Privacy Policy

Last updated: April 17, 2025

Welcome to the Privacy Policy for Kirin Wallet (the "Application" or "Service"), provided by Arraki Group limited ("Arraki Group limited", "we", "us", or "our"). We understand the importance of privacy when it comes to managing your digital assets. This Privacy Policy describes how we collect, use, and protect your information when you use our AI-powered crypto wallet Application, and outlines your privacy rights.

We are committed to maintaining high standards of security and privacy while providing you with a seamless wallet experience. By using Kirin Wallet, you agree to the collection and use of information in accordance with this Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data You Provide

While using Kirin Wallet, we may ask you to provide certain personally identifiable information. We aim to collect only what is necessary to provide and improve our Service:

Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Blockchain Data

It's crucial to understand that blockchain transactions are inherently public. When you use Kirin Wallet:

What We Don't Collect or Store

To maximize your security and privacy, Kirin Wallet is designed as a non-custodial wallet. We never collect, store, or have access to:

You are solely responsible for the security of your private keys and recovery phrase.

Automatic Data Collection (Usage Data)

Usage Data is collected automatically when using the Service.

Usage Data may include information such as your Device's Internet Protocol address (e.g., IP address), device type, operating system type and version, manufacturer and model, browser type (if applicable), screen resolution, language settings, mobile carrier, general location information (e.g., city, state derived from IP address), unique device identifiers (including identifiers used for analytics or advertising purposes, where applicable), and other diagnostic data.

When You access the Service by or through a mobile device, We automatically collect certain information, including the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We also collect online activity data, such as pages or screens you viewed within the Application, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and interaction with features.

Information from Third-Party Social Media Services

The Company may allow You to create an account or link functionalities using Third-party Social Media Services such as:

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal Data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account, depending on the permissions granted.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Wallet Security Principles

Kirin Wallet employs strong security measures, but ultimate security relies on your practices and the non-custodial design:

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

How We Share Your Personal Information

We may share Your personal information in the following situations:

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating offices (located in Hong Kong SAR China) and potentially in any other places where the parties involved in the processing (like Service Providers) are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Delete Your Personal Data

You have the right to delete or request that We assist in deleting the Personal Data that We have collected about You (subject to legal limitations).

Our Service may give You the ability to delete certain information about You from within the Service settings (e.g., removing optional account information).

You may update, amend, or delete Your information at any time by signing in to Your Account, if you have one, and visiting the account settings section that allows you to manage Your personal information. You may also contact Us (see "Contact Us" section) to request access to, correct, or delete any personal information that You have provided to Us.

Please note, however, that We may need to retain certain information when we have a legal obligation or lawful basis to do so (e.g., for regulatory compliance, resolving disputes, enforcing agreements). Also, note that information recorded on public blockchains cannot be deleted by us or anyone else.

Security of Your Personal Data

The security of Your Personal Data is important to Us. We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. We strive to use commercially acceptable means to protect Your Personal Data. However, remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security. Your role in securing your device and your private keys/seed phrase is critical.

Your Choices

Do Not Track Signals

Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" signals in a standardized way as no consensus standard exists. We are monitoring the development of these standards. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Declining to Provide Information

We aim to collect only the personal information necessary to provide and secure the Service. If you decline to provide information essential for certain features (e.g., email for account recovery if offered), we may be unable to provide those specific features or support related to them. Core wallet functionality (managing keys, sending/receiving crypto) generally does not require providing Personal Data directly to us.

Access, Correction, and Deletion

You can review and update certain information through the Application settings where applicable. You also have the right to request access to, correction of, or deletion of your personal data that we hold, subject to limitations described elsewhere in this policy. Please refer to the "Delete Your Personal Data" section and the "Contact Us" section for how to make these requests.

Communication Preferences

If we send you marketing emails or non-essential communications, you will have the option to opt-out by following the unsubscribe instructions in the email or contacting us. We may still send essential service-related communications (e.g., security updates, critical alerts).

Children's Privacy

Our Service does not address anyone under the age of 13 (or a higher age threshold if required by applicable law in your jurisdiction). We do not knowingly collect personally identifiable information from anyone under the relevant age threshold. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your Privacy Rights (Jurisdiction Specific)

Your Rights Under Hong Kong Law

As Arraki Group limited is based in Hong Kong SAR China, this Privacy Policy is primarily governed by the laws of Hong Kong, including the Personal Data (Privacy) Ordinance (PDPO). Under the PDPO, you may have rights regarding your personal data, such as the right to access and correct your data held by us.

To exercise any rights you may have under applicable law, please contact us using the details provided in the "Contact Us" section. We will respond to your request consistent with applicable law. Please provide sufficient information to allow us to reasonably verify your identity and understand your request.

Governing Law

This Privacy Policy and any disputes relating hereto shall be governed by and construed in accordance with the laws of the Hong Kong Special Administrative Region of the People's Republic of China, without regard to its conflict of laws principles.

Links to Other Websites

Our Service may contain links to other websites or services that are not operated by Us (e.g., links to blockchain explorers, partner websites, social media). If You click on a third party link, You will be directed to that third party's site or service. We strongly advise You to review the Privacy Policy of every site or service You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page and updating the "Last updated" date.

If we make material changes, we may let You know via email (if you have provided one) and/or a prominent notice within Our Service, prior to the change becoming effective.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Your continued use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, our privacy practices, or wish to exercise your rights, you can contact us: