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Privacy Policy

 

 Last Updated:  October 24, 2025

1. Introduction

Welcome to Cointrol Limited (“Cointrol”, “we”, “our”, “us”).
We are committed to upholding privacy, security, and transparency across all of our platforms — including our QuantumAccount wallet, Paymaster services, Bundler infrastructure, and related websites, APIs, and digital tools (collectively, the “Services”).

Cointrol Limited is a UK-registered company developing post-quantum, non-custodial wallet infrastructure built on Ethereum ERC-4337 Account Abstraction, using Falcon-1024 (Keccak variant) for quantum-resistant digital signatures.

We take privacy seriously. This document explains our policy regarding the collection, use, and protection of information when you interact with our Services.


 

2. Our Approach to Privacy

Cointrol is built on the principle of user sovereignty.
Our architecture is designed so that no personal data is collected, stored, or processed by default.
Your keys, identities, and transactions remain entirely under your control and are managed locally on your device or via your connected wallet.

We will only collect or process data if:

  1. It is legally required (e.g. by financial regulations or compliance obligations), or
     
  2. You have explicitly consented to its collection for a specific purpose (e.g. participation in a token sale, account verification, or support request).
     

When data collection is required, we will:

  • Clearly inform you of what data is being collected and why.
     
  • Request your informed consent before processing.
     
  • Handle data securely and in accordance with applicable privacy laws including the UK GDPR and the Data Protection Act 2018.


 

3. Information We May Collect (If Applicable)

While our Services are designed to operate without collecting personal data, certain interactions may require limited information.
Examples include:


Contact or Support Enquiries

     Name, email address, message content

     To respond to your enquiry


Regulatory Compliance

     Identity verification documents, proof of address

     Only if legally required (e.g. AML/KYC)


Website Analytics (optional, if consented)

     Anonymous usage metrics

     To improve system performance only 


 

4. Smart Contract and Blockchain Data

All on-chain transactions (including UserOperations, Paymaster deposits, and QuantumAccount deployments) are public by design and stored on the Ethereum blockchain or compatible networks.
Such data — wallet addresses, transaction hashes, and smart contract interactions — are immutable and beyond our direct control.

Cointrol does not link any blockchain addresses to real-world identities unless required by regulation and supported by user consent.


 

5. Cookies and Local Storage

Our website may use minimal local storage to maintain functionality (for example, session preferences or authentication tokens).
We do not use tracking cookies, third-party advertising scripts, or analytics platforms that profile users.
Where optional analytics are used (e.g. self-hosted performance metrics), they will be anonymised and clearly disclosed.


 

6. Legal Basis for Processing

Where we are legally required to process data, we do so under one or more of the following lawful bases:

  • Consent: You have clearly agreed to the processing for a specific purpose.
     
  • Legal Obligation: Processing is required to comply with applicable laws (e.g. AML/KYC, taxation, or regulatory reporting).

 

7. Data Security

Security is central to our mission.
We employ post-quantum cryptography (Falcon-1024), end-to-end encryption, and strict access controls for any system components that might process user-submitted data.

When we engage service providers (e.g. cloud hosting, email, or payment gateways), we ensure that they meet or exceed industry security standards and comply with applicable data protection laws.


 

8. Data Retention

We retain information only for as long as necessary to fulfil its intended purpose or to meet legal requirements.
Once the purpose expires, data is securely deleted or anonymised in compliance with GDPR retention guidelines.

Blockchain data cannot be deleted, but we will not associate any personal identifiers with it unless explicitly required by law.


 

9. Your Rights

If you have provided data to us under consent, you retain full rights under the UK GDPR, including the right to:

  • Access your information
     
  • Correct inaccuracies
     
  • Request deletion of your data
     
  • Withdraw consent at any time
     

Requests can be made by contacting us using the details below.


 

10. International Data Transfers

If any data is processed outside the United Kingdom, we will ensure that such transfers are made in compliance with applicable data protection laws and appropriate safeguards.


 

11. Updates to This Policy

We may occasionally update this Privacy Policy to reflect changes in regulation or operational practices.
All updates will be published on our website with a revised “Last Updated” date.


 

12. Contact Information

For questions, requests, or concerns regarding this Privacy Policy, please contact us at:

Cointrol Limited
Registered in the United Kingdom
Email: info@cointrol.co.uk
Address: 21 Tressillian Crescent, London, SE4 1QJ (mail enquiries only)

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