Privacy Policy

Effective Date: 18 June 2026 · ADS CARE AGENCY GLOBAL LIMITED · Brenon Wallet

1. Who We Are

Brenon Wallet is operated by ADS CARE AGENCY GLOBAL LIMITED, a private limited company registered in the Hong Kong Special Administrative Region ("the Company," "we," "us"). This Privacy Policy explains how we collect, use and protect your personal data under the Hong Kong Personal Data (Privacy) Ordinance (Cap. 486) (the "PDPO") and — for California residents — the California Consumer Privacy Act (CCPA/CPRA). Where you access the Service from the EU/EEA, we also honour applicable rights under the EU General Data Protection Regulation (GDPR).

ADS CARE AGENCY GLOBAL LIMITED (Data User)
Room 1D, 2/F, Fu Tao Building, 98 Argyle Street, Mongkok, Hong Kong
Email: [email protected]
Phone: +852 2388 6470

2. Data We Collect

Beta Application Data: Name, email address, Telegram handle and the use-case details you share when applying for the beta.
Wallet & Key Data: Never collected. Your seed phrase and private keys are generated and stored only on your device and never reach us.
Screening Metadata (anonymised): On-chain addresses and risk scores involved in deposit screening are processed to deliver the AML feature. Public blockchain data is not personal data in itself; where it is linked to you it is handled under this policy and minimised.
Technical Data: IP address, device OS, app version and anonymous crash logs for stability and security purposes.
Communications: Emails and messages you send to us.

3. How We Use It

To evaluate beta applications and manage participation.
To operate and improve the AML screening engine and risk scoring.
To communicate product updates, beta access details and support responses.
To detect and prevent fraud, abuse and security threats.
To comply with applicable Hong Kong law.

4. Basis for Processing

Consent — beta enrolment and communications.
Legitimate interests — security, fraud prevention, AML risk reduction and product improvement.
Legal obligation — applicable Hong Kong law.

5. Sharing & Sale of Data

We do not sell your personal data. We do not share personal data with third parties except: (a) blockchain-analytics and data providers strictly to perform AML screening, acting as processors; (b) email or messaging providers operating the beta; or (c) where required by law, court order or a lawful request from a competent authority.

6. Your Rights

Under the PDPO (Hong Kong): You have the right to request access to and correction of your personal data, and to be informed how it is used. To exercise these rights, email [email protected]. You may also lodge a complaint with the Office of the Privacy Commissioner for Personal Data, Hong Kong (PCPD, pcpd.org.hk). EU/EEA residents additionally have the GDPR rights of access, rectification, erasure, restriction, portability and objection.

California residents (CCPA/CPRA): You have the right to know what personal information is collected, request deletion, correct inaccurate data and opt out of the sale of personal information (we do not sell data).

7. Retention

Beta application and participant data: programme duration + 24 months.
Screening metadata: retained only as long as needed to operate and audit the AML feature, then minimised or deleted.
Technical logs and crash data: 60 days.
Communications: 3 years.

8. Security

Data in transit is protected with TLS encryption. Your keys and seed phrase never leave your device by design. In the event of a personal-data breach affecting you, we will notify affected users and the Office of the Privacy Commissioner for Personal Data, Hong Kong where required.

9. Cookies

The website uses strictly necessary session cookies only. A dismissible banner is shown on first visit. No analytics, advertising or tracking cookies are used.

10. Children

The Service is not directed at persons under 18. We do not knowingly collect data from minors. If you believe a minor has submitted data, contact us for immediate deletion.

11. Changes

We may update this Privacy Policy with at least 30 days' notice to active participants for material changes.

12. Contact

ADS CARE AGENCY GLOBAL LIMITED
Room 1D, 2/F, Fu Tao Building, 98 Argyle Street, Mongkok, Hong Kong
Email: [email protected]
Phone: +852 2388 6470