ELLIPAL Private Policy

INTRODUCTION

ELLIPAL (hereinafter referred to as "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 when you use our products and services.

This Policy applies to all interactions with our Services, including:

  • Our hardware wallets (such as ELLIPAL Titan 2.0, Titan, Titan Mini, and X Card)
  • Our mobile applications for iOS and Android ("ELLIPAL Wallet App")
  • Our website at https://www.ellipal.com/ ("Website")
  • Related services and features

This policy applies only to information we collect through our Services, how we use this information, and under what circumstances we may disclose the information to third parties, and does not apply to our collection of information 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.

For any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: cs@ellipal.com

Website: https://www.ellipal.com/

For data protection matters, including exercising your rights under applicable data protection laws (GDPR, CCPA, etc.), please use the contact information above.

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 information needed to assist you effectively. This encompasses your contact information like email address, the content of your inquiries and support communications, and your interaction history with our support team. In certain situations 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 you submit and ratings you provide 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 like browser type, language preferences, and referring site. For logged-in users or blog commenters, we may collect IP addresses.

Like most website operators, our collects non-personally-identifying information of the sort that web browsers and servers typically make available.

Some visitors to our website 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 at our Website to provide a username and email address.

Blockchain-Related Information

  • We collect publicly available blockchain information for display purposes:

    • Wallet addresses (for transaction history display)
    • Transaction data (publicly available on blockchain)
    • Account balances (derived from public blockchain data)

    IMPORTANT: The blockchain-related information is retrieved in real-time from public blockchains, which 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 service 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
    • 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. Users 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 on a third party link, you will be directed to that third party's site.
  • You can access any dApp through the ELLIPAL Wallet App. When you use a dApp, you will leave the ELLIPAL Wallet App and directly access that dApp's site.

We strongly advise you to review the privacy policy and terms and conditions 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, to enrich and perfect your online experience, we use "Cookies", similar technologies and services provided by others to display personalized content, appropriate advertising and store your preferences on your computer.

A cookie is a small text file that a website requests your browser to save on your device when you visit the site. They help websites remember your preferences so you can have a smoother experience the next time you visit. Cookies 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 for website analysis and attribution to 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 any advertisers.

Our visitors who do not wish to have cookies placed on their computers should set their browsers to refuse cookies before using ELLIPAL Limited's websites, with the drawback that certain features of ELLIPAL Limited's websites may not function properly without the aid of cookies.

By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree to our use of cookies.

1.5 E-commerce

When you purchase our services and products, 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 following purposes:

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
  • 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
  • Conduct research and analytics
  • Perform quality assurance testing
  • Optimize application and hardware wallet performance

2.4 Communication and Marketing

  • Send notifications and promotional materials
  • 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 our rights, property, and safety, and those of 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 as to better understand how visitors use our Website or how users use our products
  • Such data cannot be used to identify you individually and may be used without restriction, for example, we may publish a report on trends in the usage 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 Business Partners

We will use the information we collect for big data analysis. For example, we may use the information we collect to analyze industry insight reports that do not contain any personal information.

We may disclose and share with our partners information that is processed without post-identification content to understand how users use our services or to inform the public about the overall usage trends of our services.

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 service 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
  • 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
  • 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
  • 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
  • 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
  • Enforcement of our rights

6. DATA SECURITY

We implement comprehensive technical and organizational measures to protect your Personal Data:

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 occurs—such as personal information disclosure—we will activate our emergency response plan to contain the incident and notify you through push notifications, announcements, and other channels.

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
  • Not 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. We cannot guarantee absolute security against all threats. If you believe your data has been compromised, please contact us immediately.

ELLIPAL shall not be liable for any data breaches or losses resulting from force majeure, third-party services (including but not limited to network operators, device manufacturers, operating system providers), malware infection, or users' failure to fulfill their custodial obligations (such as disclosure of seed phrases, PIN codes, etc.).

7. HOW DO YOU CONTROL YOUR PERSONAL DATA

  • You may access, modify, and delete your account information and other personal data provided while using our Services. You may also contact us following the guidelines in this Policy. The scope and manner in which you can access, modify, or delete your personal information depends on the specific Services you use.
  • We collect and use your information to implement the functions of our products and Services as described in this Policy. If you believe we have incorrectly collected or used your personal information, you may request that we delete it. If you find that personal information we have collected or stored is inaccurate, you may also request that we correct it. Please contact us using the details listed in this Policy.
  • When you access, modify, or delete information, we may require authentication to protect your account security.
  • Please understand that due to technical limitations or legal and regulatory requirements, we may not be able to fulfill all requests. We will respond to your request within a reasonable timeframe.

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. THE SCOPE OF APPLICATION

This Policy, together with the Terms & Conditions posted on our Website and ELLIPAL Wallet App, set 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 or statements 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 privacy 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
  • User feedback

Notification of Changes

  • We will post the updated Policy on 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 changes, please discontinue use of our Services

Review Regularly

  • We encourage you to review this Policy periodically
  • 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 contact us:

Email: cs@ellipal.com

Website: http://ellipal.com