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Privacy Policy

Last Updated: March 2026

Your privacy matters to us. This Privacy Policy explains how Hashtrion Pty Ltd ("Hashtrion", "we", "our", or "us") collects, uses, and protects your personal information when you use the Hashtrion Wallet mobile application (the "Application"). By using the Application, you agree to the practices described in this Policy.

  1. Who We Are

    Hashtrion Pty Ltd is an Australian registered company and the data controller responsible for your personal information collected through the Application.

    If you have any questions about this Privacy Policy or how we handle your personal information, please contact us at:

    Hashtrion Pty Ltd

    Email: support@hashtrion.com

    Website: https://www.hashtrion.com

  2. Information We Collect

    Depending on how you use the Application, we may collect the following types of information:

    a) Information you provide to us

    • Email address (if you contact us for support)
    • Name and contact details (if required for third-party service onboarding)
    • Identity verification documents (KYC data, where required by third-party on-ramp providers)
    • Communications you send to us, including support requests

    b) Information collected automatically

    • Public blockchain wallet addresses generated or used within the Application
    • Country or region you are connecting from
    • Device type and operating system version
    • App usage data and crash reports (for performance and stability purposes)
    • IP address

    c) Information from third parties

    • Identity verification data processed by third-party KYC providers (where you use integrated on-ramp or regulated services)
    • Transaction monitoring data from blockchain analytics providers

    Note: Hashtrion does not store your private keys, recovery phrases, or secret keys. These remain solely on your device and are never transmitted to us.

  3. How We Use Your Information

    We use the information we collect to:

    • Provide, maintain, and improve the Application and its features
    • Respond to your support requests and communications
    • Monitor and ensure the security of the Application
    • Comply with applicable legal and regulatory obligations
    • Detect and prevent fraud, money laundering, or other unlawful activity
    • Analyse usage patterns to improve user experience
    • Send important notices about the Application, including updates to these policies

    We do not use your personal information for advertising purposes and we do not sell your personal information to third parties.

  4. Legal Basis for Processing

    We process your personal information on the following legal bases:

    • Contractual necessity — to provide the Application and its features to you
    • Legitimate interests — to maintain and secure the Application, analyse usage, and prevent fraud
    • Legal obligation — to comply with applicable laws, including anti-money laundering (AML) and counter-terrorism financing (CTF) obligations
    • Consent — where you have provided explicit consent, such as for optional communications
  5. Sharing Your Information

    We do not sell or rent your personal information. We may share your information with the following categories of third parties only where necessary:

    • On-ramp service providers (e.g. MoonPay, Banxa, Transak) — to facilitate fiat-to-crypto purchases you initiate within the Application
    • KYC and identity verification providers — to carry out identity checks required by on-ramp or regulated services
    • Blockchain analytics providers — for transaction monitoring and AML compliance
    • Cloud hosting and infrastructure providers — for Application hosting, storage, and performance monitoring
    • Customer support platforms — to manage and respond to support requests
    • Law enforcement or regulatory authorities — where required by applicable law or valid legal process

    All third-party service providers are required to handle your information securely and in accordance with applicable privacy laws.

  6. Third-Party Services and On-Ramp Providers

    The Application integrates third-party services, including fiat-to-crypto on-ramp providers. When you use these services, you will be subject to their own terms of service and privacy policies.

    These providers may independently collect and process:

    • Identity documents for KYC verification
    • Payment and banking information
    • Transaction history
    • Device and location data

    Hashtrion is not responsible for the privacy practices of third-party providers. We encourage you to review their privacy policies before using their services.

  7. Data Retention

    We retain your personal information only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law.

    • App usage and log data — deleted after 6 weeks unless required for security investigations or legal compliance
    • Support communications — retained for 30 days after resolution, then anonymised for analytical purposes
    • Account and KYC data — retained for up to 5 years after the end of the relevant transaction or relationship, as required by AML obligations
    • Financial and transaction data — retained for up to 7 years where required by applicable financial regulations

    Where we no longer need personal information for its original purpose, we will securely delete or anonymise it.

  8. Data Security

    We implement appropriate technical and organisational measures to protect your personal information against unauthorised access, loss, alteration, or disclosure. These measures include:

    • Encryption of data in transit and at rest
    • Access controls based on least-privilege principles
    • Regular security reviews and monitoring
    • Strict data minimisation practices — we only collect what we need
    • Secure storage of sensitive data on infrastructure not exposed to public networks

    While we take reasonable steps to protect your information, no method of transmission over the internet or electronic storage is completely secure. We cannot guarantee absolute security.

  9. International Data Transfers

    Hashtrion is based in Australia. Your information may be processed or stored in Australia or in other countries where our service providers operate.

    Where we transfer your personal information outside of Australia, we take steps to ensure it receives appropriate protection in accordance with applicable privacy laws, including the Australian Privacy Act 1988.

  10. Cookies and Tracking

    The Application may use limited tracking technologies for crash reporting and performance analytics. These tools help us identify technical issues and improve the stability of the Application.

    We do not use tracking technologies for advertising or cross-app behavioural profiling.

  11. Your Rights

    Depending on your jurisdiction, you may have the following rights regarding your personal information:

    • Access — request a copy of the personal information we hold about you
    • Correction — request that inaccurate or incomplete information be corrected
    • Deletion — request that we delete your personal information, subject to legal retention obligations
    • Restriction — request that we limit how we use your information in certain circumstances
    • Portability — request a copy of your information in a structured, machine-readable format
    • Objection — object to processing based on our legitimate interests, including direct marketing
    • Withdraw consent — where processing is based on consent, you may withdraw it at any time without affecting prior lawful processing

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

  12. Children's Privacy

    The Application is not intended for use by anyone under the age of 18. We do not knowingly collect personal information from minors. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

  13. Changes to This Policy

    We may update this Privacy Policy from time to time. When we make material changes, we will notify you through the Application or by updating the "Last Updated" date at the top of this document.

    Your continued use of the Application after updates are published constitutes your acceptance of the revised Policy. If you do not agree, you must stop using the Application.

  14. Complaints

    If you have a complaint about how we handle your personal information, please contact us first at support@hashtrion.com and we will do our best to resolve your concern.

    If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.

  15. Contact

    For any privacy-related questions or requests, please contact us:

    Hashtrion Pty Ltd

    Email: support@hashtrion.com

    Website: https://www.hashtrion.com

© 2026 Hashtrion Pty Ltd. All rights reserved.