Privacy Policy

Welcome to UNP Wallet ("Application", "we", "us", or "our"), a digital wallet application developed and operated by ElyonGames LTD, a company incorporated in England and Wales with its registered office in London, United Kingdom.

This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile and web application. We respect your privacy and are committed to protecting your personal data in accordance with the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, and applicable international data protection laws.

UNP Wallet is operated by ElyonGames LTD, the data controller for the purposes of applicable data protection legislation.

• Company Name: ElyonGames LTD
• Registered Address: London, United Kingdom
• Contact Email: info@unipolychain.com
• Data Protection Officer: privacy@unipolychain.com

As the Data Controller, we determine the purposes and means of processing personal data collected through UNP Wallet.

We collect and process the following categories of information to provide, maintain, and improve our services:

3.1 Information You Provide

• Account Information: Email address, username, and encrypted authentication credentials
• Wallet Data: Public wallet addresses and blockchain transaction data (publicly available on-chain)
• Communication Data: Messages and correspondence when you contact our support team
• Preference Data: Language settings, display theme, auto-lock timer, notification preferences

3.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers, and mobile network data
• Usage Data: Pages visited, features used, time and date of access, and interaction patterns
• Log Data: IP address (anonymised), browser type, access times, and referring URLs
• Push Notification Tokens: Device tokens for delivering notifications (with your explicit consent)

3.3 Information We Do NOT Collect

We process your data for the following purposes:

• Service Delivery: To provide, operate, and maintain the UNP Wallet application and its features
• Transaction Processing: To facilitate blockchain transactions, staking, bridging, and exchange operations
• Account Security: To authenticate your identity, detect fraud, and protect against unauthorised access
• Push Notifications: To send transaction confirmations, security alerts, and important account updates
• Service Improvement: To analyse usage patterns and improve user experience (using aggregated, anonymised data)
• Customer Support: To respond to enquiries, resolve issues, and provide technical assistance
• Legal Compliance: To comply with applicable laws, regulations, and lawful governmental requests
• NFC Card Services: To link and manage NFC payment cards associated with your account

Under the UK GDPR and Data Protection Act 2018, we rely on the following legal bases to process your personal data:

• Contractual Necessity (Article 6(1)(b)): Processing necessary to perform our contract with you (providing wallet services)
• Legitimate Interests (Article 6(1)(f)): To improve our services, ensure security, and prevent fraud — balanced against your fundamental rights
• Consent (Article 6(1)(a)): Where you have given explicit consent, such as for push notifications and marketing communications
• Legal Obligation (Article 6(1)(c)): To comply with applicable UK and EU laws and regulations

We implement robust technical and organisational measures to protect your personal data:

• End-to-End Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.3
• Biometric Authentication: Face ID / Touch ID support for secure, convenient access
• Secure Local Storage: Sensitive data (private keys, seed phrases) stored exclusively on-device using hardware-backed keystores
• Auto-Lock Protection: Configurable inactivity timeout to prevent unauthorised access
• Zero-Knowledge Architecture: We cannot access your private keys or seed phrases — you are the sole custodian
• Regular Security Audits: Periodic security assessments and penetration testing of our infrastructure
• Access Controls: Strict internal access controls and role-based permissions for our team members

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy:

• Account Data: Retained while your account is active and for 30 days following account deletion
• Transaction Records: Blockchain transactions are immutable and permanently recorded on the public ledger
• Communication Records: Support correspondence retained for up to 24 months
• Usage Analytics: Aggregated, anonymised analytics data may be retained indefinitely
• Legal Requirements: Data may be retained longer where required by applicable law or regulation

Under the UK GDPR, you have the following rights regarding your personal data:

• Right of Access (Article 15): Request a copy of the personal data we hold about you
• Right to Rectification (Article 16): Request correction of inaccurate or incomplete data
• Right to Erasure (Article 17): Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing (Article 18): Request limitation of how we process your data
• Right to Data Portability (Article 20): Receive your data in a structured, machine-readable format
• Right to Object (Article 21): Object to processing based on legitimate interests or direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with the Information Commissioner's Office (ICO) at ico.org.uk

Our web application may use cookies and similar tracking technologies to enhance your experience:

• Essential Cookies: Required for core functionality such as authentication and session management
• Preference Cookies: Store your settings such as theme preference, language, and auto-lock timer
• Analytics Cookies: Help us understand how users interact with our application (anonymised)

Our mobile application does not use traditional browser cookies. We use local storage on your device to store preferences and session data.

You can control cookie settings through your browser preferences. Disabling essential cookies may affect the functionality of the web application.

We may share limited data with trusted third-party service providers who assist in operating our application:

• Cloud Infrastructure: Microsoft Azure for secure hosting and data processing
• Blockchain Networks: BSC (Binance Smart Chain) for on-chain transaction processing
• Push Notifications: OneSignal for delivering push notifications to your device
• Analytics: Anonymised usage metrics to improve service quality

All third-party services are contractually bound to protect your data and are only permitted to process data on our behalf and in accordance with our instructions. We do not sell your personal data to any third party.

As a UK-based company, your data may be processed in the European Economic Area (EEA) and other jurisdictions where our infrastructure providers operate. Where data is transferred outside the UK:

• We ensure appropriate safeguards are in place, such as Standard Contractual Clauses (SCCs) approved by the ICO
• Transfers to adequacy countries as determined by the UK Secretary of State for Digital, Culture, Media and Sport
• We conduct Transfer Impact Assessments where required

UNP Wallet is not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that a child under 18 has provided us with personal data, we will take immediate steps to delete such information. If you believe a child has provided us with their data, please contact us at privacy@unipolychain.com.

We may update this Privacy Policy from time to time to reflect changes to our practices, technology, legal requirements, or other factors. We will notify you of any material changes by:

• Posting the updated policy within the application
• Sending a push notification or email about significant changes
• Updating the "Last Updated" date at the top of this policy

We encourage you to review this Privacy Policy periodically. Your continued use of UNP Wallet after changes are posted constitutes acceptance of the modified policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: