Privacy Notice

Last updated: March 1, 2026 | Effective date: March 1, 2026

This Privacy Notice ("Notice") describes how DApps Platform Software Services Ltd. ("Trust Wallet", "we", "us", "our") collects, uses, shares, and protects information in connection with the Trust Wallet Card service ("Service"). We are committed to safeguarding your privacy and ensuring transparency in how we handle your data.

1. Our Privacy Commitment

Trust Wallet is built on the principle of self-custody and user sovereignty. We minimize data collection and never access, control, or store your private keys, seed phrases, or wallet balances. Your cryptocurrency assets remain entirely under your control at all times.

2. Information We Collect

2.1 Information You Provide

Data Category	Examples	Purpose
Contact information	Email address, phone number	Waitlist registration, account communications, SMS verification
Wallet address	TRON public wallet address	Card linking, transaction processing
Card preferences	Card type selection, notification settings	Service personalization

2.2 Information Collected Automatically

Data Category	Examples	Purpose
Device information	Device type, operating system, browser type	Service compatibility, security
Usage data	Pages visited, features used, session duration	Service improvement, analytics
Transaction metadata	Transaction timestamps, amounts, merchant categories	Transaction processing, fraud detection
Network data	IP address, approximate location (country-level)	Security, regulatory compliance

2.3 Information We Do NOT Collect

Private keys or seed phrases
Full wallet balances or portfolio data
Biometric data
Social security or national ID numbers
Precise geolocation data

3. How We Use Your Information

We use collected information for the following purposes:

Service delivery: Processing card applications, enabling transactions, managing your Card account;
Communications: Sending waitlist updates, transaction notifications, security alerts, and service announcements;
Security and fraud prevention: Detecting and preventing unauthorized access, fraudulent transactions, and abuse;
Compliance: Meeting legal, regulatory, and Visa network obligations;
Improvement: Analyzing aggregated usage patterns to improve the Service (no individual profiling);
Support: Responding to your inquiries and resolving issues.

4. Legal Basis for Processing (GDPR)

For users in the European Economic Area (EEA), United Kingdom, and similar jurisdictions, we process personal data based on:

Contract performance: Data necessary to provide the Service you've requested;
Legitimate interests: Security, fraud prevention, and service improvement;
Legal obligations: Compliance with financial regulations and law enforcement requests;
Consent: Marketing communications (you may opt out at any time).

5. Data Sharing

We do not sell your personal information. We may share limited data with:

5.1 Service Partners

Visa International: Transaction data required for payment processing and network compliance;
Card issuing bank: Information required for card issuance and regulatory compliance;
Payment processors: Transaction data necessary for fiat settlement.

5.2 Service Providers

Cloud hosting providers (data stored in encrypted form);
Email and SMS delivery services (contact information only);
Analytics providers (aggregated, non-identifiable data only).

5.3 Legal Requirements

We may disclose information when required by law, court order, or government regulation, or when necessary to protect our rights, safety, or property.

6. Data Security

We implement industry-standard security measures to protect your data:

AES-256 encryption for data at rest;
TLS 1.3 encryption for data in transit;
Multi-factor authentication for internal access;
Regular security audits and penetration testing;
Strict access controls on a need-to-know basis;
Secure data centers with SOC 2 Type II certification.

7. Data Retention

Account data: Retained for the duration of your Card account plus 5 years (regulatory requirement);
Transaction records: Retained for 7 years (financial record-keeping obligations);
Usage analytics: Aggregated data retained indefinitely; individual session data deleted after 90 days;
Support communications: Retained for 3 years after resolution;
Marketing preferences: Retained until you opt out or close your account.

8. Your Rights

Depending on your jurisdiction, you may have the following rights:

Access: Request a copy of personal data we hold about you;
Rectification: Request correction of inaccurate data;
Erasure: Request deletion of your personal data (subject to legal retention requirements);
Restriction: Request limited processing of your data;
Portability: Receive your data in a structured, machine-readable format;
Objection: Object to processing based on legitimate interests;
Withdraw consent: Withdraw previously given consent at any time.

To exercise any of these rights, contact us at [email protected]. We will respond within 30 days.

9. Cookies and Tracking

Our website uses minimal cookies:

Essential cookies: Required for site functionality (session management, language preferences);
Analytics cookies: Aggregated usage statistics to improve our service (no personal identification).

We do not use advertising cookies or third-party tracking pixels. You may disable cookies in your browser settings, though some features may not function properly.

10. International Data Transfers

Your data may be processed in countries outside your residence, including the United Arab Emirates and the European Union. Where data is transferred internationally, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission, or equivalent protections.

11. Children's Privacy

The Service is not intended for individuals under 18 years of age. We do not knowingly collect personal information from minors. If we become aware that we have collected data from a minor, we will delete it promptly.

12. Changes to This Notice

We may update this Privacy Notice from time to time. Material changes will be communicated via email or in-app notification at least 30 days before taking effect. The "Last updated" date at the top of this page reflects the most recent revision.

13. Contact Us

For privacy-related questions, data requests, or concerns:

Privacy team: [email protected]
General support: [email protected]
Support portal: support.trustwallet.com
Data Protection Officer: [email protected]

Postal address: DApps Platform Software Services Ltd., Office A, RAK DAO Business Center, Ground Floor, Al Rifaa, Ras Al Khaimah, United Arab Emirates