Contents
1. Introduction
This Privacy Policy explains how SmartHolder ("we", "us", "our") collects, uses, and protects information when you use our website and card-issuance Service. We are committed to data minimization: because the Service is non-custodial and does not require KYC, we collect only the limited information described below.
2. Information We Collect
Information you provide
- Email address — when you request onboarding/activation instructions for your Card.
- Support communications — messages you send us by email or via Telegram.
Information collected automatically
- Public wallet address and on-chain transaction data associated with your interaction with the Service (this is public blockchain information).
- Technical & usage data — IP address, browser type, device, pages viewed, and timestamps, collected via standard server logs and analytics.
- Cookies and similar technologies — see section 4.
3. How We Use Information
- To issue and activate your Card and send onboarding instructions.
- To operate, maintain, and improve the Service.
- To respond to support requests and communicate with you.
- To detect, prevent, and address fraud, abuse, and security issues.
- To measure marketing performance and comply with legal obligations.
6. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes described in this Policy, to comply with legal obligations, resolve disputes, and enforce our agreements. Public blockchain data is, by its nature, permanent and outside our control.
7. Security
We implement reasonable technical and organizational measures designed to protect information against unauthorized access, loss, or misuse. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
8. Your Rights
Depending on your location, you may have rights to access, correct, delete, or restrict the processing of your personal information, to object to processing, and to data portability. To exercise these rights, contact us using the details below. We may need to verify your request before acting on it.
9. International Transfers
Your information may be processed and stored in countries other than your own. Where we transfer data internationally, we take steps to ensure an appropriate level of protection consistent with applicable law.
10. Children's Privacy
The Service is not directed to individuals under 18, and we do not knowingly collect personal information from minors. If you believe a minor has provided us information, please contact us so we can delete it.
11. Third-Party Links
The Service may contain links to third-party websites and applications (such as wallet apps and Telegram). We are not responsible for the privacy practices of those third parties; please review their policies separately.
12. Changes to This Policy
We may update this Privacy Policy from time to time. The "Last updated" date above reflects the latest revision. Material changes will be indicated by updating this page.
13. Contact
For privacy questions or to exercise your rights, contact us at [email protected] or via our Telegram channel.