Privacy Policy
1. Introduction and Overview
Arin UK LTD and its subsidiaries and affiliates (“Girin Wallet”, “we”, “our”, and/or “us”) value the privacy of individuals. This Privacy Policy describes how Girin Wallet collects, uses, and shares information about users and their rights and choices regarding such information.
Effective August 10, 2025, the data controller of the Service is Arin UK LTD, a company registered in England and Wales, and this Privacy Policy is governed by the data protection laws of the United Kingdom, including the UK GDPR and the Data Protection Act 2018.
If you have any questions or wish to exercise your rights and options, please contact us in the “Contact Us” section.
2. Personal Data We Collect
We collect certain personal information from you when you use the Service. This information may be provided to us voluntarily by you, collected automatically by us, or provided to us from third-party sources.
2.1. Personal Data we collect from you
We may collect the following types of Personal Data from you directly in our Services. We may collect Personal Data from points of service that you voluntarily provide or where Personal Data is being collected as follows:
| Service | Purpose | Items |
|---|---|---|
| Girin Wallet | to login and create wallet | E-mail address |
| Customer support | handle inquiries | Email address, Inquiry details |
(any information you provide to us when requesting for customer support)
3. What We Do With Personal Data We Collect
We collect and use personal information to:
- Provide Girin Wallet/blockchain services and identify you as a user.
- Carry out marketing tasks such as promoting newsletters or events.
- Provide customer support and respond to inquiries.
- Operate, maintain, improve, personalize, and analyze the Services.
4. Sharing of Your Information
We do not share your personal data unless:
- Authorized by you,
- Required by law,
- Entrusted to third parties (such as service providers) under strict agreements.
4.1. Third Party Service Providers:
We may provide your information to third party companies (the “Third Party Service Providers”) that perform services on our behalf, including, without limitation, operation of the services, data analysis, marketing services, promotional events, email campaigns, hosting services, and customer service or support. The Third Party Service Providers may access your personal data, but are required to use it solely as directed by us for performing requested services. We consider your consent obtained by notifying you of this content in our privacy policy.
| Service | Third Party | Purpose | Retention Period |
|---|---|---|---|
| Girin Wallet | Google Cloud Platform (GCP) | Cloud service | Until contract end |
4.2. Business Partners:
We may partner with affiliates for service development and operation.
4.3. We disclose data when required by law, court, or regulators.
4.4. We may share anonymized information that cannot identify you.
5. Retaining and Deleting Personal Data
We retain data only as long as necessary. After membership termination, data may be deleted or retained as required by law:
- Customer complaints/disputes: 3 years
- Login records: 3 months
| Service | Purpose | Retention and usage period |
|---|---|---|
| Girin wallet | to receive marketing and event promotion emails | until membership withdrawal or service termination |
| user account management | until membership withdrawal or service termination | |
| Customer Support | 3 years |
In addition to the retention periods for each service-specific collected item, we may retain the following information for the specified periods to comply with legal requirements.
- Records of customer complaint or dispute resolution: 3 years
- Computer communication or internet log-in records of computer communication or facts about an internet user’s utilization of telecommunication service: 3 months
6. Transfer of Personal Data to Third Countries
We store and process data in the UK and EU. Transfers to other countries are protected by adequate safeguards (e.g. Standard Contractual Clauses). Users must acknowledge that data may be transferred to countries with different privacy laws.
7. Security of Your Information
We use reasonable safeguards to protect your data from unauthorized access, disclosure, or destruction. Users should not share passwords or send sensitive information via insecure means like email.
8. Your Privacy Rights
You have rights under the UK GDPR and other applicable laws:
- Right to access
- Right to rectification
- Right to erasure
- Right to restrict processing
- Right to object (including for direct marketing)
- Right to data portability
- Right to withdraw consent
To exercise your rights, contact: contact@girin.app
9. Your Privacy Rights
9.1 Right of access
You have the right to verify whether we process your Personal Data and, if so, access to your Personal Data together with certain additional information. Such additional information includes the purposes of processing, the categories of Personal Data concerned and the recipients of the Personal Data. We will provide you with a copy of your Personal Data without affecting the rights and freedoms of others. You may access your Personal Data by contacting us at contact@girin.app.
9.2 Right to Rectification
You are entitled to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed. You may change your personal data by contacting us at contact@girin.app.
9.3 Right to erasure
In some circumstances you are entitled to the erasure of your Personal Data without undue delay. Those circumstances include:
- the Personal Data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
- you withdraw consent to consent-based processing;
- you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and
- the Personal Data has been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary:
- for exercising the right of freedom of expression and information;
- for compliance with a legal obligation; or
- for the establishment, exercise or defense of legal claims.
- If you choose to delete your Personal Data, we will immediately delete your Personal Data. Even after your Personal Data is terminated or deleted, some or all of your information may still remain visible to others, including but not limited to any information that has been incorporated into any User contents or copied, stored or disseminated by you or other users.
You may request erasure of your information by contacting us at contact@girin.app .
9.4 Right to restrict processing
In some circumstances you are entitled to restrict the processing of your Personal Data. Those circumstances are:
- you contest the accuracy of the Personal Data;
- processing is unlawful but you oppose erasure;
- we no longer need the Personal Data for the purposes of our processing, but you require Personal Data for the establishment, exercise or defense of legal claims; and
- you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your Personal Data. However, we will only otherwise process it:
- with your consent;
- for the establishment, exercise or defense of legal claims;
- for the protection of the rights of another natural or legal person; or
- for reasons of important public interest.
You may request restriction of the processing of your information by contacting us at contact@girin.app .
9.5 Right to object
You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for:
- the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or
- the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection.
We will cease to process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
You may request restriction of the processing of your information by contacting us at contact@girin.app .
9.6 Right to object to processing for direct marketing purposes
You have the right to object to our processing of your Personal Data for direct marketing purposes (including profiling for direct marketing purposes). If you raise such an objection, we will stop processing your Personal Data for this purpose. You may object to the processing of your information for direct marketing purposes by contacting us at contact@girin.app .
9.7 Right to object to processing for scientific, historical or statistical purposes
You have the right to object to the processing of your Personal Data for scientific or historical research purposes or for statistical purposes on grounds relevant to your particular situation. You may object to the processing of your information for scientific, historical or statistical purposes by contacting us at contact@girin.app .
9.8 Right to data portability
To the extent that the legal basis for our processing of your Personal Data is:
- consent; or
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your Personal Data from us in a structured, commonly used and machine-readable format and the right to have your Personal Data transmitted to another controller. However, this right does not apply where it would adversely affect the rights and freedoms of others. You may request to receive your information by contacting us at contact@girin.app .
9.9 Right to withdraw consent
If the legal basis for the processing of your Personal Data is consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the legality of processing prior to withdrawal. You may exercise your rights in relation to your Personal Data by giving written notice to contact@girin.app .
9.10 Additional rights
- European residents have the following rights under the GDPR with respect to their Personal Data including the above rights.
If you believe that our processing of Personal Data infringes data protection law, you may file a complaint with the supervisory authority responsible for data protection.
You can find out more about your country's oversight bodies by visiting: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
- California residents have certain rights under the California Consumer Privacy Act (CCPA) & California Privacy Rights Act Disclosures
(CPRA) with respect to their Personal Data in addition to the above rights.
This section applies solely to the personal information collected from consumers or users who reside in the State of California (“users” or “you”).
The right to request disclosure of Personal Data regarding categories of personal information, categories of sources of collection, purposes, categories of third parties with whom we share the information, and specific personal information we collect about you (Cal. Civ. Code §1799.100, §1799.130)
- In the 12 months preceding the date of this Disclosure, we may have collected and disclosed for a business purpose the categories of personal information and shared personal information with the categories of third parties.
Please refer to our "Personal Data We Collect" and "Sharing of Your Information" concerning the categories of personal information(including the categories of sources from which the personal information is collected) and shared personal information with the categories of third parties.
Also, we disclose the purpose for such collecting. Please refer to our "What We Do With Personal Data We Collect”
- No Sale of Personal Information.
We do not sell or share any personal information to third parties for a business or commercial purpose. For the purposes of this Disclosure, “sale of personal information” means the disclosure of personal information for monetary or other valuable consideration.
- Privacy Rights of California Residents.
You have the following rights under the CCPA & CPRA.
- Right to Request Disclosure of Your Personal Information (Cal. Civ. Code §1798.100, §1798.130)
You have the right to request that we disclosed to you any of the following:
- Whether we collect and use your personal information;
- The categories of personal information we have collected about you;
- The business or commercial purpose for collecting personal information;
- Whether we sell or share your personal information to third parties;
- The categories of personal information we have disclosed about you for a business purpose;
- The categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
- The business or commercial purpose for collecting, sharing, or selling personal information; and
- the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
- Right to Request Deletion (Cal. Civ. Code §1798.105)
You have the right to request that we delete your personal information we have collected from you. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
- Right to Nondiscrimination (Cal. Civ. Code §1798.125)
We will not discriminate against you if you exercise your privacy rights
If you want to exercise any of your rights, please feel free to contact us by sending an email to contact@girin.app .
Upon request, please provide sufficient information to reasonably determine that you are the person or authorized representative from whom we collected personal information. If we cannot verify your identity, your request may be denied.
State in your request the rights you wish to exercise and the scope of your request.
We will consider and act on all of the above requests in accordance with applicable law. We also do not discriminate against you for exercising these rights.
10. Changes to Privacy Policy
We may update this Privacy Policy. Changes become effective when posted. We will notify you if required by law. Last updated: July 29, 2025.
11. Link
We are not responsible for third-party websites or their privacy practices. Please review their policies when you leave our site.
12. Data Protection Officer and Representative
Data Protection Officer: Din Yun — din@girin.app
Representative: Din Yun — din@girin.app
Arin UK LTD is the registered data controller under UK law.
Questions
If you have any questions regarding this Privacy Policy, contact us at: contact@girin.app