wen Privacy Policy - Mobile App (iOS & Android)
Last updated: 13 August 2026 · Effective: 13 August 2026
Applies to: the wen mobile application for iOS and Android (the "App"). The wen web app and Telegram mini app are covered by the separate Web Privacy Policy at wen.live/legal/privacy.
Contents
- 1. Who we are
- 2. Summary
- 3. Data we collect, why, and on what legal basis
- 4. Non-custodial keys: what wen can and cannot access
- 5. Regional availability, geo-restrictions, and feature gating
- 6. Blockchain data: limits on erasure and pseudonymity
- 7. How we share data
- 8. International transfers
- 9. Retention
- 10. Your rights
- 11. Mobile-specific disclosures
- 12. California residents (CCPA/CPRA)
- 13. United Kingdom
- 14. Changes
- 15. Contact
1. Who we are
The App is operated by AxonTech OÜ, an Estonian private limited company, registry code 17430331, registered address Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145 ("wen", "we", "us"). We are the data controller under the EU General Data Protection Regulation (GDPR). Privacy contact / DPO: privacy@wen.live.
2. Summary
wen is a non-custodial social trading application. We never take custody of your crypto assets and cannot move, withdraw, or freeze funds in your wallet. Balances are read live from public blockchains and trading venues. In the App, the features available to you depend on your region (§5): we determine your approximate location to enable only the features that are lawful and permitted where you are. We collect the minimum personal data needed to run your account, secure it, operate social and trading features, meet these regional obligations, and improve the App. We do not sell your personal data, and we do not use your data to track you across other companies' apps or websites.
3. Data we collect, why, and on what legal basis
| Category | Examples | Purpose | GDPR legal basis |
|---|---|---|---|
| Account & identity | Email, password hash, username, profile details | Account creation, login, support | Contract (Art. 6(1)(b)) |
| Security credentials | TOTP 2FA secret, session and refresh tokens, encrypted key-export material | 2FA; secure optional key export; session security | Contract; legitimate interests in security (6(1)(b)/(f)) |
| Wallet & on-chain data | Wallet addresses, transaction hashes, public on-chain balances and history | Trading, balance display, core functionality | Contract (6(1)(b)) |
| Trading activity | Spot orders, perps positions, copy-trading settings and limits, results | Execute and display trades; copy trading | Contract (6(1)(b)) |
| Region & eligibility data | IP address, IP-derived country/region, device region settings | Feature availability by region (§5), sanctions screening, fraud prevention, legal compliance | Legal obligation; legitimate interests (6(1)(c)/(f)) |
| Referral data | Referrer, referred users, reward accruals | Operate the referral program | Contract; legitimate interests (6(1)(b)/(f)) |
| Gamification data | XP, rank, streaks, quests, wheel/chest outcomes, badges, leaderboards | Rewards and social features | Contract (6(1)(b)) |
| User-generated content | Chat messages, theses, team content, profile media | Social features, moderation, safety | Contract; legitimate interests (6(1)(b)/(f)) |
| Device & usage data | Device model, OS version, app version, feature usage, crash logs, push tokens | Reliability, security, analytics, notifications | Legitimate interests; consent where required (6(1)(f)/(a)) |
| Communications | Support requests | Support | Contract; legitimate interests (6(1)(b)/(f)) |
| Marketing preferences | Consent records, notification opt-ins | Communications you opt into | Consent (6(1)(a)) |
We do not intentionally collect special-category data. We do not collect precise GPS location; region determination uses IP address and device/OS region signals only.
4. Non-custodial keys: what wen can and cannot access
Your wallet is created and secured through our embedded-wallet provider, Privy. wen does not hold, control, or have access to your private keys and cannot move or withdraw your funds. Optional key export is protected by your password and TOTP 2FA and is end-to-end encrypted on your device; our servers relay ciphertext they cannot read. For perpetual futures executed on an independent third-party venue, wen uses an agent key that can place orders but is technically incapable of withdrawing funds.
5. Regional availability, geo-restrictions, and feature gating
Crypto products are regulated differently around the world. To comply with the laws of the places where the App is offered and with the policies of the Apple App Store and Google Play, we:
- offer the App only in the countries listed on the App's store pages, and not in jurisdictions where its operation is prohibited or where we are subject to sanctions restrictions;
- determine your approximate region (from IP address and device region signals) each time you use regulated features, and enable or disable individual features by region. Depending on where you are, some features, including perpetual futures, copy trading, paid signal services, randomized rewards (wheel, chests), or the referral program, may be unavailable, limited (for example, leverage caps), or modified (for example, odds disclosures);
- may block or restrict access, freeze feature availability (never your funds, which we do not custody), or close accounts where required by law, sanctions, or court order;
- keep records of region determinations and related screening for compliance purposes.
Using tools to misrepresent your location (for example, VPNs) to access features not offered in your region violates our Terms and may violate the law. We are not responsible for losses arising from such circumvention.
6. Blockchain data: limits on erasure and pseudonymity
Blockchains are public, immutable, and decentralized. Wallet addresses, amounts, timestamps, and transaction hashes are recorded on ledgers wen does not control and cannot alter or delete. We cannot erase, rectify, or restrict on-chain data; GDPR erasure and rectification rights apply to data held in wen's systems only. Wallet addresses are pseudonymous, not anonymous, and public on-chain data is visible to anyone.
7. How we share data
Processors under Art. 28 GDPR agreements, disclosed only as needed: embedded wallet Privy; independent perps venue provider; hosting EEA-based cloud infrastructure; analytics and crash reporting none; no third-party provider receives your data; push delivery via Apple Push Notification service and Google Firebase Cloud Messaging; support tooling none; support is handled by email; email Resend; compliance, sanctions, and fraud screening performed in-house against publicly available sanctions lists. We may disclose data to regulators, law enforcement, or courts where legally required, and to advisors or an acquirer in a corporate transaction under confidentiality. We do not sell personal data.
8. International transfers
We operate from the EEA and rely on adequacy decisions or Standard Contractual Clauses with supplementary measures for transfers outside the EEA or your region. Details: privacy@wen.live.
9. Retention
Account data for the life of the account and 2 years after closure for legal, audit, and fraud purposes; security, access, and region-determination logs for 12 months; support records for 2 years; analytics aggregated or pseudonymized. Longer retention where law requires. On-chain data persists indefinitely (§6).
10. Your rights
Subject to the GDPR and equivalent laws: access, rectification, erasure, restriction, objection, portability, and withdrawal of consent. No solely automated decisions with legal or similarly significant effect are made about you, except region-based feature availability required for legal compliance (§5), which you may contest via privacy@wen.live. Complaints: Estonian Data Protection Inspectorate (www.aki.ee) or your local authority.
11. Mobile-specific disclosures
- Tracking (iOS App Tracking Transparency): the App does not track you across other companies' apps or websites and does not access the advertising identifier (IDFA). If this ever changes, we will request your permission through Apple's ATT prompt first and update this Policy and the store labels.
- Push notifications: with your opt-in, we send trade, price, social, security, and account notifications. Manage them in the App or in device settings. Push tokens are processed via APNs/FCM.
- Device permissions: requested in context and always optional: camera solely to scan QR codes (addresses, transfers); biometrics (Face ID / Touch ID / fingerprint) solely for optional app lock, handled entirely by your device OS; wen never receives your biometric data.
- Account and data deletion: you can delete your account and the data wen holds in-app (Settings → Account → Delete) or at wen.live/legal/delete. On-chain data is excepted (§6). Deleting the App from your device does not delete your account.
- Store labels: our Apple Privacy Nutrition Label and Google Play Data Safety disclosures summarize this Policy and are kept consistent with it.
- Age requirement: the App is rated for and restricted to users 18+ (or the age of majority where you live, if higher). Trading features require adulthood. We do not knowingly collect data from minors; contact privacy@wen.live for removal.
12. California residents (CCPA/CPRA)
California residents have the rights to know/access, delete, correct, and to opt out of "sale" or "sharing" and to limit use of sensitive personal information. wen does not sell or share personal information as defined by the CPRA and does not use sensitive personal information for purposes requiring a right to limit. No discrimination for exercising rights. Requests: privacy@wen.live; authorized agents accepted. Note that App availability in the United States and the features offered there are limited per §5.
13. United Kingdom
For UK users this Policy operates under the UK GDPR and Data Protection Act 2018; the supervisory authority is the ICO. UK representative, if appointed: Blockmob Labs Limited (United Kingdom), contact privacy@wen.live. Feature availability in the UK is limited per §5.
14. Changes
Updates will be posted here with a new "Last updated" date, with additional notice for material changes. Where a change affects regional feature availability, the App will reflect it directly.
15. Contact
AxonTech OÜ, Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 5, 10145 · privacy@wen.live · DPO: privacy@wen.live