Privacy Policy

1. About VaultX and This Policy

VaultX ("we," "us," or "our") is a non-custodial, multi-chain cryptocurrency wallet operated by Emirates Ltda, a company incorporated under the laws of Brazil.

This Privacy Policy explains how we collect, use, disclose, and protect information about users ("you") of the VaultX application available at myvaultx.app and any related services (collectively, the "Service").

By accessing or using VaultX, you acknowledge that you have read and understood this Privacy Policy. If you do not agree, please discontinue use of the Service.

2. Information We Collect

2.1 Information You Do Not Provide — By Design

VaultX is designed with privacy at its core. We do not collect or store:

• Private keys or seed phrases — these are generated and stored exclusively on your device
• Your name, email address, or identification documents (unless required by an integrated third-party service)
• Your wallet balances or transaction history beyond what is publicly visible on the blockchain

2.2 Information We Collect Automatically

2.3 Information from Third-Party Integrations

When you use third-party services integrated into VaultX (such as Transak, MoonPay, or Ramp Network for fiat on-ramp purchases), those services may collect additional personal information subject to their own privacy policies. VaultX does not receive or store sensitive financial or identity data from these providers.

3. How We Use Your Information

We use the limited information we collect to:

• Operate, maintain, and improve the VaultX application
• Monitor and analyze usage patterns to enhance user experience
• Detect, prevent, and respond to fraud, abuse, and security incidents
• Comply with applicable laws and regulations
• Respond to user inquiries and provide support

We do not use your information for targeted advertising, profiling, or sale to third parties.

4. Third-Party Services

VaultX integrates with the following third-party services. Each has its own privacy policy and data practices:

When you initiate a fiat purchase through an on-ramp provider, you will be subject to their KYC/AML requirements and privacy practices. VaultX has no control over and is not responsible for the privacy practices of these third parties.

5. Data Sharing and Disclosure

We do not sell, rent, or trade your personal information. We may share limited information in the following circumstances:

• Service providers: We may share anonymized technical data with infrastructure providers (such as Vercel for hosting) strictly for operational purposes.
• Legal requirements: We may disclose information if required by law, court order, or governmental authority.
• Safety: We may disclose information to protect the rights, property, or safety of VaultX, our users, or the public.
• Business transfers: In the event of a merger, acquisition, or sale of assets, user information may be transferred as part of the transaction, subject to the same privacy protections.

6. Data Security

We implement industry-standard technical and organizational measures to protect the information we collect, including:

• TLS/HTTPS encryption for all data in transit
• Secure server infrastructure hosted on Vercel with SOC 2 compliance
• Regular security reviews and vulnerability assessments
• Strict access controls limiting data access to authorized personnel only

Because VaultX is non-custodial, your private keys and seed phrases never leave your device and are never transmitted to our servers. The security of your wallet ultimately depends on how you safeguard your seed phrase.

7. Data Retention

We retain automatically collected data for the periods specified in Section 2.2. Anonymized, aggregated analytics data may be retained longer for product improvement purposes. We do not retain personal data beyond what is necessary to fulfill the purposes described in this policy, unless required by law.

8. Your Rights

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

• Access: Request a copy of the personal data we hold about you
• Correction: Request correction of inaccurate or incomplete data
• Deletion: Request deletion of your personal data ("right to be forgotten")
• Portability: Request transfer of your data in a machine-readable format
• Objection: Object to processing of your data for certain purposes
• Restriction: Request restriction of processing in certain circumstances

To exercise any of these rights, contact us at contact@myvaultx.app. We will respond within 30 days.

9. LGPD — Brazilian Users

For users based in Brazil, this section applies in accordance with the Lei Geral de Proteção de Dados (LGPD — Law No. 13.709/2018).

Legal Bases for Processing

• Legitimate interest (Art. 7, IX): for security monitoring, fraud prevention, and service improvement
• Contract performance (Art. 7, V): to provide the wallet services you requested
• Legal obligation (Art. 7, II): when required by Brazilian law or regulatory authorities

Data Protection Officer (DPO)

Our designated Data Protection Officer for LGPD purposes can be reached at contact@myvaultx.app.

You may file a complaint with the Autoridade Nacional de Proteção de Dados (ANPD) at gov.br/anpd.

10. GDPR — European Users

For users in the European Economic Area (EEA) or United Kingdom, this section applies in accordance with the General Data Protection Regulation (GDPR) and UK GDPR.

Legal Bases for Processing

• Legitimate interests (Art. 6(1)(f)): for security monitoring, fraud prevention, and improving our services
• Contract performance (Art. 6(1)(b)): to provide the services you requested
• Legal obligation (Art. 6(1)(c)): when required by EU or member state law

International Data Transfers

VaultX is operated from Brazil. When data is transferred outside the EEA, we ensure appropriate safeguards are in place, including standard contractual clauses approved by the European Commission.

Supervisory Authority

You have the right to lodge a complaint with your local data protection supervisory authority. A list of EU supervisory authorities is available at edpb.europa.eu.

11. Cookies and Tracking

VaultX uses minimal cookies and local storage to:

• Maintain your language and display preferences
• Keep your session active during use
• Store encrypted wallet data locally on your device (never transmitted to our servers)

We do not use advertising cookies, tracking pixels, or third-party analytics that profile your behavior across other websites. You may clear cookies and local storage at any time through your browser settings, though this may affect functionality.

12. Children's Privacy

VaultX is not directed at or intended for individuals under the age of 18. We do not knowingly collect personal information from minors. If you believe a minor has provided us with personal information, please contact us immediately at contact@myvaultx.app and we will take steps to delete such information.

13. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will update the "Last updated" date at the top of this page. We encourage you to review this policy periodically.

Continued use of VaultX after changes are posted constitutes your acceptance of the revised policy.

14. Contact Us