369 Wallet369 Wallet

Privacy Policy

Last updated: April 13, 2026

1. Introduction

Alpsoft Inc. ("Company", "we", "us", or "our") respects your privacy. This Privacy Policy explains how we collect, use, and protect information when you use the 369 Wallet mobile application ("App"). By using the App, you consent to the practices described in this policy.

2. Information We Do NOT Collect

As a self-custody (non-custodial) wallet, 369 Wallet is designed with privacy at its core. We do not collect, store, or have access to:

  • Your seed phrase (mnemonic recovery phrase)
  • Your private keys
  • Your wallet balances or transaction history
  • Your wallet addresses
  • Your passwords or PINs used to secure the App
  • Any personal identification information (name, email, phone number)
  • Camera images, video, or any media captured through device camera (camera is used only for local QR code scanning — see Section 6)
  • Biometric data (Face ID, Touch ID, or fingerprint data is processed by the device OS and never accessible to us)

All sensitive data, including your seed phrase and private keys, is encrypted and stored locally on your device using platform-native secure storage (iOS Keychain / Android Keystore) with PBKDF2 + AES encryption.

3. Information That May Be Collected

While we prioritize privacy, certain minimal data may be processed in the course of providing the service:

3.1 Network Requests

When you use the App to check balances, send transactions, or perform swaps, network requests are made to blockchain nodes (RPC providers) and third-party APIs. These requests may include your wallet address and are subject to the privacy policies of those providers.

3.2 Price Data

The App fetches real-time cryptocurrency price data from CoinGecko. These requests do not include any personal information or wallet addresses.

3.3 Cross-Chain Swaps

When you use the swap feature, transaction data is processed through the third-party DEX protocols. This may include your wallet address and transaction details. Please refer to each provider's privacy policy for more information.

4. Local Data Storage

The following data is stored locally on your device and is never transmitted to our servers:

  • Encrypted seed phrase and private keys (secured via platform keychain)
  • App preferences (language, currency, theme settings)
  • Custom token configurations
  • Network and RPC settings

5. Third-Party Services

The App integrates with the following third-party services, each with their own privacy practices:

  • Blockchain RPC Providers — for querying blockchain state and submitting transactions
  • CoinGecko API — for real-time cryptocurrency price data
  • DEX Protocols — for cross-chain and on-chain token swap routing and execution

We recommend reviewing the privacy policies of these third-party services for information about their data practices.

6. Device Permissions

369 Wallet requests certain device permissions only when necessary for specific features. We do not collect, transmit, or store any data obtained through these permissions on our servers.

6.1 Camera (android.permission.CAMERA / NSCameraUsageDescription)

The App requests camera access for the following purposes only:

  • Scanning QR codes to read cryptocurrency wallet addresses, payment requests, or WalletConnect session links.
  • Scanning seed phrase QR codes during wallet import or backup verification.

What we do NOT do:

  • We do not record, save, upload, or transmit any photo, video, or camera feed data to our servers or any third party.
  • We do not access the camera in the background or when the QR scanner is not actively open.
  • Scanned QR code data is processed locally on your device and is used only for the intended wallet operation.

You may deny or revoke camera permission at any time through your device settings. QR scanning features will be unavailable, but all other wallet functions (including manual address entry) will continue to work.

6.2 Biometric Authentication (Face ID / Touch ID / Fingerprint)

If you enable biometric authentication, biometric data is processed exclusively by the operating system's secure enclave (iOS Secure Enclave / Android BiometricPrompt). The App never receives, stores, or transmits biometric data — it only receives a success or failure signal from the OS.

7. Data Security

We implement industry-standard security measures to protect your data. Sensitive information is encrypted using PBKDF2 key derivation and AES encryption, and stored in platform-native secure storage. However, no method of electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Children's Privacy

The App is not intended for use by individuals under the age of 18 (or the age of majority in their jurisdiction). We do not knowingly collect information from children.

9. Your Rights

Since we do not collect personal data, traditional data subject rights (access, correction, deletion) do not apply in the conventional sense. However:

  • You can delete all local data by uninstalling the App from your device.
  • You can export your seed phrase at any time and use it with any compatible wallet application.
  • You have full control over your data and assets at all times.

10. International Data Transfers

While we do not collect personal data on our servers, network requests made through the App (e.g., blockchain RPC calls, price data fetches, swap requests) may be processed by third-party servers located in various countries. By using the App, you acknowledge that such data processing may occur outside your country of residence.

11. Data Retention

Since all data is stored locally on your device, we have no data retention obligations. Local data persists until you uninstall the App or manually clear the App's data. We do not maintain any server-side records of your usage or activity.

12. Korean Personal Information Protection Act (PIPA)

In accordance with the Personal Information Protection Act of the Republic of Korea:

  • Personal Information Manager: Alpsoft Inc. is responsible for the management of personal information processing practices.
  • Purpose of Processing: As a non-custodial wallet, we do not process personal information. All wallet data is stored locally on the user's device.
  • Entrustment: We do not entrust the processing of personal information to third parties.
  • Rights of Data Subjects: Users may exercise their rights under PIPA by contacting us at support@369wallet.xyz. However, as we do not collect personal information, these rights are limited in application.
  • Security Measures: We implement technical measures including encryption (PBKDF2 + AES) and secure platform storage to protect locally stored data.

13. GDPR (European Users)

For users located in the European Economic Area (EEA), we comply with the General Data Protection Regulation (GDPR):

  • Data Controller: Alpsoft Inc. acts as the data controller. Since we do not collect personal data on our servers, our role is limited.
  • Legal Basis: Where any data processing occurs through third-party services, the legal basis is your consent (by choosing to use the App) and legitimate interest (providing the wallet service).
  • Your GDPR Rights: You have the right to access, rectify, erase, restrict processing, data portability, and object to processing. Contact us at support@369wallet.xyz to exercise these rights.

14. Changes to This Policy

We may update this Privacy Policy from time to time. Any changes will be posted on our website and within the App. Your continued use of the App after changes are posted constitutes your acceptance of the updated policy.

15. Contact Us

If you have any questions or concerns about this Privacy Policy, please contact us at: support@369wallet.xyz