Privacy Policy

Last updated: 20.10.2026

Our Privacy Policy covers all personal data that you submit to us or that we obtain from you when you use our Website or the Services or the mobile application Guarda: Crypto Bitcoin Wallet (the “Mobile Application”).

The Services may be provided by GUARDACO LDA and/or GUARDIUM LTD, as specified in our Terms of Service. For the purposes of the Mobile Application, the developer name is GUARDACO LDA.

The Company respects your privacy and values its importance, and is wholly committed to keeping your information safe and secure. We process your personal data in accordance with privacy laws and this Privacy Policy to make sure your data protection rights are implemented and enforceable. We have implemented different technical and organizational solutions to comply with applicable legislation related to the processing of personal data, privacy, and data security in countries where we operate or where the applicable law applies to us. The Privacy Policy sets forth the basic rules and principles by which we process your personal data, and mentions our responsibilities while processing your personal data according to transparency obligations.

We do not intend to collect personal data of children or persons under the age of 18 (eighteen) years old.

Accordingly, the purpose of this Policy is to set out the basis on which we will process your Personal data when:

• You visit and use any page of our Website Platform, regardless of where you visit or use it from;
• You apply for, receive, pay and/or use any of our Services or the Mobile Application;
• You communicate with us or leave a query;
• You subscribe to our newsletters/updates;
  
• You submit information through a career form;
  
• You access third-party services through our Website or the Mobile Application; and
  
• We measure or analyze the Website’s or Mobile Application’s traffic.
  

• Your contact information, such as your email address, when you subscribe to our newsletters/updates or contact us;
• Information you submit through a career form, such as your name, email address, country and position of interest;
• Data that identifies you or your device such as your IP address, language, country, browser type and version, time zone setting, device information, operating system and version, application version, cookies, approximate location information and similar technical information;
• Data on how you use the Website or Mobile Application such as your URL clickstreams (the path you take through the Website), page response times, download errors, how long you stay on web pages or app screens, what you do on those pages or screens, how often, and other actions;
• other personal data you share with us or personal data that we may legally obtain from some sources.

Please note that Guarda is a non-custodial wallet. We do not store your private keys, backup files or passwords on our servers. You do not need to provide standard identification information, such as your full name, residential address or identification documents, to create and use the basic wallet functionality.

Please note that we do not store your credit card information and KYC documents you submit for identification purposes; such information is processed by the relevant third-party providers under their own privacy policies. Guarda does not have access to personal data that you enter directly on the side of such third-party providers, unless otherwise required for a specific service flow.

We do not ask you to provide any sensitive personal data, including special categories of personal data as defined under applicable data protection laws, and you should not submit such data to us. If you provide such data voluntarily, we may delete it or process it only to the extent necessary for the relevant purpose and as permitted by applicable law. We do not use solely automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. The recipients of the collected data may include:

1. Authorized personnel of our Company for whom it is necessary to process personal data for the functionality of the Company and the Services; and
2. Third-party service providers where necessary for the purposes described in this Privacy Policy.

• Third-party providers involved in purchase, payment, exchange or KYC/AML verification or similar service flows;
• Authentication, communication and technical service providers, where applicable;
• Analytics and application performance providers, such as Google Analytics and Firebase;
• Newsletter service providers, such as MailerLite;
• Hosting, infrastructure, security and technical service providers;
• Communication, support and business service providers;
• Others.

Where you use third-party services through Guarda, such third-party services are provided by independent third-party providers under their own terms and privacy policies.

The Website and Mobile Application may contain links to third-party sites or provide access to third-party services or interfaces. This Privacy Policy does not cover the privacy practices of such third parties. These third parties have their own privacy policies and we do not accept any responsibility or liability for their sites, services, interfaces, features or policies. Please read their privacy policies before you submit any data to them.

There are legal grounds necessary for the processing of personal data and we count on them to process your personal data. When we process personal data, we have obligations according to the applicable laws. We act as a data controller when we determine the purposes and means of the processing of your personal data. We use the main four grounds to process your personal data: consent, contract, legal obligation, and legitimate interests.

Consent – the freely given, informed, and unambiguous indication of your wishes to the processing of your personal data for a specific purpose which signifies agreement to the processing of personal data.

Contract – a legal ground for the processing of your personal data necessary for us to perform a contract or terms and conditions to which you are a party or in order to take steps at your request prior to entering into the contract or terms and conditions.

Legal obligations – a legal ground for the processing of your personal data when it is necessary for compliance with a legal obligation to which we are subject;

Legitimate Interests – a legal ground for the processing of your personal data when it is based on our legitimate interests or the legitimate interests of a third party, provided that those interests are not outweighed by your rights and interests and those interests have a specific purpose, they are necessary, and they are balanced.

We may share your personal information with service providers listed above, including for the purpose of conducting audits or compliance checks related to our or their business operations. We require our partners to maintain the confidentiality and security of your personal information and use it only for the specific purpose for which it was shared.

We may record, monitor, or otherwise share communications between you and our support team for the purpose of quality control, training, improving our services and our service providers’ audit. By contacting our support team, you consent to our recording and monitoring of these communications and the potential sharing of information with our service providers.

• You have the right to access information about you, especially:
  • The categories of data;
  • The purposes of data processing;
  • Third parties to whom the data disclosed;
  • How long the data will be retained and the criteria used to determine that period;
  • Other rights regarding the use of your data.
  • The right to access information may be performed only by you or your legal representative. In case if you request the right to access information via a legal representative, you have to provide proof of whether such a person may represent you.
• You have the right to make us correct any inaccurate personal data about you.
• You can object to using your personal data for profiling you or making automated decisions about you. We may use your data to determine whether we should let you know the information that might be relevant to you.
• You have the right to the data portability of your data to another service or website. We will give you a copy of your data in a readable format so that you can provide it to another service. If you ask us and it is technically possible, we will directly transfer the data to the other service for you.
• You have the right to be “forgotten”. You may ask us to erase any personal data about you if it is no longer necessary for us to store the data for purposes of your use of the Website. Please note that we cannot grant this request if the data was collected for regulatory purposes for example AML/CFT purposes.
• You have the right to lodge a complaint regarding the use of your data by us.

We store personal data as long as we need it and the retention practice depends on the type of data we collect, applicable regulatory requirements, and how we use the personal data.

The retention period is based on criteria that include legally mandated retention periods, pending or potential litigation, tax and accounting laws, intellectual property or ownership rights, contract requirements, operational directives or needs, compliance requirements, security purposes, support needs and historical archiving.

Technical, application and limited operation-related data may be processed or temporarily retained for as long as necessary to operate, secure, troubleshoot, analyze and improve the Website and Mobile Application, provide support, and interact with relevant third-party providers.

Newsletter data is retained until you unsubscribe or otherwise withdraw your consent.

Career form data is retained for recruitment and related communication purposes.

In some circumstances, we may anonymize your personal data for research or statistical purposes in which case we may use this information indefinitely without further notice to you. Where required or permitted by applicable law, we may retain certain personal data for a longer period.

KYC/AML data submitted directly to third-party providers is processed and retained by such third-party providers under their own privacy policies and retention rules.

We have appropriate technical, security and organizational measures and procedures to secure the personal data we process and to prevent it from being accidentally lost, used, altered, disclosed, or accessed without authorization. We allow disclosure of your personal data only to authorized personnel and service providers who have a business need to know such data. They are required to process personal data confidentially and, where applicable, in accordance with our instructions.

You acknowledge that no data transmission is guaranteed to be 100% secure and there may be risks. You are responsible for keeping your access credentials, passwords, backup files and other security information safe and confidential.

If you have any questions about the Privacy Policy, your personal data, or you would like to exercise any of your data protection rights, please use the following contact information of the Company. All privacy-related inquiries can be sent to the following email: [email protected].

The Services may be provided by GUARDACO LDA (legal entity ID - 516458965), whose registered office address is Rua Latino Coelho, 87, 1050-134 Lisboa, Portugal, and/or GUARDIUM LTD (legal entity ID - 2182646), whose registered office address is Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands, as specified in the Terms of Service.

For the purposes of the Mobile Application, the developer name is GUARDACO LDA.

For career-related inquiries or career form submissions, you may contact us at [email protected].