Privacy Policy
Effective October 13, 2025
Borderless Solutions Limited (“Borderless,” “we,” “our”) operates the WanderWallet mobile-only service. This policy explains what personal data we collect, why we collect it, where we store it (Brazil), and how you can exercise your rights.
1 · Who controls your data?
Borderless Solutions Limited
1111B S Governors Avenue, Ste 28357, Dover, DE 19904 USA
Email: privacy@wanderwallet.io (or in‑app → Settings → Privacy)
2 · What data do we collect?
| CATEGORY | DETAILS | WHEN COLLECTED |
|---|---|---|
| KYC & Identity | Full name, date of birth, selfie, government ID, proof of address (handled & stored by Didit.me). | During account verification. |
| Wallet & Transaction | Public blockchain address, on‑chain payments, merchant IDs, amounts, timestamps. | Whenever you sign or broadcast a transaction. |
| Approximate Location | Seven‑character geohash (~153 m accuracy). Only when you pay a merchant; not for peer‑to‑peer transfers. | At payment confirmation. |
| Device & Usage Logs | Device model/OS, app version, IP address, error logs. | On app launch and during use. |
| Aggregated Analytics | Event counts and funnels via self‑hosted PostHog. Data are anonymised and cannot be traced back to a human identity. | In‑app telemetry. |
No cookies: WanderWallet is mobile‑only; we don’t run web tracking pixels or cross‑site ads.
Noah On-Ramp
If you choose to use the optional banking on-ramp, identity verification (KYC) and any fiat-related data are collected directly by Noah US, Inc. inside Noah’s secure webview.
- WanderWallet may receive limited operational information from Noah (for example, that bank details have been issued) in order to display status in the app.
- WanderWallet does not collect or store your KYC documents.
- Access to the on-ramp may be restricted in some jurisdictions or for sanctioned users, as determined by Noah’s own compliance systems.
3 · Why and on what legal bases?
| PURPOSE | LEGAL BASIS (GDPR ART. 6) |
|---|---|
| Operate the wallet, process payments, provide support | Contract (6 (1)(b)) |
| Verify identity, screen for sanctions/AML | Legal obligation (6 (1)(c)) |
| Prevent fraud, secure the platform, improve UX | Legitimate interests (6 (1)(f)) |
| Aggregate transaction metrics for product analytics | Legitimate interests (6 (1)(f)); data anonymised |
| Send transactional notifications (receipts, security alerts) | Contract |
| No marketing communications at launch. If this changes, we will request opt‑in consent first. |
4 · How we share data
We share the minimum required with these trusted service providers (all bound by DPAs):
| RECIPIENT | ROLE |
|---|---|
| Didit.me | KYC/AML identity verification & secure storage |
| Supabase (Brazil region) | Managed Postgres database & auth |
| Microsoft Azure (Brazil region) | Encrypted cloud infrastructure / server runtime |
| Circle Internet Financial | Multi‑party computation (MPC) key custody |
| Depay.us | Fiat settlement & merchant payout |
| Resend.com | Transactional email delivery (no marketing) |
| PostHog (self‑hosted in Brazil) | Aggregated, anonymised product analytics |
We never sell or rent your personal data.
5 · International transfers
Primary storage: All production data are hosted in São Paulo, Brazil (SA‑EAST) on Supabase Postgres and Azure compute. Back‑ups and encrypted logs may occasionally be replicated to other Azure regions for disaster recovery. Whenever we move data outside Brazil, we rely on:
- Standard Contractual Clauses or equivalent safeguards, and
- Strong encryption in transit and at rest.
6 · Retention
| DATA SET | RETENTION RULE |
|---|---|
| KYC records, transaction logs, geolocation logs | 5 years after account closure (AML & audit) |
| Device/usage logs | ≤ 24 months |
| Aggregated analytics | Indefinite (cannot re‑identify you) |
We securely delete or irreversibly anonymise data once the retention period ends.
7 · Your rights
Depending on your jurisdiction, you may have rights to access, correct, delete, port, or restrict your data—and to object to processing.
How to exercise:
- In‑app → Settings → Privacy → Request Data; or
- Email us from the address linked to your wallet: privacy@wanderwallet.io.
We may need to re‑verify your identity.
8 · Security measures
- End‑to‑end encryption in transit (TLS 1.3) and at rest (AES‑256).
- Role‑based access; production secrets stored in Azure Key Vault.
- Regular penetration testing and smart‑contract audits.
- Continuous monitoring & rate‑limiting to detect abuse.
9 · Public blockchain data
Transactions you approve are recorded on the Polygon blockchain, a public ledger visible to anyone. While we do not publish real‑world identities on‑chain, sophisticated analysis could link an address to you. Only send transactions you are comfortable being public forever.
10 · No children
WanderWallet is 18+ only. We do not knowingly collect data from children. If you believe a minor is using the app, contact us and we will delete the account.
11 · Changes to this policy
We may update this policy. The “Effective” date will change, and we will give at least 14 days’ notice in‑app or via email for material changes.
12 · Contact
Questions, concerns, or data‑subject requests:
Email: privacy@wanderwallet.io
Mail: Borderless Solutions Limited, 1111B S Governors Avenue, Ste 28357, Dover, DE 19904 USA
By using WanderWallet, you acknowledge that you have read and understood this Privacy Policy and agree to its terms.