Last updated: June 23, 2026
This Privacy Policy explains how Gem Wallet LLC (“we”, “us” or “our”) handles information in connection with our website at gemwallet.com (the “Site”) and our mobile applications (the “App”), together with related products and services (collectively, the “Services”). It applies to all versions of the Services, whether accessed through our Site or through any app store or distribution channel.
Our core principle is simple: we are built around self-custody and zero tracking. We do not collect personal data that identifies you, other than limited technical data such as IP addresses as described below, and we do not link that information to your identity.
Our Core Privacy Principle
Gem Wallet is self-custodial software. We do not receive, hold, or have access to your private keys, your Secret Phrase (seed phrase), or your wallet password. These are generated and stored only on your own device and never leave it. We cannot access your funds and cannot recover your keys or Secret Phrase for you.
We do not collect personal data such as your name, email address (except where you voluntarily provide it, as described below), phone number, or physical address, and we never link the technical information we process to your identity. We do not embed any analytics or advertising tracking inside the App.
Information We Collect
We keep data collection to the minimum required to operate the Services.
On Our Website
The Site uses only the following:
- Plausible Analytics — a privacy-friendly, cookieless analytics tool that measures aggregate, anonymous usage of the Site. It does not use cookies, does not collect personal data, and does not track you across other websites.
- Cloudflare — our DNS, CDN, and security provider. It processes technical request data, including IP addresses, to deliver and protect the Site, and may set strictly necessary security cookies.
We do not use Google Analytics, advertising pixels, social media trackers, or similar tools on the Site.
In Our Mobile App
The App is built around a “zero tracking” approach. There is no analytics or advertising SDK in the App. We collect or process only the following:
- Push notification tokens (optional). Push notifications are off by default and require you to opt in; you can disable them at any time. On Android (Google Play version), push notifications are delivered through Firebase Cloud Messaging (FCM), which means your push token is processed by Google. The F-Droid and Huawei versions do not include FCM. On iOS, push notifications use Apple’s native APNs, with no third-party SDK.
- IP address. When the App communicates with our backend/API and nodes, our API receives your IP address. We use it to: (i) pass it to fiat providers where required for their own KYC/compliance when you buy crypto; (ii) perform anti-fraud checks for our referral system; and (iii) apply rate-limiting (for example, when creating a username). IP data is held only transiently and is not stored permanently.
- Diagnostic information. We do not use any crash-reporting or analytics SDK (no Firebase Analytics, Sentry, Bugsnag, or similar). On Android, Firebase analytics collection is explicitly disabled. Diagnostic information is limited to our own server-side logs, and only when an error reaches our API.
If you choose to use a custom RPC node or connect to third-party services via WalletConnect, your related data (such as your IP address and requests) is handled by those third parties, outside our control.
Information You Provide Voluntarily
You can use the Services without giving us personal information. You may choose to provide an email address — for example, to sign up for beta versions, or when you contact support. Providing it is entirely optional and at your discretion; you can contact support without sharing personal details beyond what you choose. We keep any information you share with support only for as long as necessary to respond to and resolve your request.
Information We Do Not Collect
To be explicit, we do not:
- collect, receive, or store your private keys, Secret Phrase, or wallet password;
- collect personal identity data (name, phone number, address) or require an email to use the Services;
- link the technical data we process to your identity;
- run analytics or advertising tracking inside the App; or
- sell your data to anyone.
Third-Party Services
The Services let you access independent third parties, who operate under their own terms and privacy policies. They may collect information (including personal and KYC data) directly from you, which we do not receive, process, or store:
- Fiat on/off-ramp providers (for buying or selling crypto with a card) — such as MoonPay, Paybis, Banxa, Mercuryo, and others. These providers may collect identity, payment, and KYC information directly from you in order to provide their service and comply with applicable law.
- Swap / DEX providers — such as THORChain, PancakeSwap, Jupiter, Uniswap, Chainflip, Maya Protocol, Across, and others.
- WalletConnect — used to connect to decentralized applications.
- Infrastructure providers — Cloudflare (Site delivery and security), Google (Firebase Cloud Messaging for Android push), and Apple (APNs for iOS push).
- Anti-fraud / security services — used to check IP addresses for fraud and abuse prevention.
We encourage you to review the privacy policies of any third party before using their service. We are not responsible for the privacy practices of third parties.
How We Use Information
We use the limited information described above only to:
- provide, operate, and maintain the Site and App;
- deliver push notifications that you have opted into;
- detect, prevent, and address bugs, security issues, fraud, and abuse;
- pass your IP address to fiat providers where required for their compliance, and otherwise comply with applicable law; and
- respond to and resolve your support requests as quickly and accurately as possible (using only the information you voluntarily provide).
Cookies and Tracking
We do not use cookies for analytics or advertising. Our website analytics tool (Plausible) is cookieless, and the App does not use cookies. The only cookies that may be set are strictly necessary security cookies used by Cloudflare to protect and deliver the Site. Because we do not track you, we do not act on browser “Do Not Track” signals in any other way.
Data Retention and Security
We practice data minimization: we collect as little as possible and retain technical data such as IP addresses only transiently, rather than permanently.
Wallet data stored on your device is protected using advanced, industry-standard security and encryption technologies, together with your device’s security (such as biometric authentication or passcode). Our Services have undergone independent security audits, and as an open-source project we are committed to the ongoing security and transparency of our software. Despite these measures, no method of transmission or storage is completely secure, and you are responsible for keeping your device, password, and Secret Phrase secure.
Your Rights
Because we do not collect personal data and do not link the information we process to your identity, in most cases there is no personal information for us to access, correct, or delete. Where you have voluntarily provided information (for example, an email address when contacting support), you may request access to, correction of, or deletion of that information by contacting us at [email protected]. Depending on your location, you may have additional rights under applicable data protection laws (such as the GDPR or CCPA); we will honor such rights to the extent they apply.
Children
The Services are not directed to or intended for children. You must be at least 18 years old to use the Services under our Terms of Service. We do not knowingly collect personal information from children under 13, and if we learn that we have done so, we will delete it.
Changes to This Policy
We may update this Privacy Policy from time to time. If we make material changes, we will post the updated Policy on the Site and update the “Last updated” date above. Your continued use of the Services after changes take effect means you accept the updated Policy.
Contact Us
If you have any questions about this Privacy Policy or our privacy practices, or would like to make a request or complaint, please contact us at [email protected].
Gem Wallet LLC
Reg No.: 2325666
Shams Business Center, Sharjah Media City Free Zone, Al Messaned, Sharjah, UAE