Privacy Policy

We want to be clear about this first, because it matters more than anything else in this document.

We do not collect, store, transmit, or have any access to:

• Your private keys
• Your seed phrase or recovery phrase
• Your wallet password or PIN
• Your biometric data, which stays on your device and is handled by your operating system

These are generated and stored locally on your device. They never reach our servers. This is not a policy choice we could quietly reverse. It is how the app is built.

2. What We Collect

3. How Nia Uses Your Information

Nia, our AI agent, reviews transactions, fees, and on-chain activity so it can warn you about risk and suggest better routes and timing.

To do this, Nia processes:

• The transaction you are about to sign, including the destination address, amount, and contract being called
• Public blockchain data relevant to that transaction, such as known scam addresses and contract history
• Network conditions, including current fees and congestion
• Your portfolio composition, where you have asked for portfolio insights

Nia does not need your private keys to do any of this, and does not have them. It reviews transactions before you sign, and you always make the final decision.

Where you use natural language features, the text of your request is processed to generate a response. We do not use your individual transaction data or your conversations with Nia to train third-party models.

5. Who We Share Information With

We do not sell your personal information. We have never done so, and we do not intend to.

We share information only with:

• Licensed service partners, where you use a feature they provide, such as card issuance, on and off-ramps, or currency conversion
• Infrastructure providers, including cloud hosting, blockchain node providers, analytics, and crash reporting
• Professional advisers, such as auditors and lawyers, where necessary
• Authorities and regulators, where we are legally required to disclose information

Each partner receives only what they need for their specific role, and is required to protect it.

Because Cap Wallet is non-custodial, there is a hard limit on what any authority can compel from us. We cannot hand over keys or funds we do not hold.

6. International Transfers

Cap Wallet operates across several countries, and some of our partners and infrastructure providers are located outside the United Kingdom. When we transfer personal information abroad, we rely on approved safeguards, including UK adequacy regulations, the International Data Transfer Agreement, or Standard Contractual Clauses, depending on the destination.

7. How Long We Keep Information

We keep personal information only for as long as we need it:

• Account and contact details, for as long as your account is active, and for a reasonable period afterwards
• Support messages, for up to three years
• Technical logs and diagnostics, typically for up to twelve months
• Records we are legally required to retain, including under anti-money laundering rules, for as long as the law requires

When we no longer need information, we delete it or anonymise it.

8. What We Cannot Delete

Blockchain records are permanent and public. Once a transaction is confirmed on a blockchain, it cannot be edited, deleted, or withdrawn by us, by you, or by anyone else. This applies to any transaction you make through Cap Wallet.

If you ask us to delete your personal information, we will delete what we hold. We cannot delete anything recorded on a public blockchain, because nobody can.

9. Your Rights

Depending on where you live, you have the right to:

• Access the personal information we hold about you
• Correct information that is wrong or incomplete
• Request deletion of your information
• Object to or restrict how we use it
• Receive your information in a portable format
• Withdraw consent, where we rely on it
• Complain to a data protection authority

To exercise any of these, email privacy@capwallet.app. We will respond within one month.

If you are in the United Kingdom, you can complain to the Information Commissioner’s Office at ico.org.uk. If you are in the European Union, you can complain to your national data protection authority. If you are in Nigeria, you can complain to the Nigeria Data Protection Commission.

10. Security

We protect your information using encryption in transit and at rest, access controls, and regular security review. Your keys are protected by your device’s own secure storage and, where you enable it, biometric authentication.

No system is perfectly secure. The most important security measure for your funds is not ours, it is yours: keep your seed phrase private and backed up somewhere safe. If you lose it, we cannot recover your wallet.

11. Cookies and Analytics

Our website uses cookies and similar technologies to keep the site working, understand how it is used, and remember your preferences. You can control cookies through your browser settings, or through our cookie banner where one is shown.

In the app, we use analytics and crash reporting to understand which features people use and to fix problems. Where required, we ask for your permission first.

12. Children

Cap Wallet is not for anyone under 18. We do not knowingly collect information from children. If we learn that we have, we will delete it. If you believe a child has provided us with information, contact us at privacy@capwallet.app.

13. Changes to This Policy

We may update this Policy from time to time. If we make a material change, we will tell you through the app or by email before it takes effect. The date at the top shows when it was last revised.