Doma Wallet Privacy Policy

We collect only the personal data necessary to provide, maintain, secure, and improve the Services, in accordance with applicable data protection laws and the principle of data minimisation.

Certain information is generated and stored exclusively on your device and is not transmitted to or accessible by us. This includes your private keys, seed phrases, passkeys, and other private wallet credentials. We do not collect, store, or have access to this information.

We may collect limited technical information relating to your device and your use of the Services. This may include device model, operating system, application version, device type, browser type, language preferences, feature usage, session activity, error logs, crash reports, and similar technical or operational data. This information may constitute personal data where it relates to an identified or identifiable individual. We process it to ensure proper functionality of the Services, improve performance, troubleshoot issues, maintain compatibility, and enhance security.

Blockchain transactions are publicly available and transparent by design. When you use the Services, we may access publicly available blockchain data associated with wallet addresses used with the Services. This may include wallet addresses, transaction history, transaction hashes, timestamps, transaction amounts, token or asset identifiers, approvals, and other on-chain activity.

We may process wallet addresses and associated blockchain data for operational, security, and compliance purposes, including displaying wallet activity, generating transaction records or exports, transaction monitoring, wallet screening, and the detection or prevention of fraud, sanctions breaches, or other unlawful activity. This data is obtained from publicly available blockchain records and related infrastructure services.

If you contact us for support or other inquiries, we will collect the information you provide, including the content of your communications and any relevant technical or account-related information necessary to assist you.

We may collect analytics data, including usage statistics, error logs, crash reports, and service-performance data, in order to improve the performance, reliability, and security of the Services. We do not intentionally use this data to identify individual users.

If you use optional features made available through the Wallet, we may process additional data necessary to provide those features. Depending on the feature used, this may include transaction-history export data, signed transaction instructions, signed off-chain messages, token approval information, relayer or routing data, wallet-linked handles, encrypted message ciphertext, delivery metadata, and other technical data required to enable the relevant functionality.

If you use encrypted peer-to-peer messaging functionality within the Wallet, we may process wallet-linked handles, encrypted message ciphertext, routing information, and delivery status data in order to provide that feature. We do not possess the decryption keys for end-to-end encrypted message content and cannot access readable message content.

If you interact with us through social media platforms, any personal data shared is also subject to the privacy policies of those platforms.

We do not collect or store: private keys, seed phrases, passkeys, or other private wallet credentials; any private authentication credentials stored only on your device; or personal contact details such as email addresses, unless voluntarily provided by you, for example when contacting customer support.

Certain technical and usage data is required to operate the Services. If you do not provide or permit the collection of such data, some features of the Services may not function properly or may be unavailable.

We may obtain personal data directly from you (for example, when you contact support or use optional features); automatically from your device when you use the Services; from publicly available blockchain records and related infrastructure services; and from third-party services or integrations that you choose to use through the Wallet.

Personal data may be disclosed to, or processed by, the following categories of recipients, where relevant to the provision of the Services: service providers supporting hosting, analytics, technical infrastructure, communications, security, and service delivery; third-party services or integrations that you choose to use through the Wallet, including decentralised applications, WalletConnect-connected services, on-ramp or off-ramp providers, swap providers, staking protocols, NFT marketplace providers, tax preparation vendors, relayer services, and other transaction or infrastructure providers; and competent authorities, regulators, courts, law enforcement bodies, or other persons where required or permitted by applicable law.

We process personal data only for lawful purposes that are directly related to the operation of the Services and are necessary for those purposes.

We may use personal data to: provide, operate, maintain, and support the Wallet and related Services; enable core wallet functionality, including wallet creation, wallet access, transaction display, transaction broadcasting, address management, and optional passkey or device-based authentication features; compile, display, and export transaction history derived from publicly available blockchain records; facilitate optional user-initiated features and integrations, including on-ramp and off-ramp services, token swaps, cross-chain functionality, staking integrations, NFT marketplace connectivity, WalletConnect or other decentralised application connectivity, hardware wallet support, gas-less transaction functionality, encrypted peer-to-peer messaging, and tax reporting exports; transmit technical requests, signed transaction instructions, signed off-chain messages, and related metadata to relevant blockchain networks, relayers, infrastructure providers, or integrated third-party services at your direction; monitor, detect, prevent, and investigate fraud, sanctions issues, unlawful activity, security incidents, abuse and misuse of the Services; carry out wallet address screening, transaction monitoring, and other compliance or risk-management checks using publicly available blockchain data and other relevant information; provide customer support, respond to inquiries, and troubleshoot operational or technical issues; enforce our Terms of Use and other applicable terms, disclosures, or feature-specific conditions; comply with legal, regulatory, judicial, law enforcement, and compliance obligations; and improve the performance, reliability, usability, and security of the Services and develop, test, and maintain new or existing features.

We do not process personal data for purposes that are incompatible with the purposes described in this Privacy Policy.

We process personal data in accordance with the Virgin Islands Data Protection Act, 2021 (as revised).

Where required, we rely on your consent to process personal data. By using the Services, and by choosing to use specific optional features or integrations, you consent to the processing described in this Privacy Policy.

We may also process personal data without consent where such processing is necessary: for the performance of a contract to which you are a party; to take steps at your request prior to entering into a contract; to comply with a legal obligation to which we are subject; to protect your vital interests; or for the administration of justice or the exercise of functions conferred by law or regulation.

We use device, technical, and usage information to ensure that the Services function correctly, to diagnose and resolve bugs and service interruptions, to maintain compatibility across supported devices and networks, and to improve user experience and platform security. This may include processing application version, device type, operating system, language settings, feature usage, session activity, error logs, crash reports, and similar operational data.

IP addresses and similar network identifiers may be processed transiently for communications routing, service delivery, fraud prevention, security, sanctions compliance, and regulatory compliance purposes and are not retained for longer than necessary for those purposes.

We process publicly available blockchain data associated with wallet addresses to display transaction history and to support security measures, including transaction monitoring and the detection of potentially unlawful or suspicious activity. Such data is obtained from publicly accessible sources and is not collected directly from you.

We use this information to display wallet activity, support transaction-related features, generate transaction exports, facilitate optional integrations, perform wallet screening and transaction monitoring, investigate suspicious or unlawful activity, and support compliance and security functions.

Such information is obtained from publicly accessible blockchain records and related infrastructure services and is not collected from your private wallet credentials.

Where you choose to use optional third-party features or integrations made available through the Wallet, we may process and transmit relevant data necessary to enable those features. Depending on the feature used, this may include wallet address information, publicly visible transaction history, transaction instructions, signed messages, token approval information, routing data, technical metadata, and other information necessary to connect with or facilitate the requested feature.

Examples include: On-ramp, off-ramp, and swap services — enabling your connection to independent service providers and transmitting required transaction or integration data at your direction; Staking and NFT features — facilitating access to third-party smart contracts, protocols, or marketplaces; WalletConnect and dApp connectivity — enabling you to connect your wallet to third-party decentralised applications; Hardware wallet integration — facilitating transaction display and confirmation workflows in connection with compatible hardware devices; Tax reporting functionality — compiling publicly available blockchain transaction data and exporting it in a format compatible with supported third-party tax preparation services; Gas-less transactions — transmitting signed off-chain messages, approval-related information, and associated transaction metadata to relayer or infrastructure services so that the requested transaction can be processed.

When you voluntarily send exported data or otherwise interact with a third-party provider, that third party will process data in accordance with its own terms and privacy policy. We do not control the data practices of independent third parties.

If the user makes use of the encrypted peer-to-peer messaging functionality, we may process data necessary to provide that feature, such as wallet-linked handles, message routing information, delivery status data, and encrypted message ciphertext. Encrypted message content stored on our infrastructure is stored solely to facilitate transmission or delivery. We do not possess the decryption keys for end-to-end encrypted content and do not access readable message content.

Where you contact us, we use the information you provide to respond to your inquiries, investigate issues, verify relevant facts, and provide support or assistance in connection with the Services. This may include reviewing communications content, device or technical information you provide, and other information reasonably necessary to address the issue raised.

We may use personal data to verify compliance with our Terms of Use, to investigate suspected misuse of the Services, to protect users and infrastructure, and to comply with sanctions, anti-fraud, anti-money laundering, court order, regulatory, or law enforcement requirements where applicable.

This may include restricting, suspending, or disabling certain Wallet-provided features or interfaces where reasonably necessary for legal, compliance, or security reasons.

We do not use your personal data for direct marketing purposes unless we first obtain any consent required by applicable law. You may at any time require us in writing to cease processing your personal data for direct marketing purposes, and we will comply within the period required by applicable law.

We limit the collection and processing of personal data to what is adequate, relevant, and not excessive in relation to the lawful purposes for which it is processed, in accordance with applicable law.

We do not sell, rent, or trade your Personal Data. We only disclose personal data in the circumstances described below, and only for purposes that are consistent with those for which the data was collected or purposes directly related to them.

We may disclose personal data to third-party service providers who support the operation of the Services, including providers of hosting, infrastructure, analytics, security, communications, and technical services. Such providers process personal data on our behalf and are required to implement appropriate safeguards and use the data only for the purposes of providing services to us.

Where you choose to use third-party features or integrations through the Wallet, you direct us to transmit relevant data necessary to enable those interactions. Depending on the feature used, this may include wallet addresses, publicly available transaction data, transaction instructions, signed messages, or other technical data required to connect with or facilitate the third-party service. These third parties operate independently and process data in accordance with their own terms and privacy policies. We do not control their data practices.

Transactions conducted using blockchain networks are publicly recorded and visible. Information such as wallet addresses, transaction amounts, timestamps, and related data may be accessible to third parties through blockchain explorers and other tools. We do not control the disclosure of such information on public blockchain networks.

We may disclose personal data where required or permitted by applicable law, regulation, court order, or regulatory authority, or where such disclosure is necessary to: comply with legal and regulatory obligations; respond to lawful requests from authorities; prevent or investigate fraud, sanctions breaches, or unlawful activity; protect our rights, property, systems, or users; or enforce our Terms of Use.

In the event of a merger, acquisition, restructuring, or sale of all or part of our business or assets, personal data may be transferred to a successor entity, subject to applicable legal requirements.

We may share aggregated or de-identified data that does not identify any individual.

We implement reasonable technical, organisational, and security measures designed to protect personal data against loss, misuse, unauthorised access, disclosure, alteration, or destruction, taking into account the nature of the data and associated risks. However, no system or method of transmission over the internet is completely secure. You use the Services at your own risk.

As the Wallet is non-custodial, you are solely responsible for safeguarding your private keys, seed phrase, passkeys, and device security. We cannot access, recover, reset, or control your wallet credentials or digital assets.

You should: store your seed phrase securely offline; use appropriate device security controls; keep software up to date; and take precautions against phishing, malware, and unauthorised access.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, including providing the Services, maintaining security, complying with legal obligations, and resolving disputes.

Retention periods are determined based on the nature of the data, the purposes of processing, and applicable legal or regulatory requirements.

Where personal data is no longer required, we will delete or anonymise it. Where immediate deletion is not feasible (for example, due to backups), the data will be securely stored and isolated until deletion is possible.

Due to the nature of blockchain technology, publicly recorded transaction data cannot be modified or deleted. As a result, certain data associated with wallet activity may remain permanently available on public networks, and your ability to exercise certain rights (such as erasure) may be limited in practice.

We use cookies and similar technologies to ensure the proper operation of our website and Services, analyse usage, and improve performance. These may include: essential cookies required for functionality; analytics and performance cookies; and cookies placed by third-party service providers.

You can control cookies through your browser settings, although disabling them may affect functionality.

We may send optional push notifications relating to service updates, alerts, or relevant information. You can manage or disable notifications through your device or application settings.

Where biometric authentication is enabled, biometric data is processed locally on your device using its native security features and is not transmitted to or stored by us.

Subject to applicable law, you may have the right to: request access to your personal data; request correction of inaccurate or incomplete data; request deletion of personal data, where applicable; and withdraw consent where processing is based on consent.

You also have the right to require us, by written notice, to cease processing your personal data for direct marketing purposes, and we will comply within the time required by law.

To exercise your rights, please contact us. We may require verification of your identity before responding to your request.

If you are dissatisfied with our response, you may have the right to lodge a complaint with the Information Commissioner of the Virgin Islands.

If you are located in the European Economic Area, additional rights may apply under applicable law, including rights under the General Data Protection Regulation (GDPR).

We may transfer and process personal data in jurisdictions outside your country of residence, including jurisdictions that may not provide the same level of data protection.

Where required, we take reasonable steps to ensure that appropriate safeguards are in place to protect personal data, including contractual protections and technical security measures.

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or business operations. We will update the “Last Updated” date and, where appropriate, provide notice through the Services. Your continued use of the Services after any update constitutes acceptance of the revised Privacy Policy.

For questions about this Privacy Policy or our privacy practices, contact us at:

Veltis Consumer Technologies Ltd

Email: support@domawallet.ai

Website: https://domawallet.ai

Please review this Privacy Notice regularly to ensure that you are aware of its terms. Your continued use of our Services after an amendment to our Privacy Notice constitutes your acceptance to the amended terms. Thank you for trusting DOMA Wallet. We are committed to protecting your privacy while providing you with a secure, user-friendly interface for managing your digital assets.