Best Wallet Privacy Policy

Last revised: April 2025

  1. INTRODUCTION

This Privacy Policy constitutes a part of Best Wallet’s Terms and Conditions (the “Terms”). It is applied by Best Wallet EOOD, 1 Pop Bogomil str, Oborishte District, Office 9, Sofia – 1202, Bulgaria (BG) in its capacity of Data Controller.

The terms used in this Privacy Policy shall have the same meanings as in the Terms except as otherwise provided herein.

This Privacy Policy explains how Best Wallet and Best Wallet’s Operators collect, use, process, disclose, share, transfer, and protect personal information obtained through Best Wallet and its partners. The terms “we,” “us,” and “our” refer to Best Wallet and Best Wallet’s Operators. When we ask for certain personal information from users, it is because we are required by applicable laws or government orders to collect such information or it is relevant for our specified purposes. Please refer to the separate Cookies Policy for the exact use of cookies.

Please carefully read the full content of this Privacy Policy. When visiting the Best Wallet website, regardless of whether or not you register for or log in, you acknowledge, understand, and consent to all articles described in this Privacy Policy. We will not use your personal information for any purpose not covered in this Privacy Policy, the Cookies Policy or the Terms without prior notification to you and your consent.

This Privacy Policy has incorporated elements from the General Data Protection Regulation (GDPR) as we act in accordance with its personal information processing rules within the European Economic Area (EEA). We utilize standard contract clauses, rely on the European Commission’s adequacy decisions about certain countries, as applicable, and obtain your consent for these data transfers to third countries if required by applicable laws.

  1. PURPOSE 

Best Wallet collects personal data for several key purposes:

  1. Service Provision: To enable the provision of services, described in Terms of service policy.
  2. Safety and Security: To protect the integrity and proper usage of the Best Wallet Website and App.
  3. Business Development: For business development purposes such as statistical analysis, marketing, and improving user experience through personalized services as well as for further development of the website, the app and its functionalities.
  4. Legal Compliance: To comply with legal and regulatory requirements, responding to legal inquiries, if such occur.
  5. Marketing and Communication: To communicate offers, products, and services to users, including promotional activities and updates on new features. This may also include but is not limited to: communicate offers, product, services and information on products and activities, future campaigns for Non-fungible tokens (“NFTs”) or other assets; marketing/cross-marketing and communicating with you in relation to products and services offered by us and our service partners as well as our appointed agents.
  6. User Support: To investigate and respond to claims and inquiries from users, ensuring effective customer service.

These purposes align with the functionalities described on Best Wallet’s websites, such as secure asset management, transaction facilitation, and user engagement;

By accepting the Terms and this Privacy Policy you expressly agree your data to be processed for the abovementioned purposes. 

  1. LEGAL BASIS
  1. Performance of a Contract: By accepting our Terms of Use, you enter into a legal relationship with Best Wallet. Accordingly, we rely on “performance of a contract” as a legal basis where it is necessary to provide services under the Terms and for operating our App and Websites properly.
  2. Legitimate Interests: In certain instances, we process personal data for our legitimate business interests. This includes ensuring the proper management and security of our App and Websites, improving user experience, and developing new features—provided that your fundamental rights and freedoms do not override these interests.
  3. Consent: Where the law requires it, or where our activities go beyond what is necessary for contract performance or legitimate interests (for example, sending you marketing communications), we will request your explicit consent. You have the right to withdraw your consent at any time, but doing so may limit your use of some or all of our services.
  4. Legal Obligations: In some cases, we may process personal data to comply with legal or regulatory requirements. This may include responding to lawful requests from governmental authorities or meeting record-keeping obligations.
  1. TYPES OF DATA WE COLLECT

The types of Personal Data that we collect directly from you or third parties depend on the circumstances of collection and the nature of the service requested or transaction undertaken. It may include (but is not limited to):

  1. personal information that links back to an individual, e.g., name, date of birth, and other personal identification numbers;
  2. contact information, e.g., address, phone number and email address, Ethereum wallet address or other blockchain wallet addresses;
  3. technical information, e.g., IP address for API services and logins, geo location, device fingerprint, etc.  statistical data, e.g., hits to the website, and information received through the cookies.
  1.  HOW DO WE COLLECT PERSONAL DATA

This Privacy Policy covers any Personal Data provided to us:

  1. when you engage with our products and services;
  2. when you create an account with us;
  3. under any other contractual agreement or arrangement, either with us or with third party service providers. For additional information, you can refer to the Terms.

Some of the other ways we may collect Personal Data shall include (but is not limited to):

  1. communications with you via telephone, letter, fax, and email;
  2. when you visit our website;
  3. when you contact us in person;
  4. when we contact you in person;
  5. when we collect information about you from third parties (such as the social graphs available from social media companies); and other channels including our support helpdesk.
  6. Possible extrapolation of other information by processing the data.
  1. WHAT OTHER DATA DO WE COLLECT?

 From our website and services, we collect your Personal Data in the following ways:

  1. IP address: We use your IP address to help diagnose problems with our server and to administer our website. IP addresses are not linked to personally identifiable information.
  2. Cookies: A cookie is an element of data that a website can send to your browser, which may then store it on your system. We use cookies in some of our pages to store your preferences and record session information. The information that we collect is then used to ensure a more personalized service level for our users. 

Please refer to our Cookie Policy for the exact information on how we use cookies. Information collected from cookies is used by us to evaluate the effectiveness of our site, analyze trends, and manage the platform. The information collected from cookies allows us to determine such things as which parts of our site are most visited and the difficulties our visitors may experience in accessing our site.

With this knowledge, we can improve the quality of your experience on the platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We may also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to our emails and to provide you with a more personalized experience when using our site, or allow third-party service providers to do this. Your continued use of this site, as well as any subsequent usage, will be interpreted as your consent to cookies being stored on your device.

Log-in information can potentially be saved in cookies. Therefore it is important that you prevent unauthorized access to your password and your computer. If you use a shared computer, you should always log out properly and clear the browser for cookies.

  1. User feedback form: Our feedback form requires you to give us contact information (e.g. your name and email address) so that we can respond to your comments. We use your contact information from the registration form to send you information about our company. Your contact information is also used to contact you where necessary.
  2. Site tracking: We also use third-party service provider(s), to assist us in better understanding the use of our site. 

Our service provider(s) will place cookies on the hard drive of your computer and will receive information that we select, for example, how visitors navigate around our site, what pages are browsed and general transaction information. Our service provider(s) analyzes this information and provides us with aggregate reports. The information and analysis provided by our service provider(s) will be used to assist us in better understanding our visitors’ interests in our site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the platform. Our service provider(s) is/are contractually restricted from using information they receive from our Site other than to assist us.

  1. YOUR RIGHTS IN REGARD TO THE PERSONAL INFORMATION

In general, you have the right to access, amend, update or delete your personal information. 

Depending on your country of residence and its legislation, you may have the right to request from us a copy of your personal data, as well as to delete your personal data, make amendments to it or restrict its processing. We will endeavour to provide the information back to you as soon as practicable, but no later than 14 days after receiving your initial request. However, we also reserve the right to validate all requests for the authenticity of the request.

You may be requested to provide us with your personal data, such as KYC documents in specific situations to comply with legal and regulatory requirements or in case of a dispute between you and Bestwallet.com. In such cases Bestwallet.com expects you to provide us with such requested information for further processing and actions.

Unless otherwise required by law or government orders, each User has the following rights:

  1. Right of Access: You have the right to access or obtain copies of your personal information, gathered by Best Wallet. We may charge a reasonable fee for providing the access service. Best Wallet cannot provide information regarding the personal data obtained by our third-party service providers. Such information requests shall be pointed towards them directly. 
  2. Right to Rectification:  You have the right to correct your personal information that you deem inaccurate. You also have the right to ask us to complete the personal information that you deem incomplete within a reasonable limit.
  3. Right to Erasure (Right to be Forgotten): You have the right to request the erasure of your personal data under certain circumstances. Such request may not be fulfilled if there are some regulatory requirements which may prevent us from doing so. 
  4. Right to Restriction of Processing: Under certain circumstances as required by law or as specifically reminded by us, you have the right to request us to restrict the processing of your personal information; however, you understand that such restriction of the processing may prevent us from providing you with some of Best Wallet’s services.
  5. Right to Object: Under certain circumstances as required by law or as specifically reminded by us, you have the right to object to the processing of your personal information; however, you understand that such objection of the processing may prevent us from providing you with some of Best Wallet’s services.
  6. Right to Data Portability: Under certain circumstances, as required by law or as specifically reminded by us, you have the right to request us to transmit the personal information that we collect to another body, or directly to you. We may charge a reasonable fee for providing the transmission service.
  1. WITHDRAWING CONSENT

Please note that it is obligatory for the Company to process your Personal Data for the Purposes as stated above, without which some services or features provided by Best Wallet may be affected. If we do not have your consent to process your Personal Data, we will not be able to keep you updated about our future, new and/or enhanced services and products or provide the services at all.

Nevertheless, you may stop receiving promotional activities by:

  1. unsubscribing from the mailing list(s);
  2. editing the relevant account settings to unsubscribe; or
  3. sending a request via our support page on support.bestwallet.com
  1. TO WHOM DO WE DISCLOSE YOUR PERSONAL DATA

We will not trade or sell your Personal Data to third parties. Your Personal Data shall only be disclosed or transferred to the following third parties appointed or authorised by the Company for the fulfilment of the Purpose of: 

  1. data warehouses; 
  2. IT service providers;
  3. data analytics and/or marketing agency; 
  4. legal bodies as permitted or required by law such as in compliance with a warrant or subpoena issued by a court of competent jurisdiction; and/or
  5. regulatory authorities applicable to you; and/or
  6. third parties, with which we cooperate in order to provide you with our services such as but not limited to payment service providers for fiat deposits 
  7. safety and security personnel. 

In addition to the above, your Personal Data may also be disclosed or transferred to any of the Company’s actual and potential assignee, transferee or acquirer (including our affiliates and subsidiaries) or our business, assets or group companies, or in connection with any corporate restructuring or exercise including our restructuring to transfer the business, assets and/or liabilities. We shall take practical steps to ensure that their employees, officers, agents, consultants, contractors and other third parties mentioned above who are involved in the collection, use and disclosure of your Personal Data will observe and adhere to the terms of this Privacy Statement.

  1. HOW LONG WILL WE RETAIN YOUR PERSONAL DATA

The Company may store data in global hosting providers with servers across various regions and we shall take all reasonable steps to ensure that all Personal Data is destroyed or permanently deleted when no longer required for the Purpose of the company, and prepare a disposal schedule for inactive data after a 24 month period.

Best Wallet implements various security measures to ensure that your personal data is stored safely and is not compromised in any way. At the same time, Best Wallet cannot in good faith guarantee that a data breach is not possible since no security measure is able to provide absolute protection. It is advised for Users to take their own safety measures such as 2-Factor Authentication or other measures not provided by Best Wallet. If you suspect that your account information or your personal data has been compromised, you should contact Best Wallet’s Support as soon as possible.

  1. LINKS TO THIRD PARTY WEBSITES

We may link this website and/or our applications to other companies’ or organizations’ websites (collectively, “Third Party Sites”). This Privacy Notice does not apply to such Third Party Sites as those sites are outside our control. If you access Third Party Sites using the links provided, the operators of these sites may collect your personal information. Please ensure that you are satisfied with the privacy statements of these Third Party Sites before you submit any personal information. We try, as far as we can, to ensure that all third party linked sites have equivalent measures for the protection of your personal information, but we cannot be held responsible legally or otherwise for the activities, privacy policies or levels of privacy compliance of these Third-Party Sites.

  1. CHILDREN’S PRIVACY

Best Wallet is not intended for, and does not knowingly collect personal data from, individuals under the age of 18. If you are under 18 years of age, please do not use our services or submit any personal information through the platform. We do not knowingly process data from users below this age without verified parental or guardian consent, in accordance with applicable data protection laws.

If we become aware that we have inadvertently collected personal data from a child without proper consent, we will take steps to delete such information as soon as possible. Parents or legal guardians who believe their child has provided us with personal data may contact us at [email protected].

  1. SUPERVISORY AUTHORITY

If you reside in the European Union and believe that our processing of your personal data infringes the GDPR or other applicable data protection laws, you have the right to lodge a complaint with the supervisory authority in the EU country of your habitual residence, place of work, or place of the alleged infringement. We encourage you to contact us first at [email protected], so we can address your concerns directly.

  1. CROSS-BORDER DATA TRANSFERS

We may transfer your personal information to our affiliates, third-party service providers, or business partners located in countries outside of your country of residence, including jurisdictions that may not offer the same level of data protection as your home country. When such transfers involve countries outside the European Economic Area (EEA) or your jurisdiction, and where these countries are not recognized by the European Commission as providing an adequate level of data protection, we ensure that appropriate safeguards are in place to protect your data. By using Best Wallet’s services, you acknowledge that your personal information may be transferred and processed in countries outside of your country of residence, in accordance with this Privacy Notice and applicable data protection laws.

Best Wallet services are provided also through applications available at Google Play (Android and other systems) and App Store (IOS system). By downloading the app from the respective provider, you agree with their Terms and Conditions and Privacy Policy and shall not hold liable Best Wallets. 

  1. ADDITIONAL INFORMATION OR ASSISTANCE

Please note that this Privacy Policy may be amended from time to time in accordance with applicable laws and regulations and such variations may be applicable to you. For further inquiries or complaints in relation to our handling of your Personal Data or our Privacy Policy or if you wish to access, update or amend your Personal Data as mentioned above please contact us at [email protected]

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