1inch Wallet Privacy Policy  
 
Last update: October 1, 2025 
At 1inch Wallet (“Application” or “App”), we respect your privacy and are committed to protecting your 
personal data. The Application is operated by Degensoft Ltd., registered at: c/o Walkers Corporate (BVI) 
Limited, 171 Main Street, PO Box 92, Road Town, Tortola VG 1110, British Virgin Islands (“Degensoft 
Ltd.,” “we,” “us,” or “our”). We design our services to minimize the collection of personal data wherever 
possible. Where processing is necessary, we apply appropriate policies and safeguards to ensure your 
information is handled securely. 
This Privacy Policy (the “Policy”) explains how we process personal data when you use the Application. It 
applies only to your interactions with us through the Application. It does not apply to any data collected 
through other channels or services provided by third parties, in which case you should consult the 
relevant privacy policies. If you do not agree to this Policy, do not download, use or access the App. 
This Policy is an inalienable part of the 1inch Wallet Terms of Service. All capitalized terms used in this 
Policy shall have the same meaning as in the 1inch Wallet Terms of Service, unless expressly stated 
otherwise.
 
1. Identity of the Data Controller 
 
We, Degensoft Ltd., act as the data controller of the processing of your personal data. It means that we 
decide “why” and “how” your personal data is processed in connection with the Application. 
 
To contact us, please refer to Section 11 (Contact us) of this Policy. 
 
2. Categories of Data We Process 
 
When you use our Application, the categories of personal data that we collect are the following: 
 
Data you provide to us when using the Application:  
 
● any data you create through the Application, including public wallet addresses;  
● any data related to your use of the Application; 
● any identification data you voluntarily provide when contacting us via the Application (e.g., last 
name, first name, e-mail address, username, etc.); and 
● where applicable, any personal data included in any incident reports or any support requests you 
submit regarding issues encountered using our Application. 
 
Data automatically collected when you use the Application:  
 
We may use tracking technologies to automatically collect data from when you use, access, or otherwise 
interact with the Application. Such data does not reveal your specific identity (such as your name or 
contact information), but may include the following: 
 
● any technical information when accessing and using the Application (e.g., IP address, connection 
data, type of browser used, download errors, diagnostic, crash and performance logs and 
reports, device identifiers, pages accessed, and the duration of the pages’ views, etc.); 
 
● any analytics data (e.g., the IP address of the device you use to access the Application; the type 
of browser software you are using; the operating system you are using; the date and time you 
access the Application; the website address, if any, that linked you to the Application; and any 
other traffic data);  
 
● any personal data about your use of the Application (including, in particular, and depending on 
the case, data related to your use of the Application and how you interact with others using our 
Application, content viewed, features accessed, your status on our Application, such as 
Application launches, taps, clicks, scrolling data, etc.).  
 
Third-Party Services  
 
We may integrate services and technologies from third parties into some features of the Application. For 
example, we employ Cloudflare performance and security infrastructure as a proxy between you and the 
Application’s swap functionality. As a result, when you initiate the swap request, Cloudflare may collect 
your IP address. Please be aware that based on this data collection, your access to our Services may be 
restricted. For more information on the eligibility requirements for using the Application please refer to 
the 1inch Wallet Terms of Service.  
We may also engage third-party service providers to facilitate the delivery of our communications. We 
may also use Beehiiv to distribute newsletters or other updates about the Application, related services, 
and features. For more information on how Beehiiv processes personal data, please refer to Beehiiv 
Privacy Policy. 
Additionally, we use the services of several Remote Procedure Call (RPC) providers, such as QuickNode, 
Fastnode, Aurora Mainnet RPC, and zkSync Era Mainnet, to facilitate swap operations. The selection of 
the RPC provider is preset based on the blockchain network. When you initiate the swap request through 
our Application, the RPC provider usually does not collect your IP address.  
 
However, please note that third-parties may independently collect information. We recommend 
reviewing their privacy policies and associated terms to understand how they collect and process your 
data. We are not responsible for the data protection practices of any third party.  
 
We also use third-party services to help us understand your interactions and preferences on the 
Application. For more information on how we use tracking technologies please refer to Section 7 of this 
Policy (Tracking Technologies).  
 
Blockchain Data 
 
Please note that we are not responsible for (i) your use of Ethereum or any other blockchain and (ii) the 
use of your personal data as processed in these decentralized and permissionless blockchain networks.  
 
Your private key which you utilize to access your Ethereum or other blockchain funds and initiate 
transactions is stored only on your own device. We have no access to and will never ask you for your 
private keys or wallet seed. Never trust anyone or any application that asks you to enter your private 
keys or wallet seed. 
 
You should also be aware that due to the inherent transparency of the blockchain networks, transactions 
that you approve in the Application may be publicly accessible. This includes, but is not limited to, your 
public sending address, the public address of the receiver, the amount sent or received, and any other 
data a user has chosen to include in a given transaction. 
 
Transactions and addresses available on blockchain may reveal personal data about the user’s identity, 
and personal data can potentially be correlated now or in the future by any party who chooses to do so, 
including law enforcement.  
 
In addition, we may process publicly available data, including information obtained through blockchain 
intelligence and analytics services. This may involve analyzing blockchain transactions, wallet addresses, 
and other data accessible on public blockchains or related platforms to enhance the functionality of the 
Application, ensure security, and provide insights into blockchain activities. Certain elements, when 
combined with other information, may reveal your identity.  
 
We encourage you to review how privacy and transparency on the blockchain network work. 
 
3. How and Why We Process Your Personal Data 
 
In the table below, you will find the various purposes for which we may process your personal data and 
the corresponding legal basis. Depending on the circumstances, we use different legal bases to process 
the same personal data for different purposes. 
 
You also have specific rights depending on the legal basis applied. You always have the right to request 
access to, rectification of, or deletion of your personal data. These are detailed in Section 9 of this Policy 
(Your rights). 
 
We process your personal data for the following purposes and on the following legal bases: 
 
Purpose 
 
Legal Basis Categories of Data Concerned 
To provide the Application as well 
as to assess, analyze and improve 
the performance of the 
Application, related services and 
features, and to perform 
maintenance work (e.g., to ensure 
proper functioning of the 
Application, facilitate transactions, 
troubleshoot and correct any 
problems, fix errors, test our new 
features and ensure their proper 
The processing of your personal 
data is based on our legitimate 
interest to optimize our tools 
and solutions and ensure the 
satisfaction of users on our 
Application. 
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data automatically 
collected when you use the 
Application as described 
under Section 2 of this 
Policy. 
functioning, improve user 
experience on the Application, 
conduct surveys and other research 
to determine what you appreciate 
about our Application and what 
can be improved, collect feedback 
on our features and Application, 
produce statistics, etc.).  
 
To manage our contractual 
relationship with you and fulfill our 
contractual obligations when you 
use our Application in accordance 
with the provisions of the 1inch 
Wallet Terms of Service. 
The processing of your personal 
data is based on the necessity 
of contract performance or 
necessity to enter into a 
contract with you (where your 
personal data is required for us 
to perform our undertakings 
and obligations in accordance 
with a contract we are entering 
into with you when you use the 
Application). 
  
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data 
automatically collected 
when you use the 
Application as described 
under Section 2 of this 
Policy. 
To provide customer support  
(e.g., providing information and 
advice regarding the use of the 
Application, investigating incidents, 
etc.). 
The processing of your personal 
data is based on our legitimate 
interest to ensure proper 
communication with the users 
of our Application. 
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data automatically 
collected when you use the 
Application as described 
under Section 2 of this 
Policy. 
 
To provide you with marketing 
communications (e.g. newsletters, 
promotional content, and other 
information that may be of interest 
to you about the Application, 
related services, features, and 
updates, etc.). 
The processing of your personal 
data is based on your consent.  
● personal data you provide 
when using the Website as 
described under Section 2 
of this Policy; 
● personal data automatically 
collected when you use the 
Website as described under 
Section 2 of this Policy. 
 
To manage any potential or actual 
disputes with you or third parties.  
The processing of your personal 
data is based on our legitimate 
interest to defend our interests, 
including through legal 
proceedings. 
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data automatically 
collected when you use the 
Application as described 
under Section 2 of this 
Policy. 
 
To maintain a secured trusted 
environment (e.g., prevention and 
fight against computer fraud 
(spamming, hacking)). 
The processing of your personal 
data is based on our legitimate 
interest to ensure compliance 
with applicable laws, 
compliance with 1inch Wallet 
Terms of Service, prevent fraud, 
improve the security and 
ensure the proper performance 
of our Application. 
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data automatically 
collected when you use the 
Application as described 
under Section 2 of this 
Policy. 
 
To comply with legal and regulatory 
obligations that may apply to us. 
The processing of your personal 
data is necessary for 
compliance with our legal 
obligations (e.g., to answer 
requests from competent 
administrative or judicial 
authorities or data subjects’ 
requests or claims). 
● personal data you provide 
when using the Application 
as described under Section 
2 of this Policy; 
● personal data automatically 
collected when you use the 
Application as described 
under Section 2 of this 
Policy. 
 
 
 
Please note that we will not process your personal data for any purpose that is incompatible with the 
purposes listed above. 
 
4. Sharing Your Personal Data 
 
In the context of processing your personal data in accordance with this Policy, we may communicate 
your personal data to the following recipients, if necessary: 
 
1. our subsidiaries or affiliates (if any) only if necessary for operational purposes; 
2. 1inch Foundation only if necessary for the purposes set out in this Policy, including assistance in 
addressing data subject requests;  
3. service providers, external suppliers, contractors, agents to the extent that they assist us in 
carrying out the purposes set out in this Policy (e.g., analytics and storage service providers to 
assist us in the improvement and optimization of the Application; product engineering providers 
and technical maintenance vendors to ensure proper functioning of the Application; marketing 
and communication providers to promote the use of the Application; compliance and risk 
assessment service providers to comply with applicable laws and regulations and ensure safe 
environment within the Application; etc.); 
4. competent courts, public authorities, government agencies, and law enforcement agencies to 
the extent required by law or if we have a good-faith belief that such disclosure is necessary in 
order to comply with official investigations or legal proceedings initiated by governmental 
and/or law enforcement officials, or private parties, including but not limited to in response to 
subpoenas, search warrants, or court orders; 
5. third parties in connection with a merger, division, restructuring, change of control, bankruptcy, 
or other organizational change;  
6. third parties which may collect your personal data on our Application via tracking technologies; 
or 
7. third-party business partners to assist such partners’ investigations including into known 
cybersecurity breaches or cyber-hacks, or in case of a serious crime that is likely to affect users of 
our Application. In this case, we disclose information only to our trusted business partners based 
on the duration and quality of our business relationship, the reputation and regulatory status of 
the partner, and the requirements of the applicable data protection legal framework. We will 
only communicate your personal data as described under Section 3 of this Policy. 
 
We will only communicate your personal data to any recipient on a need-to-know basis and only when 
the processing by the recipient is strictly limited to the purposes identified in this Policy. We do not sell 
your personal data. 
 
5. Transfer of Personal Data 
 
As we operate globally, we may process your personal data in countries outside the European Economic 
Area (“EEA”). 
 
In these cases, we implement appropriate transfer mechanisms and safeguards to ensure that your 
personal data benefits from a level of protection essentially equivalent to that within the EEA. In 
practice, this means that each of the envisaged transfers is at least based on one of the following 
mechanisms: 
 
● the existence of an adequacy decision issued by the European Commission for the country to 
which your personal data is transferred; or, failing that, 
 
● the conclusion of the European Commission’s Standard Contractual Clauses, combined with 
supplementary technical, contractual, and/or organizational measures where required following 
a transfer impact assessment; or, failing that, 
 
● a specific derogation permitted under Article 49 GDPR. These derogations are applied only in 
exceptional cases, for example where you have explicitly consented to the transfer after being 
informed of the possible risks, or where it is required for the establishment, exercise, or defence 
of legal claims, or where the transfer is necessary for legal requirements or important reasons of 
public interest such as compliance with applicable law obligations or lawful requests from 
government authorities or courts. 
 
Information on the transfer mechanisms and safeguards may be requested by contacting us: please see 
Section 11 of this Policy (Contact us). 
 
6. Data Retention Period 
 
We retain your personal data only for as long as necessary for the purposes for which it has been 
collected, as specified in this Policy, and in accordance with the applicable laws.  
 
This means that the retention periods we apply may vary depending on the purpose for which we 
process your personal data. When determining the appropriate retention period, we take into account 
the category and amount of personal data, potential risks, and harm that may arise from unauthorized 
access or disclosure, the specific purposes for which the data is processed, the availability of alternative 
means to achieve those purposes, and the applicable legal requirements.  
 
We also retain personal data in order to comply with legal and regulatory obligations that may apply to 
us. Sometimes business and legal requirements oblige us to retain certain data, for specific purposes, for 
an extended period of time (e.g., to comply with regulatory and compliance requirements under 
applicable law, or record-keeping obligations imposed by applicable accounting, financial, or regulatory 
laws).  
 
In some situations, we may anonymize personal information about you so that it can no longer be used 
to identify you. In such cases, we can use this information indefinitely without further notice to you.  
 
7. Tracking Technologies  
 
We may use third-party service providers that use tracking technologies to analyse and improve your 
user experience within the Application, in particular, Mixpanel, Branch, Firebase, and Storyly. For more 
information about how these third-parties process your data, please refer to the corresponding policies:  
● Mixpanel Privacy Program; 
● Branch Policies;  
● Firebase;  
● Storyly.  
 
Such services rely on tracking technologies, such as cookies, pixels, plugins, and software development 
kits (SDKs) that can be stored on your devices when you visit the Application, so that it can be accessed 
later. The data collected includes statistical and performance information arising from your use of the 
Application. This type of data will only be used by us in an aggregated or anonymised manner.  
 
You have the option to disable the use of tracking technologies on your device at any time. Your mobile 
settings may provide options that allow you to limit the use of tracking technologies associated with 
your mobile device. Additionally, within our Application, you can navigate to the “Settings” and 
“Language and Permissions” sections to disable tracking technologies. 
 
Additionally, you can choose to disable cookies through your individual browser options. The settings for 
each browser are different. They are described in the help menu of your browser, which will enable you 
to know how to change your cookies preferences. For example:  
 
● in Microsoft Edge please refer here.  
● in Safari please refer here.  
● in Chrome please refer here.  
● in Firefox please refer here.  
● in Opera please refer here.  
 
8. Children’s Data 
The Application is intended for use by individuals who are at least eighteen (18) years old and is not 
directed at children. We do not knowingly collect personal information from children. If you believe that 
such information has been collected in error, please contact us using the details provided in Section 11 of 
this Policy (Contact Us). 
 
9. Your Rights 
 
Your rights associated with the processing of your personal data are outlined below. Please note that 
some of these rights are subject to specific conditions set out in the applicable personal data protection 
regulation. Therefore, if your particular situation does not meet these conditions, we will unfortunately 
not be able to respond to your request. In this case, we will inform you of the reasons for our refusal. 
 
Your rights under the General Data Protection Regulations (“GDPR”) 
 
● Right of access – You may request access to your personal data at any time. If you exercise your 
right of access, we will provide you with a copy of your personal data in our possession as well as 
all information relating to its processing. 
 
● Right of rectification – You have the right to ask us to rectify or complete any personal data in 
our possession that you consider to be inaccurate or incomplete.  
 
● Right to erasure/to be forgotten – You may request deletion of your personal data when it is no 
longer necessary for the purposes for which it was processed. However, if we are required by law 
(for example, compliance or regulatory obligations under applicable law, or ongoing legal or 
investigative proceedings) to retain certain data, we may not be able to erase such data until the 
legal obligation has been satisfied. In such cases, we will inform you of the reason why deletion 
cannot be performed. 
 
● Right to restriction of processing – You may also request that we restrict the processing of your 
personal data on grounds relating to your particular situation. For example, if you dispute the 
accuracy of your personal data or object to the processing of your personal data, you may also 
request that we do not process your personal data for the time necessary to verify and 
investigate your claims.  
 
In such cases, we will temporarily refrain from processing your personal data until necessary 
verifications have been made or until we comply with your requests. 
 
● Right to data portability – You may request portability of the personal data you have provided us 
with. At your request, we will provide you with your personal data in a readable and structured 
format so that you can easily re-use it.  
 
The portability of your personal data applies only to personal data that you have provided to us 
or that result from your activity on our Application, under the condition that the disclosure of 
your personal data does not infringe the rights of third parties. If we are unable to comply with 
your request, we will inform you of the reasons for our refusal.  
 
● Right to object – You may object at any time, on grounds relating to your particular situation, if 
we use your personal data. We will then stop processing your personal data unless there are 
overriding legitimate grounds for continuing to process your personal data (for example, if your 
personal data is necessary for the establishment, exercise, or defence of our rights or the rights 
of third parties in court proceedings). If we are unable to comply with your request to object, we 
will inform you of the reasons for our refusal. You can also object at any time to our processing 
of your personal data for marketing purposes.  
 
● Right to withdraw consent - You have the right to withdraw consent at any time for personal 
data processing based on consent. Withdrawing your consent prevents us from processing your 
personal data but does not affect the lawfulness of the processing carried out before the 
withdrawal.  
 
Your rights under the California Consumer Privacy Act (“CCPA”) 
 
If you are a resident of California, you have specific rights concerning your personal information under 
the California Consumer Privacy Act (“CCPA”). The CCPA provides you with the right to: 
 
● Know the categories and specific pieces of personal information we collect about you, the 
categories of sources from which it is collected (please see Section 2 of this Policy (Categories of 
Data We Process); the purposes for which it is used (please see Section 3 of this Policy (How and 
Why We Process Your Personal Data); and the categories of third parties with whom it is shared 
or disclosed (please see Section 4 of this Policy (Sharing Your Personal Data). 
● Access a copy of the personal information we maintain about you. 
● Correct inaccurate personal information we hold about you. 
● Delete your personal information, subject to certain statutory exceptions. 
● Limit the use and disclosure of sensitive personal information, if applicable. 
● Opt out of the “sale” or “sharing” of your personal information, including for cross-context 
behavioral advertising purposes. Please note that we do not sell your personal information as 
defined under California law. For more details on how we share your data, please refer to 
Section 4 “Sharing Your Personal Data”. 
 
You may also designate an authorized agent to submit requests on your behalf. We will take steps to 
verify your identity, and if applicable, the authority of your agent, before fulfilling any request. 
 
These rights are subject to limitations as described in the relevant law. We may deny your request if we 
need to do so to comply with our legal rights or obligations. We will respond to requests for access, 
correction, or deletion to the extent we can reasonably associate the data we hold with the identifying 
information you provide. If we are unable to comply with your request, we will notify you and explain 
the reasons. 
 
Country Specific Rights: You may also be granted specific rights as regards our processing of your 
personal data depending on the law applicable in the country you are residing in. You may contact us 
should you have any questions in that regard.  
 
Also, keep in mind that many blockchains are open to forensic analysis which can lead to 
deanonymization and the unintentional revelation of personal data, in particular when blockchain data is 
combined with other data. Because blockchains are decentralized or third-party networks that are not 
controlled or operated by us, we cannot erase, modify, or alter your personal data recorded on such 
networks. However, we will take reasonable steps within our control to limit off-chain processing and 
apply measures such as minimization, pseudonymization, or unlinking identifiers, in order to respect 
your data protection rights to the fullest extent possible. 
 
 
10.How to Exercise Your Rights 
 
If you wish to exercise your rights, you may contact us by using the contact information provided in 
Section 11 of this Policy (Contact Us). To be able to process your request efficiently, we may ask you to 
provide additional information to confirm your identity and/or to help us retrieve the personal data 
related to your request. 
If you are a California resident, you may also designate an authorized agent to submit a request on your 
behalf. The agent must present signed written permission from you authorizing them to act on your 
behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper 
authorization and/or verify your identity as the requestor. 
 
If you reside in the EEA, you can lodge a complaint with a data protection authority. You can find a list of 
the relevant supervisory authorities here. However, we encourage you to contact us first, as we are 
committed to addressing any concerns or complaints you may have regarding the processing of your 
personal data promptly and efficiently. 
 
11.Contact Us 
 
If you have any questions regarding the processing of your personal data under this Policy, including the 
exercise of your rights as detailed above, you can contact us by email at [email protected]. 
 
12.Changes to this Privacy Policy 
  
We periodically review this Policy to ensure it is compliant and up to date with applicable data 
protection regulations. We will post updates on this page accordingly. When the changes are made, we 
will update the “Last updated” date at the top of this Policy.  
 
Therefore, we encourage you to review this Policy regularly. Any modifications will take effect when 
posted or on the date specified as the effective date (if any). Your continued access to and use of the 
Application indicates your acknowledgment and acceptance of the updated Privacy Policy.