Privacy Policy

1. Introduction and Scope

This Privacy Policy (“Policy”) explains how WildXPay, with the legal company name NexWild Ltd, incorporated and existing under the laws of the British Virgin Islands and with registered address at Intershore Chambers, P.O. Box 4342, Road Town, Tortola, BVI (“Company”, “we”, “us”, or “our”) collects, uses, discloses, and safeguards information when you access or use our mobile application and self-custodial software interface (collectively, the “App” or “Services”).

We respect your privacy and are committed to protecting it. Because our software architecture is fundamentally non-custodial, our data collection practices are strictly minimized. We ensure that all off-chain data is handled lawfully, fairly, and transparently, adhering strictly to the statutory Data Protection Principles.

By installing, accessing, or using the App, you acknowledge and agree to the data collection and processing practices described in this Policy. If you do not agree with any part of this Policy, you must immediately uninstall the App and cease using our Services. This Policy is fully integrated into and subject to our Terms of Service.

2. The Non-Custodial Data Principle

2.1 No Private Key or Seed Phrase Collection

The foundation of our engineering architecture is user autonomy. The App generates public blockchain addresses and private key pairs locally on your device. This cryptographic data is encrypted using your device’s secure hardware elements. At no point is your backup recovery Seed Phrase or private key transmitted to our servers or accessible by our personnel. You are the sole custodian of your data and assets.

2.2 Public Blockchain Transparency

You acknowledge that all transactions executed through the App (such as sending, receiving, or swapping Digital Assets via DEX protocols) are permanently and publicly recorded on immutable blockchain ledgers. By design, blockchain networks are transparent. Anyone can view balances, transaction histories, and interaction paths of public cryptographic addresses. Your public address acts as a pseudonymous identifier on these networks. Because blockchain data is distributed globally and immutably, such ledger entries fall entirely outside the operational infrastructure of the Company and cannot be modified, redacted, or erased by us.

3. Information We Collect

Despite our non-custodial design, we process limited categories of information strictly to provide our software infrastructure, route decentralized exchange (DEX) swaps, maintain security, and manage customer service operations. The complete data processing matrix below outlines exactly what we process, why we process it, and our legal justification:

*Please note that while we query Public Blockchain Data to allow the interface to function, we do not centrally store or control this data. Due to the immutable nature of blockchains, standard data deletion requests cannot be applied to on-chain transactions.

4. How Your Information Is Used

We use the limited information we process for the following operational and legal purposes:

• Maintaining and improving the App’s software infrastructure and user interface.
• Monitoring and analyzing operational trends, application stability, and crash analytics.
• Facilitating connection endpoints with decentralized exchange (DEX) routers.
• Providing customer support and troubleshooting assistance.
• Protecting the technical integrity of the App and defending against security exploits or malicious network attacks.

5. Data Sharing and Third-Party Disclosures

We do not sell, rent, or monetize your data. To deliver the multi-network features within the software interface, data is transmitted or disclosed strictly under the following conditions:

5.1 Decentralized Exchange (DEX) Routing Protocols

When you utilize the integrated swap features, your cryptographic wallet address and transaction payload are transmitted to decentralized exchange routing protocols. This processing is automated and execution-based, occurring solely to identify optimal liquidity pricing and route the swap directly on-chain.

5.2 Cloud Services and Infrastructure Providers

We engage specialized third-party infrastructure, hosting, and cloud service providers to broadcast transactions and query public blockchain states. These entities process only the technical data strictly necessary to complete protocol-level queries, such as public wallet addresses and transaction hashes.

6. Security Measures

We implement robust, industry-standard technical and organizational security measures to prevent unauthorized access, alteration, or destruction of the data within our control.

However, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for ensuring your physical mobile device remains secure, updated, and free of malware or unauthorized tools.

7. Data Retention and Account Deletion

Data we collect are retained only as long as necessary to fulfill the specific purposes outlined in Section 4. Because there are no centralized accounts or user registration profiles required to utilize the non-custodial wallet, “deleting your account” simply involves completely uninstalling the App from your mobile device. Once uninstalled, all locally cached public addresses, transaction logs, and interface preferences are permanently erased from the device.

8. International Data Transfers

The limited data we collect may be transferred to, stored, and processed in jurisdictions outside of your country of residence, including countries where cloud infrastructure or third-party service providers operate. Whenever such transfers occur, we take all steps reasonably necessary to ensure your data is treated securely and is subjected to appropriate technical and contractual safeguards in compliance with applicable data protection laws. By utilizing the Services, you consent to the cross-border transfer of the data we may collect from you.

9. Regulatory Rights and Privacy Compliance

Depending on your jurisdiction of residence (such as the British Virgin Islands, European Economic Area, the United Kingdom, or various US states like California), you possess specific statutory rights as a Data Subject regarding your personal data.

Due to the non-custodial design of our software infrastructure, the Company does not maintain centralized profiles, identities, or databases linking individual real-world identities to public wallet addresses or decentralized exchange (DEX) transaction histories. Furthermore, public blockchain ledgers are decentralized and immutable. The Company has zero operational capability to alter, redact, erase, or restrict data recorded on a public blockchain. Consequently, the rights outlined below apply strictly and exclusively to the limited, off-chain data we actually collect and control (such as your customer support communications).

To the extent that we hold any of your personal data in our off-chain systems, you may exercise the following rights:

• Right of Access / To Know: The right to request confirmation of whether we process your data and to receive a clear copy of the specific personal data we hold about you.
• Right to Rectification (Correction): The right to request that we update, amend, or correct any inaccurate, outdated, or incomplete information in our records.
• Right to Erasure (“Right to be Forgotten”): The right to request the permanent deletion of your off-chain data (such as historical support tickets), subject to any overriding legal or regulatory retention obligations.
• Right to Data Portability: The right to request that we export your data to you or directly to another service provider in a structured, commonly used, and machine-readable format.
• Right to Restrict or Object to Processing: The right to limit how we use your data or object to our processing of your data when based on our legitimate business interests.
• Right to Withdraw Consent: The right to withdraw your explicit consent at any time for data processing activities that rely entirely on your permission, without affecting the lawfulness of processing before your withdrawal.
• Right to Lodge a Complaint: The right to file an official complaint regarding our data handling practices with a competent data protection supervisory authority in your region.

If you wish to exercise any of the rights detailed above regarding your data, you must submit a formal, verifiable request to our designated team at: office@wildxpay.com.

10. Privacy Policy Updates

We reserve the right to amend this Privacy Policy at any time to reflect updates in our data practices, regulatory requirements, or application features. Any modifications will be broadcasted by updating the version history within the App settings and you will be notified directly via an in-app prompt or notification modal. To ensure ongoing compliance with statutory data protection standards, you will be requested to provide your express consent to the revised Policy within the App interface. Your continued interaction with the App following the provision of such in-app consent indicates your full acknowledgment and acceptance of the revised Policy.