ELLIPAL Privacy Policy

Last Updated: November 3, 2026

Introduction

ELLIPAL Limited (“ELLIPAL,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, share, retain, and protect personal information when you interact with our products and services.

This policy applies to:

  • Our website at ellipal.com.
  • The ELLIPAL App for iOS and Android.
  • Our hardware wallets and related services.
  • Purchases, customer support, subscriptions, and other communications with us.

ELLIPAL provides non-custodial wallet services. We do not take custody of your crypto assets or have access to your private keys or Seed Phrase. You remain responsible for protecting your wallet credentials and recovery information.

Data Controller and Contact Information

The data controller responsible for the personal information described in this policy is ELLIPAL Limited.

For privacy questions or requests concerning your personal information, email cs@ellipal.com or visit our Contact Us page.

1. Information We Collect

We collect information relevant to providing, supporting, improving, and protecting our services. The information involved depends on how you interact with us.

1.1 Information You Provide

Customer and purchase information

When you create a customer record, place an order, or request a service, we may collect your name, email address, telephone number, shipping and billing addresses, order details, and payment-related information.

We use this information to process your request, arrange delivery, maintain necessary transaction records, and provide assistance. If you choose not to provide information needed for a particular service, we may be unable to complete that request.

Customer support information

When you contact us, we collect the information needed to understand and respond to your request. This may include your contact details, order reference, correspondence, device information, and any relevant photographs or videos you provide.

Subscriptions and communication preferences

If you subscribe to our communications, we collect the contact information and preferences needed to send the content you have requested.

Feedback, surveys, and reviews

If you choose to provide feedback, complete a survey, or submit a review, we collect the information you share, including your comments and ratings.

1.2 Information Collected Through Our Website and App

Depending on the features you use and your privacy choices, we may collect:

  • Device type, model, operating system, language settings, and IP address.
  • Browser type and version.
  • Pages viewed, searches, clicks, referring pages, navigation paths, and visit timestamps.
  • App version, feature interactions, session information, crash reports, error logs, and performance data.
  • Connected hardware-wallet information, such as device model, firmware version, and identifiers needed for compatibility or support.
  • Device or advertising identifiers where permitted by applicable law.

Technical identifiers and usage information may constitute personal information when they identify you or can reasonably be linked to you.

1.3 Public Blockchain Information

The ELLIPAL App uses publicly available blockchain information to display wallet addresses, transaction history, and balances.

Public blockchain information may constitute personal information when combined with other information that identifies you. Where applicable, we process it in accordance with this policy and relevant privacy laws.

1.4 Information from Other Sources

When you use integrated services, such as cryptocurrency purchases, exchanges, or staking, the relevant provider may share limited information with us. This may include transaction status, confirmations, service usage information, or error reports.

We may also receive information from analytics and marketing providers to understand how people discover and use our services.

1.5 Cookies and Similar Technologies

Our website uses cookies and similar technologies for the following purposes:

  • Essential functionality: operating the website and supporting requested features.
  • Preferences: remembering your choices and settings.
  • Analytics and performance: understanding website use and improving reliability.
  • Advertising: measuring campaigns and supporting relevant advertising where permitted.

Where required by law, we obtain consent before using non-essential cookies or similar technologies. You can manage your choices through the available privacy controls or your browser settings.

Restricting certain cookies may affect website functionality. Third-party providers may also process information under their own privacy policies.

2. How We Use Your Information

2.1 Providing Products and Services

We use information to:

  • Process purchases and payments.
  • Arrange shipping and delivery.
  • Provide wallet and App functionality.
  • Display public blockchain information.
  • Handle refunds, replacements, and warranty requests.
  • Respond to questions and provide customer support.
  • Send necessary order, service, or security communications.

2.2 Security and Fraud Prevention

We use information to protect our services, investigate suspicious activity, detect fraud or unauthorized access, and respond to security incidents.

We may also process information to meet applicable legal and regulatory requirements.

2.3 Improving Our Services

We use relevant information to understand how our services are used, diagnose errors, improve performance, test compatibility, and develop or improve products and features.

2.4 Communications and Marketing

Where permitted, we use contact information and preferences to send newsletters, product updates, promotional messages, and requests for feedback.

You can unsubscribe from marketing emails using the unsubscribe option in the email or by contacting us. Necessary communications about an existing order or service request may still be sent.

2.5 Legal and Administrative Purposes

We may use information to:

  • Meet accounting, tax, regulatory, and other legal obligations.
  • Respond to valid legal requests.
  • Resolve disputes and enforce agreements.
  • Establish, exercise, or defend legal claims.
  • Protect the rights and safety of ELLIPAL, our customers, and others.

2.6 Legal Bases for Processing

Where the GDPR or similar laws apply, we rely on an appropriate legal basis for each processing purpose. These may include:

  • Performing a contract with you.
  • Complying with a legal obligation.
  • Your consent, where required.
  • Legitimate interests, such as securing and improving our services, where those interests are not overridden by your rights.

Where processing relies on consent, you may withdraw it. Withdrawal does not affect processing that was lawful before consent was withdrawn.

2.7 Anonymous and Aggregated Information

We may use aggregated or anonymized information for analysis, research, reporting, and service improvement.

Information is treated as anonymous only when it can no longer reasonably be used to identify an individual. Removing a name or other direct identifier does not necessarily make information anonymous.

3. How We Share Your Information

We do not sell or rent your personal information to third parties.

We may share information in the circumstances described below.

3.1 Service Providers

We use service providers to support:

  • E-commerce, order management, and payment processing.
  • Shipping, delivery, and logistics.
  • Order protection and related claims.
  • Cloud hosting and website operation.
  • Customer support.
  • Email delivery and communications.
  • Analytics and performance monitoring.
  • Security and fraud prevention.
  • Marketing and campaign measurement.

Our online store operates on Shopify and uses integrated applications to support relevant store functions.

Depending on their role, providers may receive the customer, order, contact, or delivery information necessary to perform their services. Where they process information on our behalf, we require appropriate confidentiality, security, purpose limitations, and retention arrangements.

We remain responsible for the obligations that applicable law places on us when engaging providers to process personal information on our behalf.

3.2 Independently Operated Services

Some services available through our website or App are operated independently. These may include payment, order-protection, cryptocurrency purchase, exchange, staking, and other services you choose to use.

Such providers may collect information directly from you or receive information necessary to provide the selected service. They may also have their own legal, regulatory, and record-keeping obligations.

Their processing is governed by their applicable privacy policies. Please review those policies before using their services.

3.3 Legal Requirements and Protection

We may disclose information where required or permitted by law, including to:

  • Respond to valid legal processes or regulatory requests.
  • Meet legal obligations.
  • Investigate fraud or security incidents.
  • Establish, exercise, or defend legal claims.
  • Protect rights, property, or personal safety.

3.4 Affiliates

We may share information with ELLIPAL affiliates where necessary for the purposes described in this policy, subject to appropriate safeguards and applicable legal requirements.

3.5 Anonymous Information

We may share aggregated or anonymized information that does not identify individuals, for example to report usage trends or improve services.

4. International Data Transfers

Our operations and service providers may involve processing information outside your country of residence. Privacy laws in those locations may differ from those where you live.

We use appropriate safeguards for international processing, including security measures and contractual requirements where applicable. When the law requires specific transfer conditions or safeguards, those requirements apply.

For questions about international processing of your information, contact cs@ellipal.com.

5. Data Retention

We keep personal information for the purposes described in this policy and apply the following retention periods to our online-store records:

  • Customer records: personal information is deleted 90 days after the customer record is created.
  • Order records: personal information is deleted 90 days after the order is placed.

Limited information may be retained for longer where necessary to complete an unresolved transaction or service request, handle a return or warranty claim, resolve a dispute, or meet accounting, tax, regulatory, or other legal obligations.

Information retained for these purposes is kept only for the relevant need or required period. When it is no longer needed, it is deleted or anonymized as appropriate.

Other information is retained only for as long as necessary for its stated purpose, taking account of service needs, your communication preferences, and applicable legal requirements. Genuinely anonymized information may be retained for analysis and research.

We require providers processing information on our behalf to follow appropriate retention requirements. Independent providers are responsible for their own retention practices and legal obligations.

These retention practices do not shorten your warranty or affect your statutory consumer rights.

6. Data Security

6.1 Technical and Organizational Measures

We use technical and organizational measures intended to protect personal information. These include access restrictions, confidentiality requirements, encryption where appropriate, and procedures for handling information securely.

Access is limited according to business and service needs. We take reasonable steps to assess providers that process information on our behalf.

If a personal data incident occurs, we will investigate and take appropriate remedial action, including any notifications required by applicable law.

6.2 Hardware Wallets and the ELLIPAL App

Wallet credentials are separate from the personal information used to operate our website and customer services.

ELLIPAL Titan-series hardware wallets use an air-gapped architecture with QR Code Signing. ELLIPAL X Card uses NFC communication and has no independent internet connection.

Private keys are generated and stored within the applicable hardware wallet and are not transmitted to ELLIPAL during signing. Hardware-wallet signing does not give ELLIPAL access to your private keys or Seed Phrase.

The ELLIPAL App may process the device, usage, and public blockchain information described in this policy.

6.3 Protecting Your Wallet Credentials

You are responsible for keeping your Seed Phrase, private keys, wallet passwords, PIN, and Passphrase secure.

ELLIPAL will never ask you to disclose your Seed Phrase, private keys, PIN, or Passphrase through email, telephone, customer-support messages, or other communications.

Do not include these details in forms, support tickets, photographs, or videos. We do not need them to process a refund, replacement, or warranty request.

We cannot recover your assets if you lose the recovery information required to access your wallet.

6.4 Recognizing Suspicious Communications

We do not send unsolicited replacement devices without a customer request or an agreed support resolution.

If you receive an unexpected device or a message asking you to disclose wallet credentials, do not follow the instructions. Visit ellipal.com directly and contact us to verify the request.

6.5 Security Limitations and Responsibilities

No system can guarantee complete protection against every threat. We take reasonable measures to protect information, but we cannot guarantee absolute security.

Independent services operate their own systems and are responsible for their own data practices. Our use of providers does not remove any responsibility imposed on ELLIPAL by applicable law.

To the extent permitted by law, we are not responsible for losses caused by events outside our reasonable control, independent third parties not acting on our behalf, or a user’s failure to safeguard wallet credentials.

Nothing in this policy excludes liability that cannot lawfully be excluded, including our obligations as a data controller.

If you suspect an information-security issue involving our services, contact cs@ellipal.com.

7. Your Privacy Rights

Depending on your location and applicable law, you may have the right to:

  • Request access to personal information we hold about you.
  • Request correction of inaccurate or incomplete information.
  • Request deletion, subject to applicable exceptions.
  • Restrict or object to certain processing.
  • Receive eligible information in a portable format.
  • Withdraw consent where processing relies on consent.
  • Opt out of a sale or sharing of personal information, or targeted advertising, where those rights apply.
  • Complain to the relevant data-protection authority.

To submit a request, email cs@ellipal.com.

We may need to verify your identity before providing information or acting on a request. We will respond within the period required by applicable law.

If we cannot fulfill a request in full, we will explain the relevant reason. We will not discriminate against you for exercising your privacy rights.

For residents of the European Economic Area or United Kingdom, you may contact your local data-protection authority if you believe your information has been handled improperly.

For California residents, applicable rights may include knowing the categories and purposes of information collected, accessing, correcting, or deleting information, and opting out of sale or sharing as defined by California law.

8. Information About Minors

If you are under 18, your use of our services must be authorized by a parent or legal guardian where permitted by applicable law.

We handle information relating to minors in accordance with applicable requirements. If we learn that personal information was collected without required authorization, we will take appropriate action, including deletion where required.

A parent or guardian with a concern about a minor’s information can contact cs@ellipal.com.

9. External Websites and Additional Privacy Notices

Our website and App may provide access to external websites, dApps, and independently operated services.

Their content, services, and privacy practices are governed by their own terms. Review their notices before providing information or using their services.

Some ELLIPAL services may provide additional privacy notices explaining specific processing. Those notices should be read together with this policy and will identify any service-specific arrangements.

10. Changes to This Policy

We may update this policy to reflect changes in our services, data practices, or legal requirements.

The updated version will be published on our website, and the “Last Updated” date will be revised. Where required, we will provide additional notice or request consent for material changes.

Contact Us

For questions about this policy, our data practices, or your privacy rights, contact:

ELLIPAL Limited
Email: cs@ellipal.com
Website: ellipal.com
Contact page: Contact Us