ELLIPAL Privacy Policy
Last Updated: August 5, 2026
Introduction
ELLIPAL Limited (hereinafter referred to as "ELLIPAL," "we," "us," or "our") values your privacy and is committed to protecting your personal information. This Privacy Policy ("Policy") explains how we collect, use, store, share, and protect your information across everything we offer, including our hardware wallets, our ELLIPAL Wallet App, and our Website. This single Policy covers all of them together.
This Policy applies to all interactions with our Services, including:
• Our hardware wallets (such as ELLIPAL Titan 2.0, ELLIPAL Titan, ELLIPAL Titan Mini, and ELLIPAL X Card)
• Our mobile applications for iOS and Android (the "ELLIPAL Wallet App," or "App")
Our website at ellipal.com (the "Website")
• Related services and features
Whether you interact with us through the App, the Website, or a hardware wallet, the same privacy commitments in this Policy apply. This Policy applies only to information we collect through our Services, how we use this information, and the circumstances under which we may disclose it to third parties. It does not apply to information we collect from other sources.
IMPORTANT: ELLIPAL provides non-custodial wallet services. We do not store or have access to your crypto assets, private keys, Seed Phrases (recovery phrases), passwords, PIN codes, or Keystore files. You maintain full control and responsibility for securing this information.
By using our Services, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Policy, please do not use our Services.
Data Controller and Contact Information
The data controller responsible for your personal data is ELLIPAL Limited ("ELLIPAL").
If you have any questions about this Privacy Policy or how we handle your data, you can reach us through our Contact Us.
For data protection matters, including exercising your rights under applicable data protection laws (such as the GDPR and CCPA), please contact us at cs@ellipal.com.
1. Information We Collect
We are committed to collecting only the minimum information necessary to provide and improve our Services. We do not collect or store your private keys, Seed Phrases, passwords, PIN codes, or Keystore information.
1.1 Personal Information You Provide Directly
Purchase Information
When you purchase products through our Website, we collect information necessary to process and fulfill your order. This includes personal identification and contact details such as your name and email address, as well as shipping and billing addresses to ensure proper delivery. We also collect payment-related information to maintain accurate records and provide customer service.
Customer Support Information
When you contact our customer support team, we gather the information needed to assist you effectively. This includes your contact information such as your email address, the content of your inquiries and support communications, and your interaction history with our support team. Where necessary for product replacement or account security matters, we may also request device-specific information from you.
Survey and Feedback Information
When you choose to participate in surveys or provide feedback about our products and services, we collect the information you share with us. This may include your opinions, comments, and responses to survey questions, as well as any product reviews and ratings you submit regarding your satisfaction with our Services.
1.2 Information Collected Automatically
Mobile Device Information
When you use our mobile apps or access our Website from a mobile device, we automatically collect technical information about your device and access methods, including device type, model, manufacturer, operating system version (iOS or Android), IP address, language preference, and, for Website visits, browser type and version. Where permitted, we may collect device identifiers, including advertising IDs.
Usage Data from Mobile Applications
To improve our mobile application, we automatically collect app interaction data, including app version, usage patterns, feature interactions, session duration and frequency, crash reports, error logs, and performance metrics. When connecting hardware wallets, we collect device type, model, firmware version, and identifiers to ensure compatibility.
Website Usage Data
When you visit our Website, we automatically collect browsing data, including pages visited, time spent, referring and exit URLs, click behavior, navigation paths, search queries, and visit timestamps. We also gather technical information such as browser type, language preferences, and referring site. For logged-in users or blog commenters, we may collect IP addresses.
Like most website operators, we collect non-personally-identifying information of the sort that web browsers and servers typically make available. Some visitors choose to interact with us in ways that require us to gather personally-identifying information. The amount and type of information we gather depends on the nature of the interaction. For example, we ask visitors who sign up on our Website to provide a username and email address.
Blockchain-Related Information
We collect publicly available blockchain information for display purposes, including wallet addresses (for transaction history display), transaction data (publicly available on the blockchain), and account balances (derived from public blockchain data).
IMPORTANT: Blockchain-related information is retrieved in real time from public blockchains. It is completely public and has no direct relationship with any personal data.
1.3 Information from Third-Party Sources
Third-Party Service Integration
When you use integrated third-party services within the ELLIPAL App (such as swap providers, on-ramp/off-ramp providers, or staking providers), those providers may share limited information with us, such as transaction status and confirmation, service usage analytics, and error reports.
Important Note: Third-party services are operated by independent entities. ELLIPAL only provides access interfaces and assumes no joint liability for any actions, data breaches, or service failures by third parties. You should confirm and agree to the third party’s privacy policy before use. When using third-party services through our App, you are subject to their privacy policies. These providers may collect additional information directly from you (such as KYC/AML information). We are not responsible for their data practices.
Marketing and Analytics Partners
We may receive information from marketing partners and analytics services to understand how users discover our Services and to improve our marketing effectiveness.
Links to External Sites or dApps
Our Website may contain links to external sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. You can also access dApps through the ELLIPAL Wallet App; when you use a dApp, you leave the ELLIPAL Wallet App and access that dApp’s site directly. We strongly advise you to review the privacy policy and terms of every site or dApp you visit.
IMPORTANT: We have no control over, and assume no responsibility for, the content, policies, or practices of any third-party sites, products, or services.
1.4 Cookies and Tracking Technologies
When you visit our Website, we use cookies and similar technologies to enrich your experience, display personalized content and appropriate advertising, and store your preferences on your device.
A cookie is a small text file that a website asks your browser to save on your device when you visit. Cookies help websites remember your preferences for a smoother experience and can also track your usage of our Website and relay this information back to us.
Our Website uses the following types of cookies:
• Functional cookies: used to recognize you when you return to our Website.
• Analytics and performance cookies: used to analyze, operate, maintain, and improve the Website.
• Advertising cookies: we may allow third-party advertising partners to use cookies to collect information about your browsing activities across different websites for interest-based advertising. This Policy covers the use of cookies by us and does not cover the use of cookies by advertisers.
You can manage or refuse cookies at any time through your browser settings. For advertising and analytics cookies, where required by law, we will ask for your consent before placing them, and you can withdraw it at any time. Please note that some features of our Website may not function properly without certain cookies.
1.5 E-commerce
When you purchase our products and services, we ask you to provide additional information, including the personal and financial details needed to process your transactions. We collect only the information necessary to fulfill your interaction with us. Under normal circumstances, we do not disclose personally-identifying information. You can always choose not to provide personally-identifying information, though this may prevent you from accessing certain Website features.
2. How We Use Your Information
We use the information we collect for the purposes described below.
Legal bases for processing (for EEA/UK users): Where the GDPR applies, we process your personal data on one or more of the following legal bases: performance of our contract with you (such as fulfilling orders and providing support); our legitimate interests (such as improving and securing our Services), provided these do not override your rights; your consent (such as for marketing or certain cookies), which you may withdraw at any time; and compliance with our legal obligations.
2.1 Service Delivery and Performance
• Provide access to and functionality of our hardware wallets and mobile applications
• Display your cryptocurrency balances and transaction history by querying public blockchains
• Process and fulfill your product orders, and manage shipping and delivery
• Send important service notifications (software updates, security alerts, policy changes)
• Provide customer support and respond to inquiries
2.2 Security and Fraud Prevention
• Ensure the security and integrity of our Services
• Detect, prevent, and investigate fraud, unauthorized access, and security incidents
• Monitor for suspicious activities
• Comply with sanctions laws and prevent illegal activities
2.3 Product Improvement and Development
• Analyze usage patterns to improve user experience
• Identify and fix bugs, errors, and technical issues
• Develop new features and functionality, and conduct research and analytics
• Perform quality assurance testing and optimize application and hardware wallet performance
2.4 Communication and Marketing
• Send notifications and promotional materials, and inform you of new products, features, and updates
• Conduct surveys and request feedback
• Respond to your comments and questions
• Provide personalized content and recommendations
2.5 Legal and Compliance
• Comply with applicable laws, regulations, and legal processes
• Enforce our Terms & Conditions and other agreements
• Protect the rights, property, and safety of ELLIPAL, our users, and the public
• Respond to law enforcement requests and legal proceedings
• Maintain records for accounting, tax, and regulatory purposes
2.6 Aggregated and Anonymized Data
• Create de-identified, aggregated, or anonymized data for analytics, research, and business purposes. Such data cannot be used to identify you individually and may be used without restriction; for example, we may publish a report on usage trends of our Website or products.
3. How We Share Your Information
We do not sell or rent your personal data to third parties. We may share your information in the following circumstances.
3.1 Aggregated Data Analysis
We may use aggregated, anonymized data for analytics that do not identify you individually. We may share such non-identifying information with partners to understand how users use our Services or to inform the public about overall usage trends.
3.2 Service Providers (Data Processors)
We engage third-party service providers who process data on our behalf. These providers are contractually obligated to protect your information and use it only for the purposes we specify. Categories include:
• E-commerce and payment processors: to process orders and payments (e.g., Shopify, payment gateways)
• Shipping and logistics providers: to fulfill product delivery
• Cloud hosting providers: to store and manage data securely
• Analytics providers: to understand usage and improve Services (e.g., Google Analytics, Firebase)
• Customer support platforms: to manage support tickets and communications
• Email service providers: to send newsletters and notifications
• Security and fraud prevention services: to protect against threats
• Marketing and advertising partners: to deliver relevant content and measure campaign effectiveness
3.3 Third-Party Service Integration
When you choose to use third-party services through the ELLIPAL App (such as swap providers, on-ramp/off-ramp providers, or staking providers): you may share data directly with them; their use of your data is governed by their own privacy policies; we may receive limited transaction status information from them; and we are not responsible for their data practices.
3.4 Legal Requirements and Protection
We may disclose your information when required or permitted by law: to comply with legal obligations, court orders, or regulatory requirements; to respond to lawful requests from government authorities or law enforcement; to enforce our Terms & Conditions and other agreements; to protect the rights, property, and safety of ELLIPAL, our users, and the public; and to detect, prevent, and address fraud, security, or technical issues.
3.5 Affiliates and Subsidiaries
We may share information with ELLIPAL affiliates and subsidiaries for purposes consistent with this Policy, such as providing and improving Services, customer support, and marketing and analytics.
4. International Data Transfers
Your information may be transferred to, stored, and processed in countries outside your country of residence, including countries that may not provide the same level of data protection as your home country.
All data transfers are protected using encryption during transmission (TLS/SSL), secure storage practices, security commitments from recipients, and regular security assessments. By using our Services, you acknowledge and consent to the transfer of your information as described above.
5. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements.
When personal data is no longer needed, we securely delete it using industry-standard methods, or we anonymize it so it can no longer identify you. Anonymized data may be retained indefinitely for analytics and research. We may retain data longer when required by legal proceedings or investigations, regulatory requirements, or enforcement of our rights.
6. Data Security
6.1 Technical Security
We use various security measures to protect your information, including encryption, anonymization, and other methods to safeguard your personal data.
6.2 Administrative Security
We maintain comprehensive management systems, processes, and organizational structures to ensure information security. For example, we strictly limit access to information and require all personnel to comply with confidentiality obligations and undergo regular reviews.
If a security incident affecting your personal data occurs, we will act promptly to contain it and will notify affected users and the relevant authorities as required by applicable law.
6.3 Product-Specific Security
Hardware Wallets
• ELLIPAL hardware wallet devices are completely offline (air-gapped)
• Private keys are generated and stored entirely on the device
• We cannot access your private keys or Seed Phrases
• We cannot access your operational behavior on ELLIPAL hardware wallet devices
Mobile Application
• Secure communication protocols
• Local encryption for sensitive data
• Regular security updates
6.4 Your Responsibility
IMPORTANT: As a non-custodial wallet user, you are solely responsible for keeping your Seed Phrase (recovery phrase) secure and confidential; protecting your device PIN code and passwords; maintaining physical security of your hardware wallet; and never sharing your Seed Phrase or private keys with anyone, including ELLIPAL staff.
We cannot recover your funds if you lose your Seed Phrase or private keys.
6.5 Limitations
While we implement strong security measures, no system is 100% secure, and we cannot guarantee absolute security against all threats. If you believe your data has been compromised, please contact us immediately.
To the maximum extent permitted by applicable law, ELLIPAL shall not be liable for data breaches or losses resulting from force majeure, third-party services (including but not limited to network operators, device manufacturers, and operating system providers), malware, or a user’s own failure to safeguard their Seed Phrase, PIN codes, or other credentials. Nothing in this section limits liability that cannot be excluded under applicable law.
7. Your Privacy Rights
You have rights over your personal data, and we want to make them easy to exercise. Depending on where you live and the laws that apply to you, these may include:
• Access: request a copy of the personal data we hold about you.
• Correction: ask us to correct data that is inaccurate or incomplete.
• Deletion: ask us to delete your personal data, unless we are required to keep it (for example, for accounting or legal obligations).
• Restriction: ask us to limit how we process your data in certain circumstances.
• Objection: object to our processing of your data where we rely on legitimate interests.
• Portability: ask us to provide your data in a structured, commonly used format, or transfer it to another provider where technically feasible.
• Withdraw consent: where we rely on your consent, you can withdraw it at any time without affecting processing already carried out.
To exercise any of these rights, please contact us at cs@ellipal.com. We may need to verify your identity before responding, to protect your account. We aim to respond to all legitimate requests within a reasonable time, and in any case within the period required by applicable law.
We will never discriminate against you for exercising your privacy rights.
If you are in the European Economic Area or the United Kingdom and believe we have not handled your data properly, you have the right to lodge a complaint with your local data protection authority.
For California residents (CCPA): You have the right to know what personal information we collect and how we use it, to request deletion of your personal information, and to opt out of the "sale" or "sharing" of personal information as defined under the CCPA. ELLIPAL does not sell your personal data. You may exercise these rights using the contact details above, and we will not discriminate against you for doing so.
Please note that in some cases, due to technical limitations or legal and regulatory requirements, we may not be able to fulfill every request. We will explain our reasons where that is the case.
8. Protection for Minors
ELLIPAL is committed to protecting minors’ personal information. If you are under 18, you must obtain prior written consent from your parent or legal guardian before using our products or services. We protect minors’ personal information in accordance with applicable laws and regulations.
When we collect personal information from a minor with parental or legal guardian consent, we will only use or publicly disclose this information when permitted by law, with explicit consent from the parent or guardian, or when necessary to protect the minor. If we discover that we have collected personal information from a minor without verifiable parental or legal guardian consent, we will delete that data as soon as possible.
9. Scope of Application
This Policy, together with the Terms & Conditions posted on our Website and ELLIPAL Wallet App, sets forth the general rules and policies governing your use of our Services. Depending on your activities, you may be required to agree to additional terms and conditions.
This Policy applies to all our Services. However, some Services have their own specific privacy guidelines that describe in more detail how we process your information. If there is any inconsistency between this Policy and the privacy guidelines for a particular Service, please refer to that specific guideline.
10. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, changes in applicable laws, new features or services, or user feedback.
Notification of Changes
• We will post the updated Policy on our Website and ELLIPAL Wallet App
• The "Last Updated" date will be revised
• For material changes, our Website and ELLIPAL Wallet App may require your consent again
Continued Use
Your continued use of our Services after changes become effective constitutes acceptance of the revised Policy. If you do not agree to the changes, please discontinue use of our Services. We encourage you to review this Policy periodically to stay informed about how we protect your information.
Contact Us
If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach us through our Contact Us. For data protection matters, including exercising your rights under applicable data protection laws (GDPR, CCPA, etc.), please contact us at cs@ellipal.com.