Privacy Policy

Last updated: July 15, 2026

This Privacy Policy explains how the RealX team ("RealX," "we," "us," or "our") collects, uses, and shares information in connection with the RealX mobile application, website, and related services (collectively, the "Services"). By using the Services, you agree to the practices described in this Policy.

Key point up front: RealX is a non-custodial wallet. We never collect, store, request, or have access to your private keys or seed phrase. Anyone who asks you for your seed phrase is trying to steal from you — we will never do so.

1. Information We Do NOT Collect

We do not collect, store, or have access to:

• Your private keys or seed phrase / recovery phrase;
• Your device passcode or biometric data (these are handled by your device's operating system);
• Custody of your assets or funds.

2. Information We Collect

a) Information you provide.

• Account sign-in identifier. If you sign in using a third-party provider (such as Google or Apple), we may receive a basic identifier such as your email address or a provider-issued user ID, used to help you access your wallet across devices.
• Communications. Information you provide when you contact support or otherwise communicate with us.
• Referral / invite code. If you enter or are attributed a referral code, we associate it with your wallet.

b) Information collected automatically.

• Public wallet addresses and on-chain activity. Your public blockchain addresses and the transactions associated with them. Note: blockchain data is inherently public and is recorded on public ledgers we do not control.
• Device and technical information. Device type, operating system, app version, language, and similar technical data.
• Approximate location / IP address. We may process your IP address and derived approximate location to provide the Services, enforce geographic restrictions, and detect fraud.
• Usage information. How you interact with the Services (screens viewed, features used, and similar analytics).
• Attribution / install information. Where permitted, information used to attribute app installs or referrals (for example, via deep-link or install-referrer mechanisms).

c) Information from third parties.

• We may receive information from analytics, attribution, infrastructure, and fraud-prevention providers, and from third-party sign-in providers, consistent with their terms.

3. How We Use Information

We use information to:

• Provide, operate, maintain, and improve the Services;
• Enable wallet access, display balances, prices, routes, and transaction information;
• Enforce eligibility and geographic restrictions and comply with applicable sanctions and legal obligations;
• Detect, prevent, and investigate fraud, abuse, sybil/multi-account activity, and security incidents (including in connection with any points or referral program);
• Operate referral and rewards programs and attribute referrals;
• Communicate with you, including about support and material changes;
• Comply with legal obligations and enforce our Terms.

4. On-Chain Data Is Public

Transactions you make interact with public blockchains. Information recorded on a blockchain — including your public address, transaction amounts, timestamps, and counterparties — is public, permanent, and outside our control. It may be viewed, copied, and analyzed by anyone. This Policy does not apply to public blockchain data or to third-party protocols and issuers you interact with.

5. Third-Party Services

The Services aggregate and connect to third-party protocols, liquidity venues, bridges, token issuers, fiat on-ramp providers, and other services ("Third-Party Services"). When you interact with a Third-Party Service — for example, completing identity verification (KYC) required by a token issuer or on-ramp provider, or transacting through a third-party protocol — that interaction is governed by the third party's own privacy policy and practices, not this Policy. We do not perform KYC and do not receive or store the identity documents you may provide to a third party. We encourage you to review the privacy policies of any Third-Party Service you use.

6. How We Share Information

We do not sell your personal information. We may share information:

• With service providers (such as cloud infrastructure, analytics, attribution, and fraud-prevention vendors) who process information on our behalf under confidentiality obligations;
• For legal reasons, if required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of the Company, our users, or others;
• In a business transfer, in connection with a merger, acquisition, financing, or sale of assets;
• With your consent or at your direction.

7. Advertising

Our products do not display third-party advertising, and we do not sell your information to advertisers.

8. Data Retention

We retain information for as long as necessary to provide the Services, comply with legal obligations, resolve disputes, prevent fraud, and enforce our agreements. Because the Services are non-custodial, we cannot delete your wallet, keys, or on-chain history — these are not within our control.

9. Security

We implement reasonable technical and organizational measures designed to protect the information we hold. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for securing your device, credentials, and seed phrase.

10. Children's Privacy

The Services are not directed to, and are not intended for use by, anyone under 18 years of age. We do not knowingly collect information from children. If you believe a child has provided us information, please contact us.

11. International Data Transfers

We may process and store information in countries other than the one in which you reside. Where required, we take steps to ensure appropriate safeguards for such transfers. By using the Services, you acknowledge that your information may be transferred to and processed in such countries.

12. Your Rights

Depending on your jurisdiction, you may have rights regarding your personal information, such as the right to access, correct, delete, restrict, or object to certain processing, or to data portability. To exercise applicable rights, contact us at x@realx.is. We will respond consistent with applicable law. Note that we may be unable to fulfill certain requests to the extent they relate to public blockchain data, information we do not hold (such as keys), or information we are required to retain.

Region-specific note. If you are in the EEA/UK, our legal bases for processing include performance of a contract, legitimate interests (such as security and fraud prevention), consent (where applicable), and compliance with legal obligations. If you are a California resident, you have certain rights under the CCPA/CPRA; we do not "sell" or "share" personal information as those terms are defined.

13. Cookies and Similar Technologies

Our website may use cookies and similar technologies for functionality, analytics, and security. You can control cookies through your browser settings; disabling some cookies may affect functionality.

14. Changes to This Policy

We may update this Policy from time to time. We will post the revised Policy with a new "Last updated" date, and, where appropriate, provide additional notice. Your continued use of the Services after changes become effective constitutes acceptance of the revised Policy.

15. Contact

If you have questions about this Policy or our privacy practices, contact us at x@realx.is.