Privacy Policy

This Privacy Policy applies to:

• WINK Wallet;
• WINK Account;
• winkwallet.app;
• wallet-related services, including wallet creation, wallet import, wallet export, portfolio views, sending, receiving, swapping, gas abstraction, and customer support.

This Privacy Policy does not apply to third-party websites, applications, blockchain networks, protocols, exchanges, decentralized applications, or other services that WINK does not control.

If we introduce additional features in the future, we may update this Privacy Policy where those features involve new categories of personal data or new processing activities.

Blockchain networks are public by nature.

When you use blockchain networks, certain information may be visible publicly, including wallet addresses, token balances, transaction hashes, smart contract interactions, and transaction history.

WINK does not control public blockchains and cannot delete, modify, reverse, or hide blockchain records.

We may collect the following categories of information.

3.1 Account and Authentication Information

When you create or use a WINK Account, we may collect:

• email address;
• phone number, where used;
• login method, such as Google, Apple, email, or phone;
• account identifiers;
• authentication and session data;
• device verification information;
• security settings;
• account recovery information, where enabled.

3.2 Wallet and Blockchain Information

We may process wallet-related information, including:

• wallet addresses;
• public blockchain transaction hashes;
• supported asset balances;
• chain and network information;
• transaction status;
• send, receive, swap, and portfolio activity;
• smart contract interactions initiated by you.

This information may be collected directly from public blockchains, blockchain indexing providers, wallet infrastructure providers, or from your use of WINK Wallet.

3.3 Private Keys, Seed Phrases, and Encrypted Backup Data

WINK Wallet is designed as a self-custody wallet.

Private keys and seed phrases are stored on your device.

If you enable encrypted backup or synchronization, encrypted wallet backup data may be processed through our key management partner, Turnkey.

Neither WINK nor Turnkey can view your private keys or seed phrases in clear text.

WINK will never ask you to share your private keys, seed phrase, recovery phrase, passwords, or sensitive access credentials with support. You should never share this information with anyone.

3.4 Device and Technical Information

We may collect technical information, including:

• device type;
• operating system;
• app version;
• browser type;
• IP address;
• approximate location derived from IP address;
• crash logs;
• diagnostics;
• security logs;
• performance data;
• session activity;
• device identifiers, where permitted.

This information helps us maintain security, prevent abuse, troubleshoot errors, and improve performance.

3.5 Usage Information

We may collect information about how you use WINK services, including:

• pages or screens viewed;
• features used;
• clicks and interactions;
• app flows;
• wallet actions initiated;
• support interactions;
• error and diagnostic events.

3.6 Support Information

If you contact support, we may collect:

• your email address;
• message content;
• screenshots you provide;
• wallet address or transaction hash, if relevant;
• support history;
• issue details.

Do not send private keys, seed phrases, recovery phrases, passwords, or sensitive access information to support.

We use information to:

• provide and operate WINK Wallet;
• create and manage WINK Accounts;
• authenticate users and maintain secure sessions;
• help you initiate and manage blockchain transactions requested by you;
• display balances, portfolio data, transaction history, and supported assets;
• enable wallet creation, import, export, backup, and synchronization where supported;
• provide encrypted backup and recovery features where enabled;
• support gas abstraction and fee handling on supported chains and assets;
• provide customer support and troubleshoot issues;
• maintain security and prevent fraud, abuse, unauthorized access, and misuse;
• improve app performance and user experience;
• send service updates, security alerts, and important notices;
• comply with legal, regulatory, tax, accounting, or compliance obligations;
• enforce our Terms and policies.

Where applicable data protection laws require a legal basis, we process personal information based on:

• performance of a contract, where processing is needed to provide WINK services;
• legitimate interests, such as security, fraud prevention, product improvement, and service operation;
• consent, where required for optional cookies, analytics, marketing, or optional features;
• legal obligations, where processing is required by law, regulation, court order, or compliance requirement.

We may share information with the following categories of recipients.

6.1 Service Providers

We may use third-party providers for:

• wallet infrastructure;
• encrypted key management;
• blockchain indexing;
• hosting and cloud infrastructure;
• analytics, where enabled;
• crash reporting;
• customer support;
• communications;
• fraud prevention;
• security;
• technical monitoring.

These providers are authorized to process information only as needed to provide services to WINK or to you.

6.2 Key Management Partner

If you enable encrypted wallet backup or synchronization, encrypted wallet backup data may be processed through our key management partner, Turnkey.

Neither WINK nor Turnkey can view your private keys or seed phrases in clear text.

6.3 Blockchain Networks

When you initiate blockchain transactions, relevant transaction data is broadcast to public blockchain networks.

Blockchain data may become public, permanent, and visible to anyone.

6.4 Third-Party Integrations

WINK may integrate with third-party services, such as blockchain networks, swap providers, liquidity providers, infrastructure providers, or other technical partners.

If you choose to use third-party services, your information may be shared with or collected by those third parties.

Third-party services are governed by their own terms and privacy policies.

6.5 Legal and Compliance

We may disclose information if required to:

• comply with applicable law;
• respond to lawful requests;
• protect rights, safety, and security;
• prevent fraud, abuse, or illegal activity;
• enforce our Terms;
• comply with regulatory, court, or governmental requests.

6.6 Business Transfers

If WINK is involved in a merger, acquisition, reorganization, financing, or sale of assets, information may be transferred as part of that transaction, subject to appropriate safeguards.

We may use cookies and similar technologies on our website to:

• operate the website;
• remember preferences;
• improve performance;
• understand usage;
• support security;
• measure marketing effectiveness, where enabled.

For more information, see our Cookie Policy.

We may use analytics and performance tools to understand how users interact with WINK services, identify errors, improve reliability, and optimize the user experience.

Where required, optional analytics or marketing cookies will be used only with your consent.

We retain personal information only for as long as reasonably necessary to provide the services, comply with legal obligations, resolve disputes, prevent fraud, maintain security, and enforce our agreements.

Blockchain data may remain permanently available on public blockchain networks and cannot be deleted by WINK.

We use technical and organizational measures designed to protect information, including encryption, access controls, monitoring, secure infrastructure, and security review processes.

However, no system is completely secure.

You are responsible for protecting your device, WINK Account credentials, authentication methods, exported private keys, seed phrases, and recovery materials.

Depending on your location, you may have rights to:

• access your personal information;
• correct inaccurate information;
• request deletion;
• object to certain processing;
• restrict processing;
• request portability;
• withdraw consent where processing is based on consent;
• lodge a complaint with a data protection authority.

To exercise your rights, contact us at: privacy@winkwallet.app

Some requests may be limited where we must retain information for security, legal, compliance, fraud-prevention, or operational reasons.

To specifically request the deletion of your WINK Wallet account and associated data, you can use our dedicated page:

https://winkwallet.app/delete-account

You can also delete your account directly from the app, where available, by going to:

Settings → Account → Delete Account

If we send marketing communications, you may opt out at any time by using the unsubscribe link or contacting us.

We may still send service, security, account, and transactional messages.

WINK Wallet is not intended for children.

You must be at least the age of legal majority in your jurisdiction, or otherwise legally permitted to use the services.

We do not knowingly collect personal information from children.

Your information may be processed in countries other than your country of residence.

Where required, we use appropriate safeguards for international data transfers.

WINK may contain links to or integrations with third-party services.

We are not responsible for the privacy practices, content, or security of third-party services.

You should review their privacy policies before using them.

We may update this Privacy Policy from time to time.

If we make material changes, we will take reasonable steps to notify users, such as updating the date above or providing an in-app or website notice.

For questions about this Privacy Policy, contact: