Wigwam App privacy policy agreement 

Last Updated: 24.08.24

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. Mathematical Proofs and Protocol Data: We collect zero-knowledge proofs, homomorphically encrypted data sets, and other mathematical proofs as part of the MPC protocol. These data points are used strictly for validation purposes and contain no PII.
  4. 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 only retained temporarily and used to ensure the safety and reliability of our service.
  5. 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 might be temporarily retained until it can be completed.

3. Usage Data and Loyalty Program

To improve your experience and offer rewards through our loyalty program, we collect and analyze usage data such as:

  1. Wallet usage data (e.g., swap activities, dApps usage)
  2. On-chain data available via public blockchain explorers
  3. Wallet balances and related metrics

4. Third-Party Services and KYC Information

While we do not collect or store KYC information, certain third-party services integrated within the App may require KYC details to provide specific offerings such as purchasing crypto via fiat, launching a credit card, or opening an IBAN account. In such cases, you will be required to sign a separate privacy agreement directly with the integrated solution provider.

5. Security of Data

The security of your data is important to us. However, please note that no method of transmission over the internet or electronic storage is completely secure. While we strive to use commercially acceptable means to protect your data, we cannot guarantee its absolute security.

6. 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 [email protected]. 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).

7. 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 [email protected].

8. 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.

9. How We Use Your Information

The data we collect is primarily used to:

  1. Provide and maintain the App’s core functionality.
  2. Ensure the security and integrity of the App.
  3. Improve and optimize user experiences through analysis and feedback.
  4. Offer rewards and track participation in our loyalty programs.

10. Data Sharing and Disclosure

We do not sell, trade, or rent your information to third parties. We may share your data in the following situations:

  1. Legal Compliance: If required by law or in response to valid requests by public authorities.
  2. Service Providers: To trusted partners who assist us in operating the App, as long as these parties agree to keep your information confidential and comply with applicable privacy laws.

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.

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: [email protected]
Address: 33 St. James’s Square, London, England, SW1Y 4JS