Privacy Policy

1. Who We Are

Morsands Wallet is a trading name of Brazhelp Solutions Ltd, a company registered in England and Wales (Company No. 13259174), with registered office at 124 City Road, London, EC1V 2NX, United Kingdom.

We operate a non-custodial, self-custody digital asset wallet application ("the App") available on iOS and Android. For the purposes of UK data protection law, Brazhelp Solutions Ltd is the data controller.

If you have any questions about this policy or how we handle your data, please contact us at: privacy@morsands.com

2. What Data We Collect

2.1 Data You Provide Directly

• Email address (if you contact our support desk or register for updates)
• Name and contact details (if you submit a contact or onboarding form)
• Wallet addresses (only if you voluntarily share them with us for support purposes)

2.2 Data Collected Automatically

• Device type, operating system version, and app version
• Crash reports and error logs (anonymised, used for technical diagnostics only)
• General usage analytics (e.g., feature engagement, session duration — no personally identifiable information)
• IP address (collected by our hosting infrastructure; not stored or linked to user profiles)

2.3 Data We Do Not Collect

• Private keys or seed phrases — never transmitted to our servers
• Transaction history — processed on-chain; we have no access
• Biometric data — Face ID / fingerprint authentication is handled entirely by your device OS
• Payment card data — card issuance is handled by our regulated card partner; we do not store card numbers

3. How We Use Your Data

We process personal data only where we have a lawful basis to do so under UK GDPR. The purposes and corresponding lawful bases are as follows:

• Providing the App and support services — Contractual necessity (Article 6(1)(b))
• Responding to enquiries and support requests — Legitimate interests (Article 6(1)(f))
• Improving app performance and fixing bugs — Legitimate interests (Article 6(1)(f))
• Sending service-related communications — Contractual necessity or legitimate interests
• Complying with legal obligations — Legal obligation (Article 6(1)(c))
• Marketing communications — Consent (Article 6(1)(a)), where you have opted in

4. Third-Party Services

The App integrates with the following third-party services, each of which has its own privacy policy:

• Transak — Fiat on/off-ramp provider. Handles KYC and payment processing. Subject to their own data controller obligations.
• Gnosis Pay / Card Partner — Card issuance and transaction processing. Regulated financial institution.
• PIX (Brazil) — Instant payment infrastructure operated by Banco Central do Brasil. No personal data is shared with us through PIX transactions.
• Blockchain Networks — Transactions are broadcast to public blockchains (Ethereum, Bitcoin, etc.). On-chain data is public by nature.
• Firebase / Crash Reporting — Anonymised crash diagnostics. No personally identifiable data is transmitted.

We do not sell, rent, or trade your personal data to any third party for marketing purposes.

5. Data Retention

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law:

• Support correspondence: retained for 2 years from the date of last contact
• Legal and compliance records: retained for 6 years in accordance with UK statutory requirements
• Anonymised analytics: retained indefinitely (no personal data)

When data is no longer required, it is securely deleted or anonymised.

6. Your Rights Under UK GDPR

As a data subject, you have the following rights:

• Right of access — Request a copy of the personal data we hold about you
• Right to rectification — Request correction of inaccurate or incomplete data
• Right to erasure — Request deletion of your personal data ("right to be forgotten")
• Right to restriction — Request that we restrict processing of your data
• Right to data portability — Receive your data in a structured, machine-readable format
• Right to object — Object to processing based on legitimate interests or for direct marketing
• Right to withdraw consent — Where processing is based on consent, you may withdraw it at any time

To exercise any of these rights, contact us at privacy@morsands.com. We will respond within 30 days. You also have the right to lodge a complaint with the Information Commissioner's Office (ICO).

7. International Transfers

Where personal data is transferred outside the United Kingdom, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the ICO, or transfers to countries with an adequacy decision.

8. Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, destruction, or alteration. These include encrypted communications (TLS), access controls, and regular security reviews. However, no system is entirely infallible, and we encourage users to maintain strong device security practices.

9. Children's Privacy

Morsands Wallet is not directed at individuals under the age of 18. We do not knowingly collect personal data from minors. If you believe a minor has provided us with personal data, please contact us immediately at privacy@morsands.com and we will take steps to delete it.

10. Cookies and Tracking

The Morsands mobile application does not use cookies. Our website (morsands.com) may use essential cookies to ensure proper functionality. We do not use third-party advertising or tracking cookies on our website. A separate cookie notice is available on the website where applicable.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable law. The "Last updated" date at the top of this page will be revised accordingly. Material changes will be communicated via in-app notification or email where we hold your contact details.

12. Contact Us

For any privacy-related queries, requests, or complaints:

• Email: privacy@morsands.com
• Post: Brazhelp Solutions Ltd, 124 City Road, London, EC1V 2NX, United Kingdom
• Website: www.morsands.com