Privacy Policy

1. Non-Custodial Nature and Minimal Data Collection

Palit Wallet is a non-custodial (self-custodial) wallet. This means we do not store, control, or have access to your private keys, seed phrases (recovery phrases), passwords, PINs, wallet addresses, transaction signatures, or Digital Assets.

As a result, we collect very limited personal data. Most interactions with the Wallet occur directly on blockchain networks and do not involve us.

2. Information We Collect

We may collect the following categories of information:

• Information You Provide: Contact information (e.g., email address) when you voluntarily contact our support team, submit feedback, or request assistance.
• Information You Provide: Any other information you choose to share with us through communications or forms.
• Automatically Collected Information: Device and usage data such as device type, operating system, IP address, browser type, app version, and usage statistics (e.g., features accessed, session duration).
• Automatically Collected Information: Analytics data collected through third-party tools to improve the Services (e.g., crash reports, performance metrics).
• Automatically Collected Information: Log data related to app functionality and security.
• Blockchain-Related Data: We do not collect your private keys or seed phrases. However, when you use the Wallet, publicly visible blockchain data (such as your wallet address and transaction history on public blockchains) may be displayed or processed locally on your device. We do not store or link this data to your identity in our systems unless you voluntarily provide it (e.g., for support).

We do not require account registration, KYC, or personal identification to use the core wallet functions.

3. How We Use Your Information

We use the limited personal information we collect for the following legitimate purposes:

• To provide, maintain, and improve the Services.
• To respond to your inquiries and provide customer support.
• To send important notices, updates, or security alerts (where you have provided consent or where permitted by law).
• To analyze usage trends and enhance user experience and security.
• To comply with legal obligations, prevent fraud, or protect our rights and the security of the Services.
• For any other purpose with your consent or as permitted or required by law.

We do not use your information for marketing purposes unless you explicitly opt in.

4. Sharing and Disclosure of Information

We do not sell your personal data.

We may share information only in the following limited circumstances:

• With service providers or contractors who assist us in operating the Services (e.g., hosting, analytics, or support tools), under strict confidentiality agreements and in compliance with the DPA.
• When required by law, court order, or government authority (including regulatory bodies such as the National Privacy Commission or Bangko Sentral ng Pilipinas).
• To protect the rights, property, or safety of the Company, our users, or the public.
• In the event of a merger, acquisition, or sale of assets, with appropriate safeguards.

Blockchain transactions you initiate are processed on public networks and are not controlled or shared by us.

5. Data Security

We implement reasonable and appropriate organizational, physical, and technical security measures to protect any personal data we hold from unauthorized access, disclosure, alteration, or destruction, in line with the DPA.

However, no system is completely secure. Because the Wallet is non-custodial, the security of your private keys, seed phrases, and Digital Assets is entirely your responsibility. We strongly recommend that you back up your recovery phrase securely and never share it.

6. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights (subject to certain exceptions and conditions):

• Right to be informed about the processing of your personal data.
• Right to access your personal data.
• Right to object to processing or withdraw consent.
• Right to correct inaccurate or incomplete data.
• Right to erasure or blocking of data.
• Right to data portability (where applicable).
• Right to file a complaint with the National Privacy Commission.

To exercise these rights, contact us using the details below. We will respond within the timeframe required by law.

7. Data Retention

We retain personal data only for as long as necessary to fulfill the purposes for which it was collected or as required by law. Once no longer needed, we will securely dispose of or anonymize the data.

8. International Transfers

If any data is transferred outside the Philippines, we will ensure appropriate safeguards are in place to protect it in accordance with the DPA.

9. Children's Privacy

The Services are not directed at individuals under 18 years of age. We do not knowingly collect personal data from children.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The revised version will be posted with a new "Last Updated" date. Your continued use of the Services after changes constitutes your acceptance of the updated policy.

11. Contact Us

For any questions, concerns, or to exercise your data privacy rights, please contact our Data Protection Officer at:

You may also reach us through the support channels available in the Palit Wallet app.

support@palitwallet.com

Acknowledgment

By using Palit Wallet, you acknowledge that you have read and understood this Privacy Policy.