Privacy Policy
Last updated: July 07, 2025.
Holders: Card & Wallet is a software service accessible via a mobile device application and a browser service for the TON Network (the "Network") distributed by Holders Apps LTD (United Kingdom, Company Number 16436542, legal address: Suite 11 Fitzroy House, Lynwood Drive, Worcester Park, Surrey KT4 7AT) (hereinafter referred to as "we", "us", "our", or the "Company"). The App enables users to self-custody digital assets; access a digital asset browser and link to decentralized applications and decentralized exchanges; view addresses and information that are part of digital asset networks and broadcast transactions, as well as use additional services provided by partners and any further functionality we may add to the App from time to time (collectively, the "App").
This Privacy Policy explains how we collect, use, store, and protect your information when you use the App, our developer software, or our website at https://holders.cards/ (collectively, the "Services"). Please also read our Terms of Service, which describe the terms under which you use the Services.
We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Information We Collect
As the App is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your personal data to use the App. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed. Please note that your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. We may collect limited information about you from your devices or from various sources, as described below.
Information You Give Us
We may collect some personal information from you when you communicate with us, including your contact information, such as your name, email address, or phone number (depending on how you contact us).
Information Automatically Collected
We may automatically collect information about you and your devices when you use the App, including:
How We Use the Information
We use the information we collect for the following purposes:
If you are located in the United Kingdom, we only process your personal data when we have a valid legal basis, including when:
We only share your personal data when we have a valid reason for it, namely, to provide the Services and products to you and when we are legally permitted to do so.
We may disclose your personal data to:
Please be aware that your information may be transferred to, processed, and stored outside of the United Kingdom. By using the App, you consent to the transfer of your information, including personal information, as set forth in this Privacy Policy. Whenever we transfer your personal information outside of the UK to countries not deemed by the Information Commissioner’s Office (ICO) to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the ICO as providing adequate protection for personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.
Your Rights
Under the UK GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you have the right to lodge a complaint with the UK’s supervisory authority:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: https://ico.org.uk/
Retention Period
We will only retain your information as long as reasonably required for us to provide the requested customer support and inquiry services. If you delete or uninstall the App from your device or request that your information be deleted, we may still retain some information that you have provided to us to maintain the App or to comply with relevant laws.
Security
We use reasonable organizational, technical, and administrative measures to protect your information. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem.
Third Party Services
The App may contain links or API connections to other websites, products, or services such as https://ton.org or similar that we do not own or operate. We are not responsible for the privacy and confidentiality practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party API providers or any information you disclose to these third parties. We recommend you to read their privacy policies before providing any information to them.
Changes and Updates to Privacy Policy
We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. We may need to update this Privacy Policy, and we reserve the right to do so at any time. If we do revise this Privacy Policy, we will update the effective date at the top of this page so that you can tell if it has changed since your last visit and will do our best to notify you. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of the App after an amendment to our Privacy Policy constitutes your acceptance to the revised or amended agreement.
Contact Information
If you have questions about your privacy related to the App or this Privacy Policy, you may contact us at:
Holders: Card & Wallet
Email: privacy@holders.cards
If you have concerns about how we handle your personal data, you also have the right to contact the UK’s supervisory authority:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: https://ico.org.uk/
Last updated: July 07, 2025.
Holders: Card & Wallet is a software service accessible via a mobile device application and a browser service for the TON Network (the "Network") distributed by Holders Apps LTD (United Kingdom, Company Number 16436542, legal address: Suite 11 Fitzroy House, Lynwood Drive, Worcester Park, Surrey KT4 7AT) (hereinafter referred to as "we", "us", "our", or the "Company"). The App enables users to self-custody digital assets; access a digital asset browser and link to decentralized applications and decentralized exchanges; view addresses and information that are part of digital asset networks and broadcast transactions, as well as use additional services provided by partners and any further functionality we may add to the App from time to time (collectively, the "App").
This Privacy Policy explains how we collect, use, store, and protect your information when you use the App, our developer software, or our website at https://holders.cards/ (collectively, the "Services"). Please also read our Terms of Service, which describe the terms under which you use the Services.
We process your personal data in accordance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018.
Information We Collect
As the App is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your personal data to use the App. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed. Please note that your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. We may collect limited information about you from your devices or from various sources, as described below.
Information You Give Us
We may collect some personal information from you when you communicate with us, including your contact information, such as your name, email address, or phone number (depending on how you contact us).
Information Automatically Collected
We may automatically collect information about you and your devices when you use the App, including:
- Information you create through the App, such as public wallet addresses
- The IP address of the device you use to access the App
- The type of browser software you are using
- The operating system you are using
- The date and time you access or use the App
- Other non-personally identifiable information
How We Use the Information
We use the information we collect for the following purposes:
- To enable you to access and use the App, process and complete transactions, and send you related information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
- To understand and analyze how you use the App and develop new products, services, features, and functionality.
- To communicate with you about promotions, upcoming events, and other news about products and services offered by us.
- For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
- To personalize your experience of the App, such as identifying you as a repeat visitor.
- To facilitate the connection of third-party services or applications.
- To operate, maintain, and improve the App.
- To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
- For compliance purposes, including enforcing our terms of use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
- To contract with third-party API providers, including providing customer service, advertising or marketing services, and analytic services.
If you are located in the United Kingdom, we only process your personal data when we have a valid legal basis, including when:
- Performance of a contract: Processing personal data is needed to perform our obligations under a contract (to provide services) concluded with you.
- Legal obligation or public interest: We are required to process your personal data to comply with a legal obligation or for reasons of public interest.
- Legitimate interests: Where necessary, we may process personal data where there is a legitimate interest for us in pursuing commercial and business interests (for example, for product development and internal analytics purposes), except where such interests are overridden by your interests, fundamental rights, and freedoms.
- Consent: Where you have given us your consent to process your personal data for a specific purpose.
We only share your personal data when we have a valid reason for it, namely, to provide the Services and products to you and when we are legally permitted to do so.
We may disclose your personal data to:
- Data processors (including banking partners, technology providers, customer support centers) – The Company uses carefully selected service providers (data processors) that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect your personal data. We have concluded appropriate data processing agreements with these service providers and shall remain responsible for their actions in respect of the processing of your personal data.
- Third parties – In some circumstances, we also share your personal data with third parties who act as independent data controllers. We only share your personal data with third parties if stipulated herein, if required under applicable law (e.g., auditors, national regulators, or other authorities), when we need to protect your legal rights (e.g., disclosing personal data to attorneys or debt collection agencies) due to legitimate interest for the performance of an agreement, or with your consent.
- Acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. In such cases, we ensure that your rights as a data subject are not diminished.
- Your representatives, advisers, and other third parties you have contacted regarding the Service or whom you have authorized to interact with us on your behalf. We consider such authorization as your consent, and your request for such activity must be presented to us in written form.
- With your consent – We may share information with other third parties with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions. Use of the information you agree to share will be subject to those third parties' respective privacy notices.
Please be aware that your information may be transferred to, processed, and stored outside of the United Kingdom. By using the App, you consent to the transfer of your information, including personal information, as set forth in this Privacy Policy. Whenever we transfer your personal information outside of the UK to countries not deemed by the Information Commissioner’s Office (ICO) to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the ICO as providing adequate protection for personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the UK.
Your Rights
Under the UK GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
- Opt-out: You may contact us at any time to opt-out of (i) any consent you previously provided to us regarding the processing of your information; or (ii) the transfer of your information outside the UK. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent. Please note that your use of parts of the App may be ineffective upon opt-out. You may unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving marketing and promotional messages from us, you will continue to receive administrative messages from us.
- Access: Provide you with information about our processing of your information and give you access to your information.
- Amend: You may update or correct any inaccuracies in your information by contacting us.
- Restrict: Restrict the processing of your information.
- Object: Object to our reliance on our legitimate interests as the basis of our processing of your information that impacts your rights.
- Delete: In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data.
If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law, you have the right to lodge a complaint with the UK’s supervisory authority:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: https://ico.org.uk/
Retention Period
We will only retain your information as long as reasonably required for us to provide the requested customer support and inquiry services. If you delete or uninstall the App from your device or request that your information be deleted, we may still retain some information that you have provided to us to maintain the App or to comply with relevant laws.
Security
We use reasonable organizational, technical, and administrative measures to protect your information. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem.
Third Party Services
The App may contain links or API connections to other websites, products, or services such as https://ton.org or similar that we do not own or operate. We are not responsible for the privacy and confidentiality practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party API providers or any information you disclose to these third parties. We recommend you to read their privacy policies before providing any information to them.
Changes and Updates to Privacy Policy
We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. We may need to update this Privacy Policy, and we reserve the right to do so at any time. If we do revise this Privacy Policy, we will update the effective date at the top of this page so that you can tell if it has changed since your last visit and will do our best to notify you. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of the App after an amendment to our Privacy Policy constitutes your acceptance to the revised or amended agreement.
Contact Information
If you have questions about your privacy related to the App or this Privacy Policy, you may contact us at:
Holders: Card & Wallet
Email: privacy@holders.cards
If you have concerns about how we handle your personal data, you also have the right to contact the UK’s supervisory authority:
Information Commissioner’s Office (ICO)
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Tel: 0303 123 1113
Website: https://ico.org.uk/
Contact Us
Contact us
Suite 11 Fitzroy House, Lynwood Drive, Worcester Park, England, KT4 7AT
Company number 16436542
Company number 16436542
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