1inch Wallet Privacy Policy

Last update: May 23, 2025

At 1inch Limited (hereafter “1inch Limited”, "we", "us", "our"), one of

our main priorities is the privacy of the users of our 1inch Wallet

Application (the “Application”, “App”). That’s the reason why, to the

maximum extent possible, we try to collect as little of your personal

data as possible. However, since we still need to process some personal

data, we have put in place policies and practices to ensure it all goes

smoothly and that everything is secured.

This privacy policy is intended to inform you about the processing of

your personal data we carry out when you use the Application (the

“Privacy Policy”, the “Policy”). Therefore, it applies to all of your

interactions with us via the Application, and your interactions with us

in connection therewith. This Privacy Policy, however, is not applicable

to any processing of personal data collected via channels other than this

Application (including any other services or applications provided by

third parties). For those, we advise you to consult the corresponding

privacy policies.

1. Identity of the Data Controller

We, 1inch Limited, act as the data controller of the processing of your

personal data. It means that we decide “why” and “how” your personal data

is processed in connection with the Application.

To contact us, please refer to Section 11 (Contact us) of this Policy.

2. Categories of Data We Process

When you use our Application, the categories of personal data that we

collect are the following:

Data you provide to us when using the Application:

* any data you create through the Application, including public wallet

addresses;

* any data related to your use of the Application;

* any identification data you voluntarily provide when contacting us via

the Application (e.g., last name, first name, e-mail address, username,

etc.); and

* where applicable, any personal data included in any incident reports or

any support requests you submit regarding issues encountered using our

Application.

Data automatically collected when you use the Application:

We may use tracking technologies to automatically collect data from when

you use, access, or otherwise interact with the Application. Such data

does not reveal your specific identity (such as your name or contact

information), but may include the following:

* any technical information when accessing and using the Application

(e.g., IP address, connection data, type of browser used, download

errors, diagnostic, crash and performance logs and reports, device

identifiers, pages accessed, and the duration of the pages’ views, etc.);

* any analytics data (e.g., the IP address of the device you use to

access the Application; the type of browser software you are using; the

operating system you are using; the date and time you access the

Application; the website address, if any, that linked you to the

Application; and any other traffic data);

* any personal data about your use of the Application (including, in

particular, and depending on the case, data related to your use of the

Application and how you interact with others using our Application,

content viewed, features accessed, your status on our Application, such

as Application launches, taps, clicks, scrolling data, etc.).

Third-Party Services

We may integrate services and technologies from third parties into some

features of the Application. For example, we employ Cloudflare

performance and security infrastructure as a proxy between you and the

Application’s swap functionality. As a result, when you initiate the swap

request, Cloudflare may collect your IP address. Please be aware that

based on this data collection, your access to our Services may be

restricted. For more information on the eligibility requirements for

using the Application please refer to the 1inch Wallet Terms of Service.

We may also engage third-party service providers to facilitate the

delivery of our communications. We may also use Beehiiv to distribute

newsletters or other updates about the Application, related services, and

features. For more information on how Beehiiv processes personal data,

please refer to Beehiiv Privacy Policy.

Additionally, we use the services of several Remote Procedure Call (RPC)

providers, such as QuickNode, Fastnode, Aurora Mainnet RPC, and zkSync

Era Mainnet, to facilitate swap operations. The selection of the RPC

provider is preset based on the blockchain network. When you initiate the

swap request through our Application, the RPC provider usually does not

collect your IP address.

However, please note that third-parties may independently collect

information. We recommend reviewing their privacy policies and associated

terms to understand how they collect and process your data. We are not

responsible for the data protection practices of any third party.

We also use third-party services to help us understand your interactions

and preferences on the Application. For more information on how we use

tracking technologies please refer to Section 7 of this Policy (Tracking

Technologies).

Blockchain Data

Please note that we are not responsible for (i) your use of Ethereum or

any other blockchain and (ii) the use of your personal data as processed

in these decentralized and permissionless blockchain networks.

Your private key which you utilize to access your Ethereum or other

blockchain funds and initiate transactions is stored only on your own

device. We have no access to and will never ask you for your private keys

or wallet seed. Never trust anyone or any application that asks you to

enter your private keys or wallet seed.

You should also be aware that due to the inherent transparency of the

blockchain networks, transactions that you approve in the Application may

be publicly accessible. This includes, but is not limited to, your public

sending address, the public address of the receiver, the amount sent or

received, and any other data a user has chosen to include in a given

transaction.

Transactions and addresses available on blockchain may reveal personal

data about the user’s identity, and personal data can potentially be

correlated now or in the future by any party who chooses to do so,

including law enforcement.

In addition, we may process publicly available data, including

information obtained through blockchain intelligence and analytics

services. This may involve analyzing blockchain transactions, wallet

addresses, and other data accessible on public blockchains or related

platforms to enhance the functionality of the Application, ensure

security, and provide insights into blockchain activities. Certain

elements, when combined with other information, may reveal your identity.

We encourage you to review how privacy and transparency on the blockchain

network work.

3. How and Why We Process Your Personal Data

In the table below, you will find the various purposes for which we may

process your personal data and the corresponding legal basis. Depending

on the circumstances, we use different legal bases to process the same

personal data for different purposes.

You also have specific rights depending on the legal basis applied. You

always have the right to request access to, rectification of, or deletion

of your personal data. These are detailed in Section 9 of this Policy

(Your rights).

We process your personal data for the following purposes and on the

following legal bases:

Purpose

Legal Basis

Categories of Data Concerned

To provide the Application as well as to assess, analyze and

improve the performance of the Application, related services and

features, and to perform maintenance work (e.g., to ensure proper

functioning of the Application, facilitate transactions, troubleshoot and

correct any problems, fix errors, test our new features and ensure their

proper functioning, improve user experience on the Application, conduct

surveys and other research to determine what you appreciate about our

Application and what can be improved, collect feedback on our features

and Application, produce statistics, etc.).

The processing of your personal data is based on our legitimate

interest to optimize our tools and solutions and ensure the satisfaction

of users on our Application.

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

To manage our contractual relationship with you and fulfill our

contractual obligations when you use our Application in accordance with

the provisions of the 1inch Wallet Terms of Service.

The processing of your personal data is based on the necessity of

contract performance or necessity to enter into a contract with you

(where your personal data is required for us to perform our undertakings

and obligations in accordance with a contract we are entering into with

you when you use the Application).

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

To provide customer support

(e.g., providing information and advice regarding the use of the

Application, investigating incidents, etc.).

The processing of your personal data is based on our legitimate

interest to ensure proper communication with the users of our

Application.

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

To provide you with marketing communications (e.g. newsletters,

promotional content, and other information that may be of interest to you

about the Application, related services, features, and updates, etc.).

The processing of your personal data is based on your consent.

* personal data you provide when using the Website as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Website as

described under Section 2 of this Policy.

To manage any potential or actual disputes with you or third

parties.

The processing of your personal data is based on our legitimate

interest to defend our interests, including through legal proceedings.

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

To maintain a secured trusted environment (e.g., prevention and

fight against computer fraud (spamming, hacking)).

The processing of your personal data is based on our legitimate

interest to ensure compliance with applicable laws, compliance with our

performance of our Application.

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

To comply with legal and regulatory obligations that may apply to

us.

The processing of your personal data is necessary for compliance

with our legal obligations (e.g., to answer requests from competent

administrative or judicial authorities or data subjects’ requests or

claims).

* personal data you provide when using the Application as described

under Section 2 of this Policy;

* personal data automatically collected when you use the Application as

described under Section 2 of this Policy.

Please note that we will not process your personal data for any purpose

that is incompatible with the purposes listed above.

4. Sharing Your Personal Data

In the context of processing your personal data in accordance with this

Policy, we may communicate your personal data to the following

recipients, if necessary:

1. our subsidiaries or affiliates (if any) only if necessary for

operational purposes;

2. 1inch Foundation only if necessary for the purposes set out in this

Policy, including assistance in addressing data subject requests;

3. service providers, external suppliers, contractors, agents to the

extent that they assist us in carrying out the purposes set out in this

Policy (e.g., analytics and storage service providers to assist us in the

improvement and optimization of the Application; product engineering

providers and technical maintenance vendors to ensure proper functioning

of the Application; marketing and communication providers to promote the

use of the Application; AML compliance and risk assessment service

providers to comply with AML laws and regulations and ensure safe

environment within the Application; etc.);

4. competent courts, public authorities, government agencies, and law

enforcement agencies to the extent required by law or if we have a good-

faith belief that such disclosure is necessary in order to comply with

official investigations or legal proceedings initiated by governmental

and/or law enforcement officials, or private parties, including but not

limited to in response to subpoenas, search warrants, or court orders;

5. third parties in connection with a merger, division, restructuring,

change of control, bankruptcy, or other organizational change;

6. third parties which may collect your personal data on our Application

via tracking technologies; or

7. third-party business partners to assist such partners’ investigations

including into known cybersecurity breaches or cyber-hacks, or in case of

a serious crime that is likely to affect users of our Application. In

this case, we disclose information only to our trusted business partners

based on the duration and quality of our business relationship, the

reputation and regulatory status of the partner, and the requirements of

the applicable data protection legal framework. We will only communicate

your personal data if we have sufficient legitimate interest to do so.

We will only communicate your personal data to any recipient on a need-

to-know basis and only when the processing by the recipient is strictly

limited to the purposes identified in this Policy. We do not sell your

personal data.

5. Transfer of Personal Data

As we operate globally, we may process your personal data around the

world where our facilities or providers are located. Therefore, for the

purpose of processing your personal data as described in this Policy, we

may have to transfer your personal data outside the European Economic

Area (“EEA”).

In these cases, we implement appropriate transfer mechanisms and

safeguards to ensure that the personal data transferred benefit from the

same level of protection as within the EEA. In practice, this means that

each of the envisaged transfers is at least based on one of the following

mechanisms:

* the existence of an adequacy decision issued by the European Commission

for the country to which your personal data is transferred; or, failing

that,

* the conclusion of standard contractual clauses as adopted by the

European Commission; or, failing that,

* the existence of an exemption linked to one of the specific situations

exhaustively provided for by the General Data Protection Regulation

n°2016/679 ("GDPR"). For example, where you have explicitly given your

consent to the proposed transfer after having been informed of the

absence of safeguards; where the transfer is necessary for the

performance of a contract between you and us; where the transfer is

necessary for the conclusion or performance of a contract concluded, in

your interest, between us and a third party; or where the transfer is

necessary for the establishment, exercise or defence of our legal claims,

etc.

Information on the transfer mechanisms and safeguards may be requested by

contacting us: please see Section 11 of this Policy (Contact us).

6. Data Retention Period

We retain your personal data only for as long as necessary for the

purposes for which it has been collected, as specified in this Policy,

and in accordance with the applicable laws.

This means that the retention periods we apply may vary depending on the

purpose for which we process your personal data. When determining the

appropriate retention period, we take into account the category and

amount of personal data, potential risks, and harm that may arise from

unauthorized access or disclosure, the specific purposes for which the

data is processed, the availability of alternative means to achieve those

purposes, and the applicable legal requirements.

We also retain personal data in order to comply with legal and regulatory

obligations that may apply to us. Sometimes business and legal

requirements oblige us to retain certain data, for specific purposes, for

an extended period of time (e.g., to comply with AML compliance

requirements, or record-keeping obligations imposed by applicable

accounting, financial, or regulatory laws).

In some situations, we may anonymize personal information about you so

that it can no longer be used to identify you. In such cases, we can use

this information indefinitely without further notice to you.

7. Tracking Technologies

We may use third-party service providers that use tracking technologies

to analyse and improve your user experience within the Application, in

particular, Mixpanel, Branch, Firebase, and Storyly. For more information

about how these third-parties process your data, please refer to the

corresponding policies:

* Mixpanel Privacy Program;

* Branch Policies;

* Firebase;

* Storyly.

Such services rely on tracking technologies, such as cookies, pixels,

plugins, and software development kits (SDKs) that can be stored on your

devices when you visit the Application, so that it can be accessed later.

The data collected includes statistical and performance information

arising from your use of the Application. This type of data will only be

used by us in an aggregated or anonymised manner.

You have the option to disable the use of tracking technologies on your

device at any time. Your mobile settings may provide options that allow

you to limit the use of tracking technologies associated with your mobile

device. Additionally, within our Application, you can navigate to the

“Settings” and “Language and Permissions” sections to disable tracking

technologies.

Additionally, you can choose to disable cookies through your individual

browser options. The settings for each browser are different. They are

described in the help menu of your browser, which will enable you to know

how to change your cookies preferences. For example:

* in Microsoft Edge please refer here.

* in Safari please refer here.

* in Chrome please refer here.

* in Firefox please refer here.

* in Opera please refer here.

8. Children’s Data

The Application is intended for use by individuals who are at least

eighteen (18) years old and is not directed at children. We do not

knowingly collect personal information from children. If you believe that

such information has been collected in error, please contact us using the

details provided in Section 11 of this Policy (Contact Us).

9. Your Rights

Your rights associated with the processing of your personal data are

outlined below. Please note that some of these rights are subject to

specific conditions set out in the applicable personal data protection

regulation. Therefore, if your particular situation does not meet these

conditions, we will unfortunately not be able to respond to your request.

In this case, we will inform you of the reasons for our refusal.

Your rights under the General Data Protection Regulations (“GDPR”)

* Right of access – You may request access to your personal data at any

time. If you exercise your right of access, we will provide you with a

copy of your personal data in our possession as well as all information

relating to its processing.

* Right of rectification – You have the right to ask us to rectify or

complete any personal data in our possession that you consider to be

inaccurate or incomplete.

* Right to erasure/to be forgotten – You can ask us to delete your

personal data if, for example, it is no longer necessary for the

processing we carry out. We will use our best efforts to comply with your

request. Please note, however, that we may have to retain some or all of

your personal data if we are required to do so by applicable law or if

the personal data is necessary for the establishment, exercise, or

defence of our rights.

* Right to restriction of processing – You may also request that we

restrict the processing of your personal data on grounds relating to your

particular situation. For example, if you dispute the accuracy of your

personal data or object to the processing of your personal data, you may

also request that we do not process your personal data for the time

necessary to verify and investigate your claims.

In such cases, we will temporarily refrain from processing your personal

data until necessary verifications have been made or until we comply with

your requests.

* Right to data portability – You may request portability of the personal

data you have provided us with. At your request, we will provide you with

your personal data in a readable and structured format so that you can

easily re-use it.

The portability of your personal data applies only to personal data that

you have provided to us or that result from your activity on our

Application, under the condition that the disclosure of your personal

data does not infringe the rights of third parties. If we are unable to

comply with your request, we will inform you of the reasons for our

refusal.

* Right to object – You may object at any time, on grounds relating to

your particular situation, if we use your personal data. We will then

stop processing your personal data unless there are overriding legitimate

grounds for continuing to process your personal data (for example, if

your personal data is necessary for the establishment, exercise, or

defence of our rights or the rights of third parties in court

proceedings). If we are unable to comply with your request to object, we

will inform you of the reasons for our refusal. You can also object at

any time to our processing of your personal data for marketing purposes.

* Right to withdraw consent - You have the right to withdraw consent at

any time for personal data processing based on consent. Withdrawing your

consent prevents us from processing your personal data but does not

affect the lawfulness of the processing carried out before the

withdrawal.

Your rights under the California Consumer Privacy Act (“CCPA”)

If you are a resident of California, you have specific rights concerning

your personal information under the California Consumer Privacy Act

(“CCPA”). The CCPA provides you with the right to:

* Know the categories and specific pieces of personal information we

collect about you, the categories of sources from which it is collected

(please see Section 2 of this Policy (Categories of Data We Process); the

purposes for which it is used (please see Section 3 of this Policy (How

and Why We Process Your Personal Data); and the categories of third

parties with whom it is shared or disclosed (please see Section 4 of this

Policy (Sharing Your Personal Data).

* Access a copy of the personal information we maintain about you.

* Correct inaccurate personal information we hold about you.

* Delete your personal information, subject to certain statutory

exceptions.

* Limit the use and disclosure of sensitive personal information, if

applicable.

* Opt out of the “sale” or “sharing” of your personal information,

including for cross-context behavioral advertising purposes. Please note

that we do not sell your personal information as defined under California

law. For more details on how we share your data, please refer to Section

4 “Sharing Your Personal Data”.

You may also designate an authorized agent to submit requests on your

behalf. We will take steps to verify your identity, and if applicable,

the authority of your agent, before fulfilling any request.

These rights are subject to limitations as described in the relevant law.

We may deny your request if we need to do so to comply with our legal

rights or obligations. We will respond to requests for access,

correction, or deletion to the extent we can reasonably associate the

data we hold with the identifying information you provide. If we are

unable to comply with your request, we will notify you and explain the

reasons.

Country Specific Rights: You may also be granted specific rights as

regards our processing of your personal data depending on the law

applicable in the country you are residing in. You may contact us should

you have any questions in that regard.

Also, keep in mind that many blockchains are open to forensic analysis

which can lead to deanonymization and the unintentional revelation of

personal data, in particular when blockchain data is combined with other

data. Because blockchains are decentralized or third-party networks that

are not controlled or operated by us, we are not able to erase, modify,

or alter your personal data from such networks.

10. How to Exercise Your Rights

If you wish to exercise your rights, you may contact us by using the

contact information provided in Section 11 of this Policy (Contact Us).

To be able to process your request efficiently, we may ask you to provide

additional information to confirm your identity and/or to help us

retrieve the personal data related to your request.

If you are a California resident, you may also designate an authorized

agent to submit a request on your behalf. The agent must present signed

written permission from you authorizing them to act on your behalf. We

reserve the right to deny the agent’s request if we are not reasonably

able to confirm proper authorization and/or verify your identity as the

requestor.

If you reside in the EEA, you can lodge a complaint with a data

protection authority. You can find a list of the relevant supervisory

authorities here. However, we encourage you to contact us first, as we

are committed to addressing any concerns or complaints you may have

regarding the processing of your personal data promptly and efficiently.

11. Contact Us

If you have any questions regarding the processing of your personal data

under this Policy, including the exercise of your rights as detailed

above, you can contact us by email at info@1inch.io.

12. Changes to this Privacy Policy

We periodically review this Policy to ensure it is compliant and up to

date with applicable data protection regulations. We will post updates on

this page accordingly. When the changes are made, we will update the

“Last updated” date at the top of this Policy.

Therefore, we encourage you to review this Policy regularly. Any

modifications will take effect when posted or on the date specified as

the effective date (if any). Your continued access to and use of the

Application indicates your acknowledgment and acceptance of the updated