Privacy Policy

1. Who we are and what this covers

Wallion operates wallion.app and is responsible for deciding how personal information collected for the website’s purposes is used. For questions or requests about personal information, contact privacy@wallion.app.

This policy covers our informational website, website downloads, recruitment communications, optional website analytics and newsletter subscriptions. Application-specific processing and independent third-party services are covered by the privacy information supplied with those services.

Browsing this website does not require a wallet connection or an account. We do not ask for private keys or recovery phrases. Please never include them in a form, message or application.

2. Information we handle

• Information you send: your name, email address, message and other details you choose to include when contacting us.
• Recruitment information: contact details, country and time zone, résumé or profile links, work experience, your introduction and communications about a role. We may review professional material you share or identify for that purpose.
• Newsletter information: your email address, subscription choices and records of consent or withdrawal.
• Technical request information: the server delivering the website receives information such as your IP address, requested page or file, request time and browser headers. Hosting and security services may use this information to deliver content and detect misuse.
• Preferences and optional analytics: your cookie choice and its timestamps, and, if you allow an enabled analytics service, information about page visits, device or browser type, referral source and website interactions. The cookie notice identifies optional services before they run.

You choose whether to contact us, apply or subscribe. Without the relevant contact or application details, we may be unable to respond or assess an application. Declining optional analytics or newsletters does not prevent ordinary browsing or access through a valid referral.

3. Referral access and device signals

A valid referral creates a technical visitor profile linked to the member who issued the first link. A secure session cookie lets us check that access for 30 days. A later referral does not change the original member association. Revoking a link also invalidates all sessions linked to it. Clearing cookies or using another browser requires a valid referral again.

We retain request time, IP address and browser request headers to operate referral access and investigate misuse. With your cookie permission, we also collect browser and operating-system descriptions, device category, language, timezone, screen size, a fingerprint of these signals and wallet-provider names announced to the website by browser extensions. These self-reported signals help analyse device and wallet usage, including competing wallet products, and build an analytics dataset. They cannot establish a person's identity or grant or restore access.

We do not connect to a wallet or request accounts, balances, addresses, signatures, keys or recovery phrases for this analysis. We do not infer contact details from device signals. The issuing member can see their attributed activity and its technical details in Dashboard; authorized operators can manage access and investigate problems. Technical observations are retained for 90 days. Opaque referral and ownership records remain with activity history. Optional collection requires the current consent choice described in the Cookie Policy.

When you request an available desktop download, Cloudflare Turnstile checks for automated misuse. It receives network and browser signals needed for that check. The check starts only after you request a download and is separate from optional analytics. See the Cloudflare Turnstile Privacy Addendum. We retain download-request and transfer-start records as technical observations for 90 days; these records do not establish that a file was completely downloaded or installed.

4. Purposes and legal bases

Where applicable law requires a legal basis, we use the following bases for the corresponding purposes:

• Website delivery and security: our legitimate interests in operating a reliable website, preventing abuse and investigating faults, subject to your rights and interests.
• Enquiries: our legitimate interests in responding to you, or steps at your request before entering a contract when your enquiry concerns a potential agreement.
• Recruitment: steps at your request before an employment or other engagement contract, our legitimate interests in assessing suitability and administering recruitment, and any specific legal obligations that apply.
• Optional analytics and newsletters: your consent. We keep these choices separate and allow you to withdraw either choice.
• Compliance and claims: compliance with a specific legal obligation, or our legitimate interests in establishing, exercising or defending legal claims, as applicable.

We consider the impact on you before relying on legitimate interests. You can object to processing on that basis. We do not use your information for solely automated decisions that have legal or similarly significant effects on you.

5. Recruitment information

We use information you submit or send about a role to review relevant experience, communicate with you and manage recruitment. Access is limited to people involved in that work and providers supporting it. Applying does not subscribe you to marketing.

Provide only information relevant to your application. We do not ask for identity documents, financial information or sensitive personal information in an initial application. If a later stage requires additional information or checks, we will explain what is needed, why and who will receive it before collecting it.

We seek separate permission to retain an unsuccessful application for future opportunities. If you join Wallion, information needed for the engagement moves into the applicable personnel records and privacy notice.

6. Analytics, newsletters and cookies

Optional analytics helps us understand which pages and downloads visitors use and where the website needs improvement. We require an affirmative cookie choice before activating optional analytics. A record of consent does not itself load a tracking service. The Cookie Policy lists the storage active on this website.

You can reopen “Cookie preferences” in the footer to change your choice. Clearing the website’s browser storage also removes the saved preference. Choosing “Deny all” leaves optional tracking disabled.

We send newsletters only to people who subscribe. Each marketing email must include an unsubscribe option. You may also withdraw your subscription by contacting privacy@wallion.app. Cookie consent, a download, an enquiry or a job application does not enrol you in a newsletter.

We do not sell or rent personal information or share it for cross-context behavioural advertising. We do not use advertising trackers or email-open tracking.

7. Who receives information

Information may be available to authorized Wallion personnel and service providers needed for hosting, security, email delivery, recruitment administration and consented analytics. Providers acting on our instructions must use information only for the agreed service and apply appropriate confidentiality and security safeguards. Ask privacy@wallion.app for information about the providers relevant to your request.

We may disclose information when a binding legal requirement requires it, to protect people and the website from unlawful activity, or to establish, exercise or defend legal claims. We assess requests and disclose only information relevant to their purpose.

If a business transfer affects personal information, we require appropriate safeguards and provide notice of material changes to the responsible operator or purposes. Following an external link takes you to a service with its own privacy practices.

8. International transfers

A provider or team member may process information in a country different from yours. Where a transfer is restricted by applicable data-protection law, we must use an applicable safeguard before making it. Depending on the transfer, this may be an adequacy decision, approved standard contractual clauses or another lawful mechanism, together with any additional measures required.

For information about the locations and safeguards relevant to your information, or to request a copy of applicable safeguards with confidential details removed where necessary, contact privacy@wallion.app.

9. How long we keep information

We keep personal information for the purpose for which it was collected, using the following retention limits:

Cookie preferences

180 days from your most recent choice, or until you clear the website’s browser storage.

Routine technical and security logs

Up to 30 days, unless particular records are needed to investigate an incident or comply with a legal requirement.

Enquiries

Up to 12 months after the enquiry is resolved.

Recruitment

Up to 12 months after the recruitment process ends. Keeping an application for future opportunities requires separate permission for a stated period.

Referral technical observations and optional analytics records

90 days. Reports that no longer identify anyone may be kept longer.

Newsletter subscriptions

Until you unsubscribe. We keep the minimum suppression record needed to honour your opt-out and evidence of consent where necessary to demonstrate compliance.

A specific legal requirement or an active dispute may justify longer retention of relevant records. We restrict those records to that purpose. When retention ends, we delete or anonymize the information; protected backups are removed through their normal deletion cycle.

10. Your choices and rights

Depending on the law that applies to you, you may request access to your information, correction of inaccurate information, deletion, restriction of processing or a portable copy. You may object to processing based on legitimate interests and object to direct marketing at any time.

You can withdraw consent as easily as you gave it. Withdrawal affects future processing and does not change the lawfulness of processing carried out before withdrawal. Some information may need to be retained to meet a legal obligation or deal with a legal claim; we will explain a relevant exception.

Send requests to privacy@wallion.app. We may ask for proportionate information to verify your identity and prevent disclosure to someone else. We will not ask for wallet secrets. We respond within the deadlines required by applicable law and explain any permitted extension or refusal.

You may complain to the data-protection authority responsible for your location or the matter. For the EEA, the European Data Protection Board’s authority directory provides national contact details. You do not have to contact us first.

11. Security and younger visitors

We use organizational and technical measures appropriate to the information and the risks involved, including limiting access to people who need it for their work. No method of storage or transmission can guarantee absolute security. Avoid including unnecessary sensitive information in messages or applications.

The website’s recruitment and newsletter services are intended for people aged 16 or older, subject to any higher age or additional permission required by local law. We do not knowingly collect children’s information through these services. If you believe a child has provided information without the required permission, contact privacy@wallion.app so we can investigate and take appropriate action.

12. Changes and contact

We update this policy when our processing, services or legal requirements change. The date at the top identifies the current version. We provide an appropriate notice for material changes and obtain new consent before using information for a new purpose that requires it.

For privacy questions, rights requests, provider information or transfer safeguards, write to privacy@wallion.app. For other legal enquiries, write to legal@wallion.app.