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Privacy Policy
1. Our Commitment to Your Privacy
Welcome to Hopper Wallet! This Privacy Policy outlines how Hopper Wallet ("Hopper dex DAO LLC", "we", "us", or "our") collects, uses, stores, shares, and protects your Personal Data when you access or use the Hopper Wallet application, associated services, website, or any related features (collectively, the "Services").
By utilizing our Services, you confirm that you have the legal capacity to agree to this Privacy Policy and that you have read, understood, and consent to the data practices described herein. If you disagree with any part of this Privacy Policy, you must not use our Services. This document details the types of data we handle, our reasons for doing so, how it's managed, potential sharing scenarios, your rights concerning your data, and how to contact us.
2. Who We Are and How to Reach Us
Hopper dex DAO LLC is the primary entity responsible for your Personal Data (the "Data Controller").
For any privacy-related questions or to exercise your data protection rights, please contact our Data Protection Team at:
Email: [email protected]
3. Understanding Key Terms
Personal Data: Any information related to an identifiable individual, or one who can be identified, directly or indirectly, through identifiers like name, identification number, location data, online identifiers (e.g., IP address, wallet addresses), or factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity. This does not include anonymized data.
Sensitive Data: A subset of Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for unique identification, health data, or data concerning a natural person's sex life or sexual orientation.
Processing: Any operation performed on Personal Data, such as collection, recording, organization, structuring, storage, adaptation, retrieval, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction.
4. Information We Collect and Collection Methods
Hopper Wallet processes Personal Data obtained through your interaction with our Services or with your explicit consent.
Information You Provide Directly:
- Onboarding & Setup: Information provided during the wallet creation or import process (excluding critical private data mentioned below).
- Communications: When you contact our support team, participate in surveys, or communicate with us via email or other channels.
Information Collected Automatically:
Transactional Data: Information related to transactions initiated through Hopper Wallet, public blockchain addresses interacted with, and balances viewable through your connected wallets on public blockchains.
Device and Access Information: IP address, device type, operating system, browser type, device identifiers (e.g., MAC address), access times, pages viewed, and session information for devices used to access the Services.
Geolocation Data: Approximate location derived from your IP address or more precise location if you grant permission.
Interaction Data: Information about your activities on third-party decentralized applications (dApps) or websites when Hopper Wallet interacts with them, to enhance security and user experience.
Information We Explicitly DO NOT Collect or Store:
- Your wallet password for the Hopper Wallet application.
- Your private keys.
- Your seed phrase (mnemonic phrase).
- If using advanced features like Multi-Party Computation (MPC), we do not store your complete private key shards in a reconstructible way by ourselves.
Information from Third Parties:
- We may receive information from third-party services, such as identity verification services (if you opt-in to features requiring this), analytics providers, or partners. We will take steps to ensure such third parties are compliant with applicable privacy laws.
We will not collect Sensitive Data without your explicit consent, unless required or permitted by law (e.g., for legal obligations or to address suspected unlawful activity).
Failure to provide necessary Personal Data may limit our ability to offer you some or all of our Services. We generally do not offer the option to engage with us anonymously or under a pseudonym if identification is essential for service provision or legal compliance.
5. Handling of Unsolicited Personal Data
If we receive Personal Data that we did not solicit, we will assess if it's relevant to our stated collection purposes. If not, we will destroy or de-identify it, provided it is lawful and reasonable to do so. If it is relevant and combined with other data we are entitled to collect, it will be treated in accordance with this Privacy Policy.
6. Categories of Individuals Whose Data We Collect This policy applies to Personal Data collected from:
- Users and prospective users of Hopper Wallet Services.
- Visitors to our website.
- Individuals who contact us.
- Service providers and business partners.
7. Our Use of Your Personal Data
We use your Personal Data for the following purposes:
Service Provision and Maintenance: To operate, maintain, and provide you with the features and functionality of Hopper Wallet, and to manage our relationship with you as per our Terms of Service.
Security and Fraud Prevention: To protect the security of your account, our Services, and to detect and prevent fraudulent or unauthorized activity.
Enhancement of Services: To understand how users interact with our Services, allowing us to improve existing offerings and develop new ones.
Customer Support: To respond to your inquiries, provide assistance, and resolve issues.
Legal and Regulatory Compliance: To comply with applicable laws, regulations, legal processes, and governmental requests.
Marketing and Communications: With your consent, to inform you about products, services, promotions, and events that may interest you. You can opt-out at any time (see Section 13).
Aggregated Analytics: To create aggregated, anonymized statistical data to understand usage trends and improve our services.
With Your Consent: For any other purpose for which you provide explicit consent.
We will only use Sensitive Data for the purpose for which it was provided, a directly related secondary purpose, with your explicit consent, or as permitted by law.
8. Legal Grounds for Processing Your Personal Data
We process your Personal Data based on one or more of the following legal grounds:
Performance of a Contract: When processing is necessary to provide the Services you requested under our Terms of Service.
Legal Obligation: When processing is necessary for us to comply with our legal or regulatory responsibilities.
Legitimate Interests: When processing is necessary for our legitimate interests (or those of a third party), provided your fundamental rights and freedoms do not override those interests. This includes improving our Services, security, and fraud prevention.
Consent: When you have given us explicit consent to process your Personal Data for a specific purpose (e.g., marketing).
Protection of Vital Interests: In rare cases, to protect your vital interests or those of another person.
Public Interest: Where processing is necessary for the performance of a task carried out in the public interest.
9. How and When We Share Your Personal Data
Hopper Wallet may disclose Personal Data to:
Affiliates and Corporate Group: Our parent companies, subsidiaries, and other entities under common control, along with their representatives.
Service Providers: Third-party vendors and partners who assist us in delivering our Services, such as cloud hosting, data analytics, IT support, customer service platforms, and security services. These providers are contractually bound to protect your data and use it only for the purposes we specify.
Blockchain Networks: By nature of blockchain technology, some information (like your public wallet address and transaction details) will be publicly recorded on the respective blockchain when you make transactions. This is not controlled by Hopper Wallet.
Legal Authorities and Regulatory Bodies: If required by law, court order, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to comply with legal obligations, protect our rights or property, prevent fraud, or ensure the safety of our users or the public.
Corporate Transactions: In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or a portion of our assets, your Personal Data may be transferred as part of that transaction.
Professional Advisors: Our lawyers, accountants, auditors, and other professional advisors, where necessary for them to provide services to us.
With Your Consent: To any other third party with your prior consent to do so.
We do not sell your Personal Data. We take reasonable steps to ensure that any third parties with whom we share your data have adequate data protection measures in place.
10. Data Storage, Security, and Retention
Security Measures: We implement robust technical and organizational security measures designed to protect your Personal Data from unauthorized access, use, alteration, disclosure, or destruction. These include encryption, access controls, secure software development practices, and regular security assessments.
Storage: Your Personal Data is primarily stored on secure servers, which may be operated by us or our third-party service providers.
Retention: We retain your Personal Data for as long as necessary to fulfill the purposes for which it was collected, including providing Services, satisfying legal, accounting, or reporting requirements, and for our legitimate business purposes. For example, certain data may be retained to comply with anti-money laundering regulations (if applicable to specific features you use) or to resolve disputes. Once data is no longer needed, we will securely delete or anonymize it.
11. International Transfer of Personal Data
Hopper Wallet operates globally, and your Personal Data may be transferred to, stored, and processed in countries other than your country of residence. These countries may have different data protection laws. When we transfer your Personal Data internationally, we will take appropriate measures to ensure that the transfer complies with applicable data protection laws and that your Personal Data remains protected to the standards described in this Privacy Policy (e.g., by using Standard Contractual Clauses, adequacy decisions, or other legally recognized transfer mechanisms).
12. Your Data Protection Rights
Subject to applicable law, you may have the following rights regarding your Personal Data:
- Right to Access: To request a copy of the Personal Data we hold about you.
- Right to Rectification: To request correction of inaccurate or incomplete Personal Data.
- Right to Erasure (Right to be Forgotten): To request deletion of your Personal Data, under certain conditions (e.g., if it's no longer necessary for the purposes collected, or if you withdraw consent). We may decline requests where retention is legally required or for legitimate business purposes.
- Right to Restrict Processing: To request that we limit the processing of your Personal Data under certain circumstances.
- Right to Data Portability: To receive your Personal Data in a structured, commonly used, and machine-readable format, and to transmit it to another controller, where technically feasible.
- Right to Object: To object to our processing of your Personal Data, particularly for direct marketing purposes or when processing is based on legitimate interests.
- Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw it at any time. This will not affect the lawfulness of processing based on consent before its withdrawal.
- Right to Lodge a Complaint: To lodge a complaint with a relevant data protection supervisory authority if you believe our processing of your + Personal Data infringes applicable laws.
To exercise these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by law and will require identity verification.
13. Marketing and Other Communications
We may use your Personal Data to send you marketing communications about Hopper Wallet's products, services, and promotions, but only with your explicit consent or where otherwise permitted by law. You can opt-out of receiving these communications at any time by:
- Clicking the "unsubscribe" link in any marketing email.
- Adjusting your communication preferences within the Hopper Wallet settings (if available).
- Contact us directly at [email protected].
Please note that you cannot opt-out of essential service-related communications, such as security alerts, policy updates, or transactional notifications, which are necessary for the proper functioning and security of your account and our Services.
14. Cookie Policy and Tracking Technologies
When you visit our website or use our Services, we may use cookies and similar tracking technologies (e.g., web beacons, pixels) to collect information.
- What are Cookies? Small data files stored on your device by your browser.
- Why We Use Them:
- Essential Cookies: For the basic functioning of our Services (e.g., maintaining your session).
- Preference Cookies: To remember your settings and preferences.
- Performance & Analytics Cookies: To collect information about how you use our Services, helping us improve them (e.g., Google Analytics).
- Security Cookies: To help detect and prevent security risks.
- Your Choices: Most browsers allow you to control cookies through their settings. However, disabling certain cookies may affect the functionality of our Services.
15. Third-Party Links and Services
Our Services may contain links to third-party websites, dApps, or services that are not operated by Hopper Wallet. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site 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.
16. Privacy of Minors
Hopper Wallet Services are not intended for individuals under the age of 18 (or the age of legal majority in their jurisdiction). We do not knowingly collect Personal Data from minors. If we become aware that we have inadvertently collected Personal Data from a minor without parental consent, we will take steps to delete such information promptly. If you believe a minor has provided us with Personal Data, please contact us.
17. Modifications to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make changes, we will update the "Effective Date" at the top of this policy and post the revised version on our website or within the Hopper Wallet application. We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes signifies your acceptance of the revised Privacy Policy. For material changes, we may provide more prominent notice.
18. Language This Privacy Policy may be provided in multiple languages for convenience. In case of any discrepancy or conflict between the English version and a version in another language, the English version shall prevail.
19. Specific Jurisdictional Provisions
If you are a resident of certain jurisdictions (e.g., European Economic Area (EEA), California, Singapore, Australia), you may have additional rights under local laws. We are committed to complying with all applicable data protection laws. For specific details relevant to your jurisdiction, please refer to any applicable addenda to this policy or contact us.
For European Economic Area (EEA) Residents: We process your Personal Data in compliance with the General Data Protection Regulation (GDPR). Our legal bases for processing are detailed in Section 8. You have rights as outlined in Section 12, including the right to lodge a complaint with a supervisory authority. Transfers of Personal Data outside the EEA are conducted with appropriate safeguards.
For California Residents: You may have additional rights under the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA). We do not "sell" or "share" (for cross-context behavioral advertising) your personal information as defined by the CCPA/CPRA. You have rights to know, delete, correct, and opt-out of certain uses of your data.
20. Contact Us
If you have any questions, concerns, or complaints about this Privacy Policy or our data handling practices, please contact our Data Protection Team: