Privacy Policy
Privacy Policy
Effective Date: 11/6/2025
Coin98 Wallet Ltd. ("Coin98”, "we", "our", and "us") recognizes the importance of your personal data and is firmly committed to safeguarding your privacy and protecting your rights in accordance with applicable data protection laws. We encourage you to review this Privacy Policy carefully, as it explains the manner in which we collect, use, disclose, and otherwise process your personal data.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY PLEASE LEAVE THE WEBSITE, UNINSTALL MOBILE APPLICATIONS AND/OR EXTENSION OR CEASE USING COIN98 SOFTWARE AND SERVICES IMMEDIATELY.
All the definitions used in this Privacy Policy shall have the same meaning as in our Terms of Service unless this Policy sets a different meaning.
Our Relationship with You
We collect a variety of information that you provide, depending on your engagement with our Coin98 Software and Services. Some Personal Data is required to use the Coin98 Software and Services, while other data is optional.
Your Personal Data
“Personal Data” means any information related to an identified or identifiable natural person. This includes (a) Information you provide to us; (b) Information collected about you automatically; and (c) Information we obtain from third parties, including but not limited to, publicly accessible sources, affiliated companies, service providers, other trusted third parties, or your use of our (or our service provider’s) digital technologies and services.
2.1. Personal Data You Provide to Us
We collect a variety of information that you provide, depending on your engagement with our Coin98 Software and Services. Some Personal Data is required to use the Coin98 Software and Services, while other data is optional.
(a) Account and Profile Information
When you create an account or use our Coin98 Software and Services, you may provide Personal Data such as:
Your name;
Government-issued identification documents (e.g., passport, national ID card, driver’s licence);
National identification numbers;
Facial images, selfies, or video recordings used for biometric identity verification;
Other information necessary for account creation, maintenance, or compliance purposes.
Where permitted by applicable law or based on your explicit consent, we may collect and process biometric data, such as facial scan data extracted from your selfie or video, for the purposes of verifying your identity. This process may include comparing your facial scan with the photo contained in your submitted government-issued identification document, as part of our Know Your Customer (KYC), Anti-Money Laundering (AML), and fraud prevention procedures.
We only collect and use biometric data:
With your explicit, informed consent;
For the limited purposes of identity verification and regulatory compliance;
In accordance with applicable data protection laws and biometric data handling regulations;
Using service providers who are contractually bound to protect and handle your data securely and confidentially.
Your biometric data will be stored securely and retained only for as long as required to fulfill the stated purposes or to comply with applicable legal and regulatory requirements. You may withdraw your consent at any time, but doing so may limit or prevent access to the Services that require identity verification.
(b) Contact Information
When contacting us via email, website forms, or other means, you may provide Personal Data such as:
Name and contact details (e.g., email address);
The content of your communications.
(c) Support Information
When you request technical support, we may collect:
Your contact details;
The nature of your request;
Any further information you voluntarily provide;
Data related to your usage of the Coin98 Software and Services to assist with support.
(d) Other Information
You may also provide additional information, including:
Your wallet address;
Uploaded content;
Preferences and settings relevant to the Services.
For certain Coin98 Software and Services, additional Personal Data may be required to verify your identity or deliver the Coin98 Software and Services. We will notify you where this applies.
You are responsible for ensuring that all Personal Data provided is true, accurate, complete, and up to date. Please inform us in writing of any changes.
Where our collection of Personal Data is based on your consent, you may withdraw it at any time. Please note, however, that doing so may affect our ability to:
(i) Provide the Coin98 Software and Services;
(ii) Fulfil legal or contractual obligations.
Our Coin98 Software and Services are not intended for individuals under the age of majority in their jurisdiction. If you are a parent or guardian and believe that your child has provided us with Personal Data without your consent, please contact us.
If you provide Personal Data relating to third parties (e.g., employees, customers, family members), you represent and warrant that:
(i) You have informed them of this Privacy Policy and the purposes of data collection;
(ii) You have obtained their consent to share their Personal Data with us (where required); and
(iii) You agree to indemnify us against any claims from such individuals relating to our processing of their Personal Data in accordance with this Privacy Policy.
2.2. Personal Data We Collect Automatically
When you use our Coin98 Software and Services, we may automatically collect certain categories of Personal Data, either directly or through third-party service providers. This data is collected to improve functionality, ensure security, and meet legal and regulatory obligations. We never collect your private keys and never have access to your wallet because none of your private keys ever leave your web browser storage or local storage of your mobile phone.
(a) Financial and Transactional Information
We may collect information such as:
Transaction records;
Digital Asset holdings;
Wallet addresses.
Such data is collected to comply with legal obligations, including AML, KYC, and CTF requirements.
(b) Technical and Device Information
We may collect technical data from your device or browser, including:
Internet Protocol (IP) address;
Device identifiers and hardware model;
Browser type, operating system, and platform details;
Crash reports, diagnostics, and performance data.
(c) Usage and Interaction Data
To understand how you interact with our Coin98 Software and Services, we may collect:
Clickstream data and browsing behavior;
Pages viewed and session duration;
Search queries and navigation paths.
This information helps us analyze user behavior, improve usability, and detect suspicious activity.
(d) Cookies and Similar Technologies
We use cookies and similar tracking technologies, such as pixel tags, web beacons, and local storage, to:
Monitor and analyze usage patterns;
Enhance Services performance and reliability;
Personalize your user experience.
You may adjust your browser or device settings to manage cookie preferences. However, disabling cookies may limit certain features or functionality.
(e) Location Information
We may infer your general location (e.g., country or city) based on your IP address. This information is used for:
Legal compliance;
Fraud detection and prevention;
Service localization and customization.
We do not collect precise geolocation data unless explicitly authorized by you.
(f) Single Sign-On and Third-Party Platforms
If you choose to log in or interact with the Coin98 Software and Services via a third-party platform (e.g., Google, Apple), we may receive Personal Data such as:
Your name;
Email address;
Profile photo or other basic account information.
This data is shared with us under the terms of the third party platform’s privacy policy. We encourage you to review the privacy practices of any third-party platform you use in connection with the Coin98 Software and Services.
2.3. Information from Third Parties
We may receive Personal Data about you from third-party sources, which we may combine with data we collect directly. These sources may include:
(a) Affiliates and business partners: This may include identity verification data, transaction records, and usage information obtained from companies within our corporate group or business network.
(b) Public blockchain data: We may collect data available on public blockchains, such as wallet addresses, transaction history, and token holdings. While such data is publicly accessible, it may be considered Personal Data when linked to other identifiers.
(c) Retail merchants and service providers: If you interact with third-party merchants, vendors, or service providers through our platform, we may receive data necessary to facilitate transactions or resolve support inquiries.
(d) Public databases and watchlists: We may screen your information against government-issued sanctions or watchlists (e.g., OFAC, UN sanctions lists) and other publicly available data sources for compliance with AML/CTF, and fraud prevention regulations.
Please note that even if information is publicly available (such as on a blockchain), it may still be treated as Personal Data under applicable laws when combined with other data that enables identification.
Why We Process your Personal Data
We only process your Personal Data for purposes that are lawful, proportionate, and relevant to the context in which it was collected. In accordance with applicable data protection laws, we rely on specific legal bases - such as contractual necessity, compliance with legal obligations, your consent, and our legitimate interests - to process your Personal Data for the following purposes:
(a) to create, manage, and maintain your account or user profile;
(b) to enable your access to the Coin98 Software and Services, including wallet connectivity, transaction execution, and user verification;
(c) to support integrations with third-party service providers and enhance the Coin98 Software and Services with additional features;
(d) for personalization to customize the Coin98 Software and Services to meet your specific needs, such as identifying your requests for regionality to improve your experience with the Coin98 Software and Services, and facilitating interactions with third-party services;
(e) for product improvement to improve the Coin98 Software and Services and to develop new products, services, and features;
(f) to communicate with you, by phone, text, email, or other communication channels for purposes including: (i) security, maintenance, and administrative notifications; (ii) respond to your inquiries, requests, or feedback, (iii) providing technical support or updates related to your use of the Coin98 Software and Services; (iv) notifying you of material changes to this Privacy Policy or our Terms of Service;
(g) subject to any consent requirements, to send marketing materials, alerts about the latest developments and features or other promotional materials, and to develop new promotional materials that can be useful or relevant to you. You will always be provided with an opportunity to opt out of receiving marketing communications;
(h) for customer and third-party relationship management including to track emails, phone calls, and other actions you have taken as a prospective customer or our customer or other third-parties;
(i) for aggregation or de-identifying of Personal Data which is a format that does not allow you to be personally identified. We use the resulting information for statistical analysis regarding the use of the Coin98 Software and Services, such as to better understand our customer base, or for other purposes;
(j) for administrative and legal purposes, such as for compliance purposes. This includes enforcing our Terms of Service or enforcing or defending other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency, and to comply with our legal obligations and internal policies as permitted by law, such as preventing the Coin98 Software and Services to be accessed by individuals in sanctioned territories, or by sanctioned individuals;
(k) to detect, investigate, and respond to violations of our Terms of Service or attempts at unauthorized access. We process Personal Data to ensure the security and integrity of the Coin98 Software and Services and protect them from misuse or malicious attacks.
We will not use or process your Personal Data for purposes not specified in this Privacy Policy without first obtaining your consent, where required by law. If we intend to process your data for a new or unrelated purpose, we will notify you and seek your consent in accordance with applicable legal requirements. In some cases, we may process your data without your knowledge or consent, but only where this is required or permitted by law.
We may disclose your Personal Data to law enforcement agencies, regulators, courts, or other competent authorities where legally required. Where possible and appropriate, we will attempt to notify you of such disclosures. However, in certain situations (e.g., where prohibited by law or where the request relates to an emergency), we may be unable to provide such notice.
While we may challenge requests that are unlawful, vague, or overbroad, we do not guarantee that we will contest every such request.
With whom do we share your Personal Data
We do not sell your Personal Data. However, your Personal Data may be made available, disclosed or shared to our related parties and/or within our Affiliates in order to provide you with our Coin98 Software and Services, support business operations, ensure compliance, and utilize shared IT infrastructure and services across the group.
When sharing your Personal Data with Affiliates and third parties, we will use our best endeavours to ensure that such entities are either subject to this Privacy Policy or will follow practices at least as protective as those described in this Privacy Policy.
We may share your Personal Data with the following entities or in the following circumstances:
(a) Affiliate: Your Personal Data may be shared with and processed by our Affiliates in order for us to conduct business and offer Coin98 Software and Services to you.
(b) Third-party service providers: We may employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risks. These third-party service providers only have access to the Personal Data they need to perform their functions and may not use the Personal Data for other purposes. Further, they must process the Personal Data in accordance with our contractual agreements and only as permitted by applicable data protection laws.
(c) Legal authorities: We may be required by applicable laws or by courts to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will only disclose information about you to legal authorities to the extent we are obliged to do so according to the applicable laws. We may also need to share your information in order to enforce or apply our legal rights or to prevent fraud.
(d) Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy notices (unless, of course, the user consents otherwise). Also, in the unlikely event that we or substantially all of our assets are acquired by a third party, user information will be one of the transferred assets.
(e) Protection of Coin98 and others: We release accounts and other Personal Data when we believe the release is appropriate to comply with the applicable laws or our regulatory obligations, to enforce or apply our Terms of Services and other agreements, or to protect the rights, property or safety of Coin98, our users or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
How secure is your Personal Data?
We design our systems with your security and privacy in mind. We have appropriate security measures in place to prevent your information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We work to protect the security of your Personal Data during transmission and while stored by using encryption protocols and softwares. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need-to-know.
Our security procedures mean that we may ask you to verify your identity to protect you against unauthorized access to your account. We recommend using a unique password for your account that is not utilized for other online accounts, use multi-factor authentication (where possible) and to sign off when you finish using a shared computer.
What rights do you have in relation to your Personal Data?
You have the following rights with respect to your Personal Data. We are committed to upholding these rights and enabling you to exercise them freely and without discrimination:
(a) Right to Access: You have the right to obtain access to the Personal Data we hold about you and to receive information regarding: (i) the purpose of processing, (ii) the categories of Personal Data concerned, (iii) the recipients or categories of recipients to whom your data has been or will be disclosed, (iv) the envisaged data retention period; and (v) the source of the data (if not collected directly from you); and (vi) whether we use automated decision-making.
(b) Right to Rectification: You may request that we correct or update any inaccurate or incomplete Personal Data that we hold about you.
(c) Right to Delete: You may request that we delete your Personal Data, and we will do so without undue delay if: (i) the data is no longer necessary for the purposes for which it was collected; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) the data has been unlawfully processed; (v) the data has to be erased for compliance with a legal obligation.
(d) Right to Object to Processing: You have the right to object to our processing of your Personal Data based on our legitimate interests. You may also freely opt out of (i) the sharing of your Personal Data with third parties for any of the purposes stated in this Privacy Policy; and/or (ii) any use of your Personal Data that is incompatible with the original purposes for which it was collected or subsequently authorized by you. To exercise your right to object or opt out, please contact us at: [email protected].
(e) Right to Restrict Processing: You have the right to restrict us in the ability of processing your Personal Data if: (i) you contest the accuracy of your Personal Data and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your Personal Data, but you need it for establishment, exercise or defense of legal claims; (iv) you have objected to the processing and we are verifying whether our legitimate grounds override your objection.
(f) Right to Portability: You have the right to receive the Personal Data which you provided to us in a structured, commonly used and machine-readable format, and to request its transfer to another data controller, where technically feasible and legally permissible.
(g) Right to Withdraw your Consent: If our processing is based on your consent, you may withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing carried out prior to such withdrawal.
(h) Right to Lodge a Complaint: You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
(i) Right Against Discrimination: We will not discriminate against you for exercising your rights.
(j) Right to Opt Out of Targeted Advertising, Sale or Sharing: Where applicable law provides, you may ask us to stop using your Personal Data for targeted advertising, or to stop the sale or sharing of your data with third parties for such purposes.
For any questions or feedback in relation to this Privacy Policy or your Personal Data, or if you wish to make a complaint to us, please submit your requests, feedback or complaint to [email protected].
Where We Store Your Personal Data
The security of your Personal Data is our top priority. We shall take care in implementing and maintaining the security of our Services, as well as that of your Personal Data. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Data and to prevent instances of unauthorized use.
Please note that it is impossible to fully guarantee the security of your Personal Data. While we take reasonable steps to safeguard your Personal Data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from any unauthorized or unintended access that is beyond our control (e.g. hacking or cybercrimes), or abuse of your information. We recommend that you take independent safety precautions to protect your Personal Data, particularly your credential information such as your username and password. You hereby agree that we shall not be liable for any information leakage and other losses not caused intentionally or otherwise by our gross negligence, including, but not limited to, hacker attacks, power interruptions, or unavoidable technical failures. For the avoidance of doubt, we do not make any warranty, guarantee, or representation that your use of Coin98 Software and Services is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk.
How Long We Store Your Personal Data
We will store your Personal Data for as long as it is necessary in order to fulfill the purposes for which it was collected, including for the purposes of satisfying any business, contractual, legal, regulatory and/or statutory obligations (such as audit, accounting or reporting requirements).
Depending on the nature of the data and the applicable legal framework, certain categories of Personal Data may be retained for extended periods. This may include, but is not limited to user profiles, identification and verification records, information relevant to AML/KYC/CTF procedures, account and transaction information, contracts and agreements, or account statements and operational records.
We will assess and respond to requests to delete Personal Data and we shall accordingly delete Personal Data provided that the Personal Data is no longer needed, unless retention is required by applicable law or necessary for the establishment, exercise, or defense of legal claims.
Where permitted by law, we may anonymize or aggregate Personal Data so that it can no longer be associated with you. We may retain and use such anonymized or aggregated data for legitimate business purposes without further notice to you.
Please note that certain blockchain-related data, including wallet addresses generated through the Coin98 Software and Services, are stored on decentralized blockchain networks and cannot be deleted, altered, or erased due to the immutable nature of blockchain technology.
Transfer of Personal Data to Other Countries
Due to the global nature of our Services and operational structure, your Personal Data may be transferred to, stored, or processed in jurisdictions outside your country of residence. This may occur where we, our affiliates, or our service providers operate or host infrastructure, and may be necessary for reasons including improving service performance, ensuring business continuity, consolidating data management, or complying with legal or regulatory requirements.
Such jurisdictions may have different, and sometimes less stringent, data protection laws than those applicable in your home country. In these cases, we take all reasonable and appropriate steps to ensure that your Personal Data remains protected and is handled in accordance with applicable privacy laws.
Where required by law, we implement appropriate safeguards for international data transfers. These may include:
Entering into data transfer agreements incorporating Standard Contractual Clauses approved by regulators;
Ensuring that the recipient country or organization has been deemed to provide an adequate level of data protection;
Applying binding corporate rules, technical and organizational safeguards, or other lawful mechanisms as permitted under relevant data protection laws.
We only transfer your Personal Data to recipients who are contractually bound to handle such data in compliance with applicable privacy regulations and our instructions.
You may contact us to learn more about the specific safeguards applied to cross-border data transfers. By using the Coin98 Software and Services or submitting your Personal Data to us, you consent to such transfers, storage, and processing outside your country of residence.
Third-Party Collection of Personal Data
Coin98 Software and Services may contain links to third-party websites, platforms, or services that are not owned, operated, or controlled by us. These links are provided solely for your convenience. You may also access Coin98 Software and Services through third-party websites, platforms, or interfaces.
Please note that this Privacy Policy applies only to Coin98 Software and Services. When you interact with third-party websites or platforms, their own privacy policies and practices will govern the collection, use, and disclosure of any Personal Data you provide to them. We do not control and are not responsible for the privacy, security, or data practices of such third parties.
In addition, certain features of our Services may include or integrate third-party software development kits (SDKs), cookies, trackers, plug-ins, or embedded content (e.g., videos, widgets, or social media tools). These third parties may collect Personal Data or usage information directly from your device when you interact with such features. Their data practices are also governed by their respective privacy policies.
You acknowledge and agree that:
We are not responsible or liable for any content, products, services, or representations provided by such third-party websites, platforms, or providers;
This Privacy Policy does not apply to any Personal Data you provide directly to third parties, or that is collected through third-party SDKs, trackers, or integrations;
You knowingly and voluntarily assume all risks of using such third-party technologies or services, and we shall not be held liable for any losses, damages, or consequences arising from your interactions with them.
We strongly encourage you to review the privacy policies of any third-party websites, applications, or services before sharing your Personal Data or using features that rely on third-party technologies.
Changes to this Privacy Policy
We may update or modify this Privacy Policy from time to time. When we do so, we will provide notice of such changes by updating the “Effective Date” at the top of this Privacy Policy and, where appropriate, by other means such as email notifications or in-app messages via the Coin98 Software and Services or its newsfeed.
Your continued access to or use of the Coin98 Software and Services after any such updates constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes to this Privacy Policy, you must discontinue your use of the Coin98 Software and Services.
We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your Personal Data.
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