PAI Wallet

Privacy Policy

Effective Date: 27 June 2026

This Privacy Policy explains how PERCEPTION AI FZCO ("PERCEPTION AI", "we", "our", or "us") collects, uses, stores, shares and protects your personal information when you use PAI Wallet, our non-custodial Web3 digital wallet available through our website, mobile applications and other supported platforms.

This Privacy Policy also explains your privacy rights and the choices available to you regarding your personal information. By using PAI Wallet, you acknowledge that you have read this Privacy Policy.

1. Data Controller

PERCEPTION AI FZCO
DMCC Business Centre, Level 12
Unit No. UT-12-CO-180
Uptown Tower, JLT
Dubai, United Arab Emirates
Trade Licence No. DMCC-1002138

2. Scope

This Privacy Policy applies to:

  • PAI Wallet mobile applications;
  • PAI Wallet website;
  • wallet account services;
  • blockchain wallet functionality;
  • customer support;
  • related services provided by PERCEPTION AI FZCO.

It applies to users worldwide.

3. Information We Collect

Depending on how you use PAI Wallet, we may collect the following information.

Information You Provide

You may provide:

  • your name;
  • email address;
  • username;
  • profile information;
  • customer support enquiries;
  • communications with us;
  • feedback;
  • optional account preferences; and
  • other information you voluntarily submit.

You should avoid providing confidential or unnecessary personal information unless required for customer support.

Wallet Information

Depending upon the features you use, we may process information including:

  • public wallet addresses;
  • supported blockchain networks;
  • wallet nicknames;
  • blockchain transaction metadata;
  • token preferences;
  • network preferences;
  • wallet settings; and
  • wallet connection history.

PAI Wallet does not collect, store or have access to your private keys or recovery phrases unless you voluntarily provide them to us during a support request (which we strongly advise against).

You should never disclose your recovery phrase or private keys to anyone.

Blockchain Information

Blockchain networks are public distributed ledgers.

Transactions conducted using PAI Wallet may be permanently recorded on public blockchains.

Blockchain information may include:

  • wallet addresses;
  • transaction hashes;
  • token transfers;
  • smart contract interactions;
  • NFT transfers;
  • staking transactions;
  • validator interactions;
  • gas fees; and
  • blockchain timestamps.

This information is generally publicly accessible and cannot usually be modified or deleted.

Account Information

If you create an account, we may collect:

  • authentication credentials;
  • login information;
  • account preferences;
  • subscription status (where applicable); and
  • purchase history.

Device Information

We may automatically collect:

  • device type;
  • operating system;
  • browser type;
  • application version;
  • language settings;
  • IP address;
  • approximate location derived from IP address;
  • mobile device identifiers;
  • crash reports;
  • diagnostic information; and
  • security logs.

Usage Information

We may collect information regarding:

  • application usage;
  • wallet features used;
  • session information;
  • error logs;
  • performance metrics;
  • security events; and
  • interactions with supported wallet features.

4. Cookies and Tracking Technologies

We use cookies and similar technologies to improve the operation and security of PAI Wallet.

These technologies may include:

  • cookies;
  • local storage;
  • secure device storage;
  • SDKs;
  • analytics technologies;
  • authentication tokens; and
  • device identifiers.

Essential Cookies

These technologies help:

  • operate the Service;
  • authenticate users;
  • maintain security;
  • prevent fraud;
  • remember login sessions; and
  • keep the Wallet functioning correctly.

These technologies are generally required for the operation of the Service.

Functional Cookies

These may remember:

  • language preferences;
  • interface settings;
  • accessibility settings;
  • preferred blockchain networks; and
  • user preferences.

Analytics

Where permitted by applicable law, we may collect analytics information to understand:

  • application performance;
  • feature usage;
  • crash reporting;
  • user engagement; and
  • service improvements.

Analytics information is generally aggregated wherever reasonably possible.

Advertising

PAI Wallet is not intended to use personal information for targeted advertising unless expressly disclosed in the future.

Should this change, this Privacy Policy will be updated accordingly.

Managing Cookies

Most browsers and mobile operating systems allow users to:

  • delete cookies;
  • restrict cookies;
  • manage permissions; and
  • configure privacy preferences.

Disabling certain technologies may affect the functionality of PAI Wallet.

5. How We Use Your Information

We use personal information to:

  • provide PAI Wallet services;
  • authenticate users;
  • maintain wallet functionality;
  • improve user experience;
  • provide customer support;
  • improve security;
  • detect fraud;
  • investigate abuse;
  • monitor performance;
  • comply with legal obligations; and
  • communicate important service information.

We do not sell your personal information.

6. Blockchain Processing

PAI Wallet interacts with public blockchain networks.

When you initiate blockchain transactions, certain information is transmitted to the relevant blockchain network.

Blockchain networks operate independently of PERCEPTION AI.

Because blockchain ledgers are public by design, information recorded on a blockchain may remain publicly accessible indefinitely.

PERCEPTION AI cannot modify, erase or delete information that has been permanently recorded on a blockchain.

Wallet addresses, transaction hashes and certain blockchain activity may therefore remain publicly visible even if you later delete your account or uninstall PAI Wallet.

7. Private Keys and Recovery Phrases

PAI Wallet is a non-custodial wallet.

Your private keys and recovery phrase are generated and stored under your control.

PERCEPTION AI does not ordinarily collect, possess or have access to:

  • private keys;
  • recovery phrases;
  • wallet passwords; or
  • biometric authentication information used to unlock your device.

If you voluntarily disclose this information to customer support despite our warnings not to do so, we will use reasonable efforts to protect it but cannot guarantee its confidentiality.

Users should never send recovery phrases or private keys to PERCEPTION AI or any third party.

8. Legal Bases for Processing

Where required by applicable law, we process personal information on one or more of the following legal bases:

  • your consent;
  • performance of a contract;
  • compliance with legal obligations;
  • legitimate business interests;
  • protection of vital interests; or
  • other lawful bases permitted by applicable law.

9. Sharing Information

We do not sell your personal information.

We may share information with:

  • cloud infrastructure providers;
  • hosting providers;
  • authentication providers;
  • blockchain infrastructure providers;
  • node operators;
  • RPC providers;
  • payment processors where applicable;
  • analytics providers;
  • customer support providers;
  • professional advisers;
  • auditors;
  • regulators; and
  • law enforcement authorities where legally required.

All service providers are required to protect personal information in accordance with applicable contractual and legal obligations.

10. International Data Transfers

PAI Wallet is a global service.

Your personal information may be processed or accessed in countries outside your country of residence.

Where required by applicable law, we implement appropriate safeguards for international data transfers.

11. Data Retention

We retain personal information only for as long as reasonably necessary to:

  • provide the Service;
  • comply with legal obligations;
  • resolve disputes;
  • enforce agreements;
  • maintain security;
  • investigate abuse; and
  • satisfy regulatory requirements.

Certain blockchain information cannot be deleted because it is permanently stored on public blockchain networks that are outside our control.

12. Data Security

We implement reasonable technical and organisational measures designed to protect personal information, including:

  • encryption where appropriate;
  • authentication controls;
  • secure infrastructure;
  • access controls;
  • monitoring;
  • incident response procedures;
  • regular software updates; and
  • security testing where appropriate.

However, no method of internet transmission or electronic storage can be guaranteed to be completely secure.

Users remain responsible for securing:

  • their devices;
  • passwords;
  • recovery phrases;
  • private keys; and
  • wallet backups.

13. Children's Privacy

PAI Wallet is not intended for children below the minimum legal age required to use the Service independently under applicable law.

We do not knowingly collect personal information from children in violation of applicable laws.

If we become aware that such information has been collected, we will take reasonable steps to delete it.

Parents or guardians who believe a child has provided personal information may contact us.

14. Your Privacy Rights

Depending on your jurisdiction, you may have rights including:

  • access to your personal information;
  • correction of inaccurate information;
  • deletion of personal information where legally possible;
  • restriction of processing;
  • objection to certain processing;
  • withdrawal of consent;
  • portability of personal information; and
  • the right to lodge a complaint with an appropriate supervisory authority.

These rights may be subject to legal limitations, particularly where blockchain records cannot be modified or deleted.

Requests may be submitted to: support@paicloud.ai

15. Third-Party Services

PAI Wallet may interact with independent third-party services including:

  • blockchain networks;
  • node providers;
  • RPC providers;
  • decentralised applications;
  • smart contracts;
  • NFT marketplaces;
  • staking providers;
  • blockchain bridges; and
  • other Web3 infrastructure.

These services operate independently of PERCEPTION AI.

We are not responsible for their privacy practices, security measures or data handling.

Users should review the privacy policies of any third-party services they choose to use.

16. Security Incidents

If we become aware of a personal data breach requiring notification under applicable law, we will notify affected individuals and relevant supervisory authorities where legally required.

Where appropriate, we may also take steps to mitigate the impact of any security incident and improve our security measures.

17. Compliance with Financial Crime Laws

Although PAI Wallet is a non-custodial wallet, we reserve the right to comply with applicable laws relating to:

  • anti-money laundering;
  • counter-terrorist financing;
  • sanctions compliance;
  • fraud prevention;
  • financial crime investigations; and
  • lawful requests from competent governmental or regulatory authorities.

Where legally required, we may disclose personal information to regulators or law enforcement agencies.

Nothing in this Privacy Policy requires PERCEPTION AI to monitor blockchain transactions or identify wallet owners beyond our legal obligations.

18. Blockchain Analytics

To improve security, prevent fraud and comply with applicable legal obligations, PAI Wallet may use blockchain analytics or transaction monitoring services provided by independent third parties.

These services may analyse publicly available blockchain information including:

  • wallet addresses;
  • transaction histories;
  • blockchain interactions;
  • sanctions screening;
  • fraud indicators; and
  • blockchain risk scoring.

These analyses relate primarily to publicly available blockchain information and are used solely for legitimate security, compliance and operational purposes.

19. Changes to this Privacy Policy

We may update this Privacy Policy from time to time.

Where material changes are made, we will publish an updated version together with a revised Effective Date.

Continued use of PAI Wallet after changes become effective constitutes acceptance of the updated Privacy Policy to the extent permitted by applicable law.

20. Governing Law

This Privacy Policy shall be interpreted together with the International Privacy Addendum and, except where mandatory local privacy laws provide otherwise, shall be governed by the laws applicable to PERCEPTION AI FZCO in the United Arab Emirates.

Nothing in this Privacy Policy limits or excludes any mandatory rights provided to individuals under applicable data protection legislation.

21. Contact Us

If you have any questions regarding this Privacy Policy or your personal information, please contact:

Email: info@paicloud.ai
Email: support@paicloud.ai
Email: contact@paicloud.ai

22. Summary

In summary, we aim to:

  • collect only the information reasonably necessary to provide PAI Wallet;
  • protect personal information using appropriate technical and organisational security measures;
  • respect applicable privacy laws wherever our users are located;
  • remain transparent about how information is processed;
  • minimise the personal information we collect wherever reasonably possible;
  • never intentionally collect your private keys or recovery phrases during normal use of PAI Wallet;
  • acknowledge that blockchain records are generally permanent and publicly accessible; and
  • provide users with reasonable control over their personal information wherever technically and legally possible.

Thank you for trusting PAI Wallet.

Addendum

International Privacy Addendum

This International Privacy Addendum supplements the PAI Wallet Privacy Policy and applies to users located in jurisdictions with specific privacy laws, including the European Union (EU), United Kingdom (UK), United States (California), United Arab Emirates (UAE), and other jurisdictions with applicable data protection legislation.

If there is any conflict between this Addendum and the Privacy Policy, this Addendum shall prevail to the extent required by applicable law.

1. International Data Transfers

PAI Wallet is a global service.

Your personal information may be processed, stored or accessed in countries outside your country of residence.

Where required by applicable law, we implement appropriate contractual, technical and organisational safeguards for international transfers.

2. European Union (GDPR)

If you are located within the European Economic Area, your personal information is processed in accordance with the EU General Data Protection Regulation ("GDPR").

Where required, we rely upon one or more lawful bases for processing, including:

  • your consent;
  • performance of a contract;
  • compliance with legal obligations;
  • legitimate interests that are not overridden by your rights; and
  • protection of vital interests.

GDPR Rights

Subject to applicable law, you may request:

  • access to your personal information;
  • correction of inaccurate information;
  • deletion of personal information where legally possible;
  • restriction of processing;
  • objection to processing;
  • withdrawal of consent;
  • portability of your information;
  • objection to automated decision-making where applicable; and
  • the right to lodge a complaint with your local supervisory authority.

Please note that blockchain information permanently recorded on public blockchains cannot generally be modified or deleted by PERCEPTION AI.

3. United Kingdom (UK GDPR)

If you are located in the United Kingdom, your personal information is processed in accordance with the UK General Data Protection Regulation and the UK Data Protection Act 2018.

UK users generally have the same privacy rights described above for users located within the European Union.

Complaints may also be submitted to the appropriate UK supervisory authority where applicable.

4. California Privacy Rights (CCPA / CPRA)

If you are a California resident, you may have rights under the California Consumer Privacy Act ("CCPA"), as amended by the California Privacy Rights Act ("CPRA").

Subject to applicable law, you may request:

  • access to personal information collected about you;
  • deletion of personal information;
  • correction of inaccurate personal information;
  • information regarding the categories of personal information collected;
  • information regarding the categories of third parties receiving personal information;
  • limitation of certain uses of sensitive personal information where applicable; and
  • freedom from discrimination for exercising your privacy rights.

PERCEPTION AI FZCO does not sell personal information as defined under the CCPA.

We also do not knowingly share personal information for cross-context behavioural advertising unless expressly disclosed.

5. UAE Personal Data Protection Law (PDPL)

If you are located within the United Arab Emirates, your personal information is processed in accordance with applicable UAE data protection legislation, including Federal Decree-Law No. 45 of 2021 concerning the Protection of Personal Data ("PDPL"), where applicable.

Subject to applicable law, users may request:

  • access to personal information;
  • correction of inaccurate information;
  • deletion of personal information where legally applicable;
  • restriction of processing;
  • transfer of personal information where legally applicable; and
  • withdrawal of consent where consent is the legal basis for processing.

6. Blockchain Data and Privacy Rights

Public blockchain networks differ from traditional databases.

Transactions executed through PAI Wallet may become permanently recorded on distributed public ledgers that are operated independently of PERCEPTION AI.

Accordingly:

  • blockchain records generally cannot be amended or deleted;
  • blockchain transaction histories may remain permanently accessible;
  • wallet addresses may become publicly associated with transaction activity;
  • PERCEPTION AI cannot modify information stored on public blockchains; and
  • certain privacy rights, including deletion or rectification, may not be technically possible in relation to information permanently recorded on blockchain networks.

Nothing in this Addendum should be interpreted as granting PERCEPTION AI technical control over blockchain records.

7. Apple App Store Privacy Information

Where PAI Wallet is distributed through Apple's App Store:

  • personal information is collected only for the purposes described in this Privacy Policy;
  • optional permissions may be managed through Apple device settings;
  • users may withdraw optional permissions at any time through device settings;
  • Apple may independently collect information in accordance with Apple's own privacy policies; and
  • PERCEPTION AI is responsible only for information collected directly through PAI Wallet.

8. Google Play Privacy Information

Where PAI Wallet is distributed through Google Play:

  • Android permissions are requested only where reasonably necessary for application functionality;
  • users may manage permissions through Android system settings;
  • Google may independently collect information under Google's own privacy policies; and
  • PERCEPTION AI is responsible only for information collected directly through PAI Wallet.

9. Security Measures

We maintain reasonable administrative, technical and organisational safeguards appropriate to the nature of the personal information processed, including:

  • encryption where appropriate;
  • authentication controls;
  • secure cloud infrastructure;
  • access controls;
  • security monitoring;
  • software updates;
  • incident response procedures; and
  • periodic security reviews where appropriate.

Although we strive to protect personal information, no security measure can guarantee absolute protection.

Users remain solely responsible for protecting their own:

  • devices;
  • passwords;
  • wallet credentials;
  • recovery phrases; and
  • private keys.

10. Children's Privacy

PAI Wallet is not directed to children who are below the minimum legal age required to use the Service independently under applicable law.

We do not knowingly collect personal information from children in violation of applicable legal requirements.

If we become aware that personal information has been collected from a child in violation of applicable law, we will take reasonable steps to delete such information.

Parents or legal guardians who believe that a child has provided personal information may contact us using the details provided in this Privacy Policy.

11. Blockchain Infrastructure Providers

To provide PAI Wallet services, we may utilise independent third-party blockchain infrastructure providers, including:

  • Remote Procedure Call (RPC) providers;
  • blockchain node operators;
  • blockchain indexing services;
  • cloud infrastructure providers;
  • security providers;
  • analytics providers; and
  • other technology providers reasonably necessary to operate the Service.

These providers may process limited technical information necessary to facilitate your connection to supported blockchain networks.

PERCEPTION AI does not control the independent operation of blockchain networks or public distributed ledgers.

12. Data Minimisation

We are committed to collecting only the personal information reasonably necessary to provide, maintain, secure and improve PAI Wallet.

Where reasonably possible, we seek to minimise the collection of personal information through technical design and operational processes.

Because PAI Wallet is a non-custodial wallet, we intentionally avoid collecting information that is unnecessary for the operation of the Service.

13. User Responsibilities

You are responsible for protecting your own privacy when using blockchain technology.

In particular, you should:

  • never disclose your recovery phrase;
  • never disclose your private keys;
  • verify wallet addresses before sending assets;
  • carefully review permissions granted to decentralised applications;
  • maintain appropriate device security;
  • use strong passwords and authentication methods;
  • keep your software updated; and
  • remain vigilant against phishing attacks and fraudulent websites.

PERCEPTION AI cannot protect information that you voluntarily disclose to third parties or publish on public blockchain networks.

14. Data Accuracy

We make reasonable efforts to ensure that personal information we process is accurate and, where necessary, kept up to date.

Users are responsible for notifying us of any material inaccuracies in account information.

Blockchain records themselves are maintained by decentralised blockchain networks and cannot be corrected or amended by PERCEPTION AI.

15. Changes to this International Privacy Addendum

We may update this International Privacy Addendum from time to time.

Updated versions will be published together with a revised Effective Date.

Your continued use of PAI Wallet after updated versions become effective constitutes acceptance of the revised Addendum to the extent permitted by applicable law.