Privacy Policy

1. Information We Collect

1.1 Information You Provide

When you create an account, make a purchase, or contact us, you may provide:

• Account Information: Email address, name, and password credentials
• Transaction Information: Gift card selections, purchase amounts, recipient details for gift deliveries, and cryptocurrency wallet addresses used for payments
• Verification Information: Where required by law or our risk assessment, government-issued identification documents, proof of address, and related verification data
• Communications: Messages you send to our support team, feedback, and survey responses

1.2 Information Collected Automatically

When you access our Services, we automatically collect:

• Device Information: Device type, operating system, browser type, and unique device identifiers
• Usage Information: Pages visited, features used, time spent on pages, and interaction patterns
• Network Information: IP address, approximate geographic location (country/region level), and internet service provider
• Transaction Metadata: Timestamps, transaction status, and blockchain network information (public blockchain data only)

1.3 Information from Third Parties

We may receive information from:

• Identity Verification Providers: Results of verification checks where you have consented to such verification
• Blockchain Networks: Publicly available transaction data from cryptocurrency networks
• Business Partners: Information from gift card brand partners necessary to fulfil your orders

2. How We Use Your Information

We use your information for the following purposes:

2.1 Service Delivery

• Processing your gift card purchases and delivering codes
• Managing your account and authentication
• Sending transaction confirmations and receipts
• Delivering gift notifications to recipients on your behalf
• Providing customer support and responding to inquiries

2.2 Legal and Compliance

• Complying with anti-money laundering (AML) and know-your-customer (KYC) requirements
• Detecting, preventing, and investigating fraud, abuse, and security incidents
• Meeting tax reporting and regulatory obligations
• Responding to lawful requests from authorities

2.3 Service Improvement

• Analysing usage patterns to improve our Services
• Developing new features and functionality
• Conducting research and analytics
• Testing and troubleshooting

2.4 Communications

• Sending service-related notifications (order confirmations, security alerts)
• With your consent, sending promotional communications about new gift cards and offers
• Responding to your inquiries and support requests

3. Legal Basis for Processing

Under Swiss and EU data protection law, we process your personal data on the following legal bases:

• Contractual Necessity: Processing necessary to perform our contract with you, including processing orders and delivering gift cards.
• Legal Obligation: Processing required to comply with legal requirements, particularly AML/KYC regulations and tax obligations.
• Legitimate Interests: Processing for our legitimate business interests, such as fraud prevention, security, and service improvement, where these interests are not overridden by your rights.
• Consent: Where you have given explicit consent, such as for marketing communications. You may withdraw consent at any time.

4. Data Sharing and Disclosure

We do not sell your personal data. We may share your information in the following circumstances:

4.1 Service Providers

We share data with trusted service providers who assist us in operating our Services, including payment processors, email delivery services, identity verification providers, and hosting providers. These providers are contractually obligated to protect your data and use it only for the purposes we specify.

4.2 Gift Card Partners

When you purchase a gift card, we share necessary information with the gift card brand or their authorised distributor to fulfil your order. This typically includes the gift card amount and delivery email address.

4.3 Legal Requirements

We may disclose your information when required by law, regulation, court order, or in response to a lawful request by public authorities, including to meet national security or law enforcement requirements.

4.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your personal data may be transferred. We will provide notice before your data is transferred and becomes subject to a different privacy policy.

5. International Data Transfers

Your data is primarily stored and processed in Switzerland and the European Economic Area (EEA). Where we transfer data outside these regions, we ensure appropriate safeguards are in place:

• Adequacy decisions recognising equivalent data protection standards
• Standard Contractual Clauses approved by the European Commission
• Other lawful transfer mechanisms under applicable data protection law

6. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes for which it was collected:

• Account Data: Retained while your account is active and for 3 years after closure
• Transaction Records: Retained for 10 years to comply with AML regulations and tax requirements
• Verification Documents: Retained for 10 years after the end of the business relationship as required by Swiss AML law
• Support Communications: Retained for 3 years from the date of resolution
• Analytics Data: Aggregated and anonymised within 26 months

7. Data Security

We implement robust technical and organisational measures to protect your personal data:

• Encryption of data in transit and at rest using industry-standard protocols
• Secure authentication mechanisms including support for two-factor authentication
• Regular security assessments and penetration testing
• Access controls limiting data access to authorised personnel
• Continuous monitoring for security threats and anomalies
• Incident response procedures and breach notification processes

While we strive to protect your data, no method of transmission or storage is 100% secure. We encourage you to use strong passwords and protect your account credentials.

8. Your Rights

Under Swiss and EU data protection law, you have the following rights regarding your personal data:

• Right to Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request that we correct inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data in certain circumstances, subject to legal retention requirements.
• Right to Restriction: You may request that we restrict processing of your personal data in certain circumstances.
• Right to Data Portability: You may request a copy of your data in a structured, commonly used, machine-readable format.
• Right to Object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw that consent at any time.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the Swiss Federal Data Protection and Information Commissioner (FDPIC) or your local supervisory authority.

To exercise these rights, please contact us at privacy@walletspree.com. We will respond to your request within 30 days. We may need to verify your identity before processing your request.

9. Cookies and Tracking

We use cookies and similar technologies to operate our Services, remember your preferences, and understand how you use our platform.

9.1 Types of Cookies We Use

• Essential Cookies: Required for the operation of our Services, including authentication and security. These cannot be disabled.
• Functional Cookies: Remember your preferences and settings to enhance your experience.
• Analytics Cookies: Help us understand how visitors interact with our Services so we can improve them.

9.2 Your Cookie Choices

You can control cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling certain cookies may affect the functionality of our Services.

We do not use third-party advertising cookies or engage in cross-site tracking. We do not sell data collected through cookies to third parties. For more details, see our Cookie Policy.

10. Children's Privacy

Our Services are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@walletspree.com. If we learn that we have collected personal data from a child, we will take steps to delete that information promptly.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will:

• Update the "Last updated" date at the top of this policy
• Notify you by email (if you have an account) or through a prominent notice on our Services
• Where required by law, obtain your consent to material changes

We encourage you to review this Privacy Policy periodically. Your continued use of our Services after any changes constitutes acceptance of the updated policy.

12. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us: