g., insufficient gas), this information may be temporarily retained until completion.
  10. Wallet Usage Data: We collect data on in-wallet activities (such as swap transactions, dApp usage, page views, crash logs, and internal user identifiers) to gather insights aimed at improving the wallet experience and enhancing our integrated loyalty program.

2.1. Mobile Analytics & Attribution (AppsFlyer)

We use a third-party analytics and attribution service provided by AppsFlyer Ltd. to help us understand how users find and use our mobile application, measure the effectiveness of marketing campaigns, and improve our services.

When you install or use our app, certain information may be automatically collected and shared with AppsFlyer, including:

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

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

AppsFlyer processes this information in accordance with its own Privacy Policy and applicable data protection laws.

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

For more information on how AppsFlyer handles data, please visit:
https://www.appsflyer.com/privacy-policy/

 2.2 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

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

3. 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

4. Third-Party Services and KYC Information

Third-Party Services

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

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.

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. 

Transak privacy policy: https://transak.com/privacy-policy 

Mercuryo privacy policy: https://mercuryo.io/legal/privacy/ 

Wigwam does not control, access, or store your KYC documentation collected by these providers and is not responsible for their handling of such data.

5. Push Notifications

We may send push notifications to your mobile device to provide updates, service-related messages, promotional communications, or other information related to our application.

To enable push notifications, your device may provide us with a push notification token. This token is used solely to deliver notifications and is not shared with third parties for advertising purposes.

You can opt out of receiving push notifications at any time by changing your device settings.

6. 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.

7. 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, as covered by the GDPR. 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 or want it removed from our systems, please email us at info@wigwam.app. In certain circumstances, you have the following data protection rights:

  1. The right to access, update, or delete the information we hold about you.
  2. The right of rectification if the information is inaccurate or incomplete.
  3. The right to object to our processing of your Personal Data.
  4. The right to request that we restrict the processing of your personal information.
  5. The right to data portability, allowing you to obtain a copy of your data in a structured, machine-readable format.
  6. The right to withdraw consent at any time where we rely on your consent to process your data.

Please note that we may ask you to verify your identity before responding to such requests. Additionally, some services may not be available if certain necessary data is not provided.

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).

8. Your Data Protection Rights Under the California Privacy Protection Act (CalOPPA)

CalOPPA requires commercial websites and online services to post a privacy policy. If you are a California resident, you have the following rights:

  1. You can visit our site anonymously.
  2. Our Privacy Policy link includes the word “Privacy” and can easily be found on our homepage.
  3. Users will be notified of any privacy policy changes on our Privacy Policy page.
  4. Users can change their personal information by emailing us at info@wigwam.app.

9. Service Providers

We may employ third-party companies and individuals to facilitate our Service (“Service Providers”), provide services on our behalf, perform service-related tasks, or assist us in analyzing 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.

10. Data Sharing and Disclosure

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.

11. Data Retention

We retain network logs and related security data only for as long as necessary to fulfill the purposes outlined in this policy. In general, these logs are stored for a few months before being automatically deleted.

12. Your Choices and Rights

  1. You have the right to opt out of data collection where applicable, such as by disabling certain app features or not providing optional email addresses.
  2. You can request access, correction, or deletion of your information by contacting us via email: info@wigwam.app

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will post the updated policy with the “Last Updated” date at the top. Please review the policy periodically for any changes.

14. Contact Us

If you have any questions about this Privacy Policy or our data practices, please contact us at:

Jetter App LTD
Email: info@wigwam.app
Address: 378–79 Pall Mall, London, England, SW1Y 5ES