Privacy Policy

1. Introduction

This Privacy Policy explains how the Company collects, uses, stores, and protects information when you use the Wallet and related services. The Wallet is designed as a non-custodial solution, meaning users retain full control of their private keys and digital assets.

2. Data Controller

KIML View Ltd, registered in the British Virgin Islands, is the data controller responsible for processing personal data under this Privacy Policy.

Registration Details:

Company Registration Number: 1979665

Registered Address: Intershore Chambers, Road Town, Tortola, British Virgin Islands, VG1110

3. Information We Collect

The Wallet is designed to minimize data collection. We may collect:

• Technical information: IP address, device type, operating system, browser type, and usage logs.
• Optional information: If you contact us, we may collect your name, email address, and message content.
• Wallet activity: Transaction history visible on public blockchains (not collected or stored by us, but publicly available).
• No seed phrases or private keys: The Wallet does not store, transmit, or access your seed phrase or private keys. You are solely responsible for securing your seed phrase.

What We Do NOT Collect:

• Private keys or seed phrases
• Passwords
• Personal identification documents (unless required by law)
• Financial information beyond what is publicly visible on blockchain networks

4. Purpose of Processing

We process data for the following purposes:

• To operate and improve the Wallet
• To ensure security and prevent misuse
• To comply with applicable legal and regulatory obligations
• To respond to user inquiries and support requests
• To conduct analytics and improve user experience
• To detect and prevent fraud, security incidents, and technical issues

5. Legal Basis for Processing

For users in jurisdictions with data protection laws (including the European Union and United Kingdom), processing is based on:

• Consent: When you voluntarily provide information
• Legitimate interest: For security, analytics, and service improvement
• Legal obligation: When required by law or regulation
• Contractual necessity: To provide the Wallet services you have requested

6. Data Sharing

We do not sell or rent personal data. Data may be shared with:

• Service providers: Third-party hosting, analytics, security, or customer support partners who process data on our behalf under strict confidentiality obligations
• Blockchain networks: Transaction data you submit is broadcast to public blockchain networks and becomes permanently visible
• Regulators or law enforcement: If required by applicable law, court order, or regulatory investigation
• Business transfers: In connection with a merger, acquisition, or sale of assets (with notice to affected users)

All third-party service providers are contractually obligated to protect your data and use it only for specified purposes.

7. International Transfers

As a company registered in the British Virgin Islands, we may transfer data internationally. When transferring data to jurisdictions with data protection laws (such as the EU/UK), appropriate safeguards will be applied to protect your information, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions by relevant data protection authorities
• Other lawful transfer mechanisms under applicable data protection laws

8. Data Retention

• Technical logs: Retained for up to 12 months for security and troubleshooting purposes
• Support communications: Retained as long as necessary to resolve the inquiry, plus an additional period for legal compliance
• Analytics data: Anonymized after 12 months
• Data deletion: Data is deleted or anonymized once retention is no longer required by law or legitimate business purpose

You may request earlier deletion of your personal data by contacting us at support@kimlwallet.com.

9. Security Measures

We implement technical and organizational measures to protect data, including:

• Encryption of data in transit and at rest
• Access controls and role-based permissions
• Regular security audits and penetration testing
• Incident response procedures
• Employee training on data protection

User Responsibility: As a non-custodial wallet, you are solely responsible for:

• Securely storing your seed phrase and private keys
• Protecting your device from malware and unauthorized access
• Using strong passwords and two-factor authentication where available

We cannot recover lost seed phrases or access your funds.

10. User Rights

Depending on your jurisdiction, you may have the right to:

• Access your personal data and obtain a copy
• Rectify inaccurate or incomplete personal data
• Erase your personal data ("right to be forgotten") under certain conditions
• Restrict or object to processing
• Data portability: Receive your data in a structured, commonly used format
• Withdraw consent at any time (without affecting prior lawful processing)
• Lodge a complaint with a supervisory authority (where applicable)

For EU/UK Users:

You may lodge a complaint with:

• UK: Information Commissioner's Office (ICO) – ico.org.uk
• EU: Your local data protection authority

To exercise these rights, contact us at: support@kimlwallet.com

We will respond to your request within one (1) month, or inform you if additional time is needed.

11. Children's Privacy

The Wallet is intended for users who are at least the age of majority in their jurisdiction (typically 18 years old, or 13-16 years in some jurisdictions with parental consent).

We do not knowingly collect personal data from minors without proper consent. If we become aware that we have collected data from a minor without proper authorization, we will take steps to delete such information promptly.

If you believe a minor has provided us with personal data, please contact us at support@kimlwallet.com.

12. Cookies and Tracking Technologies

The Site may use cookies and similar tracking technologies for:

• Essential cookies: Required for the Site to function
• Analytics cookies: To understand how users interact with the Wallet
• Preference cookies: To remember your settings

You may disable cookies through your browser settings, but this may affect Site functionality.

Third-Party Analytics: We may use services such as Google Analytics. These services have their own privacy policies governing data use.

13. Third-Party Links and Services

The Wallet may contain links to third-party websites, decentralized applications (dApps), or services. This Privacy Policy does not apply to third-party sites. We are not responsible for the privacy practices of third parties.

We encourage you to review the privacy policies of any third-party services you access through the Wallet.

14. Amendments

The Company may update this Privacy Policy from time to time to reflect:

• Changes in applicable law or regulation
• Updates to our data processing practices
• New features or services

Notice of Changes: Users will be notified of material changes via:

• A notice on the Site
• Email notification (if you have provided an email address)
• In-app notification

Effective Date of Changes: Changes become effective upon posting unless otherwise stated.

Continued Use: Continued use of the Wallet after changes constitutes acceptance of the updated Privacy Policy. If you do not agree to changes, you should discontinue use of the Wallet.

15. Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of the British Virgin Islands. Any disputes arising from this Privacy Policy shall be subject to the jurisdiction of the courts of the British Virgin Islands.

For users in the EU, nothing in this section affects your rights under the General Data Protection Regulation (GDPR). For users in the UK, nothing in this section affects your rights under UK data protection laws.

16. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or your personal data, please contact:

KIML View Ltd

Email: support@kimlwallet.com

Website: kimlwallet.com

Registered Address: Intershore Chambers, Road Town, Tortola, British Virgin Islands, VG1110

Company Registration Number: 1979665

Response Time: We will respond to inquiries within ten (10) business days.