Legal

User Agreement

This Agreement is issued by CRYPTO FUND LLC and governs your use of New One, a non-custodial multi-chain wallet. It consists of two parts: the Terms of Service and the Privacy Statement. Both apply to you.

Last updated June 30, 2025

Part I

Terms of Service

These Terms govern your access to and use of New One. Read them carefully — they include an arbitration agreement and a class-action waiver in Section 15, and limitations on our liability in Section 13.

1Key Definitions and Interpretation

Unless the context requires otherwise, the following terms have the meanings set out below wherever they appear in this Agreement.

Agreement: This consolidated document, comprising the Terms of Service in Part I and the Privacy Statement in Part II, together with any appendices, schedules, and supplemental terms we publish and identify as forming part of it.
Blockchain: A distributed, cryptographically secured ledger maintained by a decentralized network of participants, on which Digital Asset transactions are recorded.
DApp: A decentralized application that operates on a Blockchain and with which you may interact through the App, including but not limited to lending protocols, marketplaces, and games.
DEX: A decentralized exchange — a smart-contract-based protocol that facilitates the exchange of Digital Assets without an intermediary holding custody of those assets.
Digital Asset: Any cryptographic token, coin, or other digital representation of value recorded on a Blockchain, including native network assets, fungible tokens, and NFTs.
Gas Fee: A fee payable to Blockchain network validators or miners to process and confirm a transaction. Gas Fees are set by the relevant network, are paid to third parties, and are not received or retained by us.
NFT: A non-fungible token — a Digital Asset that is uniquely identifiable and not interchangeable on a one-to-one basis with another asset of the same class.
Non-Custodial: A model in which the service provider does not hold, control, or have the technical ability to access a user's Private Keys or Digital Assets at any time.
Private Key: The secret cryptographic value that authorizes transactions from a Wallet. Whoever holds the Private Key controls the associated Digital Assets.
Recovery Phrase: An ordered sequence of words (also called a seed phrase or mnemonic) from which a Wallet's Private Keys can be deterministically regenerated.
Services: The App, the Site, and all related software, interfaces, and functionality we make available to you, as described in Section 2.
Site: Our website and any successor or associated web properties we operate.
Smart Contract: Self-executing code deployed to a Blockchain that performs defined operations when specified conditions are met.
Third-Party Service: Any protocol, application, exchange, bridge, on-ramp, or other service operated by a party other than us that you access or interact with through the Services.
Wallet: A software instrument generated or imported through the App that stores Private Keys locally on your device and enables you to sign Blockchain transactions.
You: The individual or entity accessing or using the Services. If you use the Services on behalf of an entity, "you" includes that entity, and you represent that you are authorized to bind it.

Rules of Interpretation

Headings are for convenience only and do not affect the interpretation of any provision.
Words in the singular include the plural and vice versa; references to any gender include all genders.
"Including," "includes," and "such as" are illustrative and do not limit the generality of the preceding words.
A reference to a statute or regulation includes any amendment, consolidation, or re-enactment of it in force from time to time.
If any provision of this Agreement conflicts with a supplemental term governing a specific feature, the supplemental term controls with respect to that feature only.

2Our Services

New One is a Non-Custodial Digital Asset wallet. The Services allow you to generate or import a Wallet, view balances across supported Blockchains, sign and broadcast transactions, and connect to Third-Party Services such as DApps, DEXs, and NFT marketplaces.

The defining characteristic of the Services is that they are Non-Custodial. Private Keys and Recovery Phrases are generated on your device and stored in your device's secure hardware. They are not transmitted to us, backed up to our systems, or recoverable by us under any circumstances. We are not a bank, broker, exchange, money transmitter, or custodian, and we do not hold, control, or have access to your Digital Assets.

Because we do not hold your assets, we cannot reverse, cancel, freeze, or modify a transaction once it has been broadcast to a Blockchain, and we cannot restore access to a Wallet whose Recovery Phrase has been lost. Blockchain transactions are final and irreversible by design.

We provide software. We do not provide investment, financial, legal, tax, or accounting advice, and nothing in the Services constitutes a recommendation to acquire or dispose of any Digital Asset.
We do not operate any Blockchain, issue any Digital Asset, or control any Smart Contract deployed by a third party.
Where the Services display prices, balances, gas estimates, or protocol information, that data is sourced from public networks and third-party providers and is furnished for convenience only, without warranty as to accuracy or timeliness.
Certain features may be provided by, or routed through, Third-Party Services. Your use of those features is governed by the relevant third party's own terms, and we are not a party to that relationship.
We may add, modify, or discontinue supported Blockchains, assets, or features at our discretion.

3Usage Requirements and Your Responsibilities

To use the Services you must be at least 18 years old and have the legal capacity to enter into a binding contract. You must not use the Services if you are subject to sanctions or are located in, ordinarily resident in, or organized under the laws of a jurisdiction subject to comprehensive sanctions administered by the U.S. government.

Because the Services are Non-Custodial, the security of your Digital Assets rests entirely with you. You are solely responsible for:

Recording your Recovery Phrase and storing it offline, in a location that is secure and known only to you. We will never ask you for it, and anyone who does is attempting to defraud you.
Keeping your device free of malware, applying operating system and application updates, and protecting device access with a passcode and biometric lock.
Verifying the accuracy of every recipient address, contract address, asset, network, and amount before you sign a transaction.
Reviewing and, where appropriate, revoking token approvals and other authorizations you have granted to Smart Contracts.
Assessing any Third-Party Service before you connect to it or authorize it to act on your behalf.

If you lose your Recovery Phrase, or if it is obtained by another person, your Digital Assets will in all likelihood be permanently lost or stolen. This outcome is a consequence of the cryptographic design of Blockchain systems and is not something we are able to remedy.

4Risk Disclosure

Digital Assets involve substantial risk. You should not commit funds you cannot afford to lose entirely. The following summary is not exhaustive.

Market risk. Digital Asset prices are highly volatile and may fall to zero. Past performance is not indicative of future results.
Self-custody risk. Loss, theft, or destruction of your Recovery Phrase results in permanent loss of access, with no recovery mechanism and no insurance.
Technology risk. Blockchains, Smart Contracts, bridges, and wallet software may contain bugs, be exploited, fork, congest, or halt. Transactions may fail while still incurring Gas Fees.
Counterparty and protocol risk. Third-Party Services may be insolvent, malicious, negligent, or compromised. Liquidity may be withdrawn without notice.
Security risk. Phishing sites, fraudulent applications, malicious token approvals, address-poisoning, and social engineering are widespread in this sector.
Regulatory risk. Laws governing Digital Assets are unsettled and evolving. Changes may restrict or prohibit your ability to use the Services or to hold particular assets.
Tax risk. Transactions may create taxable events in your jurisdiction. Determining and reporting these is your responsibility.

5Your Representations and Warranties

Each time you use the Services, you represent and warrant that:

You are at least 18 years old and have full legal capacity to accept this Agreement.
You understand the nature and risks of Digital Assets and Non-Custodial software, and you accept those risks.
All funds and Digital Assets you use in connection with the Services are lawfully owned or controlled by you and derive from lawful sources.
You are not a person or entity listed on, or owned or controlled by a person listed on, any sanctions list administered by the U.S. Department of the Treasury's Office of Foreign Assets Control or any equivalent authority.
Your use of the Services complies with all laws applicable to you, and is not prohibited in your jurisdiction.
Any information you provide to us is accurate and not misleading, and you will keep it current.

6Prohibited Activities

You must not, and must not permit any other person to:

Use the Services in furtherance of money laundering, terrorist financing, sanctions evasion, fraud, or any other unlawful purpose.
Use the Services to acquire, transfer, or conceal the proceeds of criminal activity.
Reverse engineer, decompile, or attempt to derive the source code of the Services, except to the extent that restriction is unenforceable under applicable law.
Interfere with, disrupt, or place undue load on the Services or the infrastructure supporting them, including by automated scraping, denial-of-service, or exploitation of vulnerabilities.
Circumvent or attempt to circumvent any access control, rate limit, geographic restriction, or security measure.
Infringe our intellectual property rights or those of any third party, or use our name, logo, or branding without written permission.
Impersonate any person or misrepresent your affiliation with any person or entity.
Introduce malware or any other code intended to damage, disable, or gain unauthorized access to any system or data.

We may suspend or terminate access to the Services where we reasonably believe this Section has been breached, without prior notice where the circumstances warrant.

7Fees and Taxes

Core wallet functions — creating a Wallet, holding assets, sending and receiving — are provided without charge by us. You will, however, always pay Gas Fees to the relevant Blockchain network. Gas Fees are determined by network conditions, are paid to validators or miners rather than to us, and are not refundable, including where a transaction fails or is not confirmed.

Certain optional features, such as cross-chain swaps or fiat on-ramps, are provided in cooperation with Third-Party Services and may carry a spread, routing fee, or service fee. Where we apply a fee, it will be disclosed to you before you confirm the relevant transaction. We may introduce or adjust fees on a prospective basis with notice.

You are solely responsible for determining what taxes apply to your transactions and for reporting and remitting them to the appropriate authorities. We do not withhold taxes and do not provide tax reporting on your behalf except where required by law.

8Content and Intellectual Property

The Services, including all software, interfaces, text, graphics, logos, and design elements, are owned by CRYPTO FUND LLC or its licensors and are protected by copyright, trademark, and other intellectual property laws. Subject to your compliance with this Agreement, we grant you a limited, revocable, non-exclusive, non-transferable, non-sublicensable license to use the Services for your personal or internal business purposes. No other rights are granted, whether by implication, estoppel, or otherwise.

You retain ownership of any content you submit to us, such as feedback, support correspondence, or materials you publish through a feature that permits it. By submitting content, you grant us a worldwide, royalty-free, perpetual, irrevocable, sublicensable license to use, reproduce, modify, and display that content for the purpose of operating, improving, and promoting the Services. You represent that you have the rights necessary to grant this license.

Digital Assets, including NFTs, that you acquire through Third-Party Services are not provided by us. Any intellectual property rights attaching to them are governed by the terms of the relevant issuer or creator, not by this Agreement.

9Service Changes, Suspension, and Interruption

We may modify, suspend, or discontinue all or part of the Services at any time, including to address a security threat, comply with a legal obligation, perform maintenance, or retire a feature. Where the change is material and circumstances permit, we will give reasonable notice.

The Services depend on infrastructure we do not control, including Blockchain networks, node providers, app stores, and Third-Party Services. We are not liable for any unavailability, delay, data inaccuracy, or loss arising from those systems, nor for any event beyond our reasonable control, including natural disaster, war, civil unrest, labor action, epidemic, governmental action, network failure, or power outage.

Because the Services are Non-Custodial, suspension or discontinuation of the Services does not affect your ownership or control of your Digital Assets. Your Recovery Phrase can be used to restore your Wallet in any compatible wallet application.

10Compliance with Laws

You are responsible for complying with all laws applicable to your use of the Services, including those concerning anti-money laundering and countering the financing of terrorism, economic sanctions, securities, commodities, consumer protection, taxation, and data protection.

Core wallet functionality does not require you to provide identity documents to us. Where you elect to use an optional feature provided by a regulated Third-Party Service — for example a fiat on-ramp — that provider may require identity verification under its own legal obligations. Any information you provide in that process is collected and processed by that provider under its own terms and privacy policy.

We may take steps we consider necessary to comply with legal obligations, including restricting access from particular jurisdictions and responding to lawful requests from governmental authorities.

11Privacy and Data Protection

Our collection and use of personal information is described in the Privacy Statement in Part II of this Agreement, which forms an integral part of it. The Privacy Statement addresses rights available under the California Consumer Privacy Act as amended by the California Privacy Rights Act, comparable state privacy laws, and, for users outside the United States, the relevant regimes identified in the appendices.

We do not collect, transmit, or store your Private Keys, Recovery Phrase, or device passcode. These never leave your device.

12Indemnification

You agree to indemnify, defend, and hold harmless CRYPTO FUND LLC and its members, managers, officers, employees, contractors, and agents from and against any claim, demand, action, loss, liability, damage, cost, or expense (including reasonable attorneys' fees) arising out of or relating to:

Your breach of this Agreement or of any law or regulation.
Your use or misuse of the Services, including any transaction you sign.
Content you submit through the Services.
Your infringement or misappropriation of the rights of any third party.
Any dispute between you and a Third-Party Service or another user.

We reserve the right to assume the exclusive defense and control of any matter subject to indemnification by you, in which case you agree to cooperate with us.

13Disclaimer of Warranties and Limitation of Liability

THE SERVICES ARE PROVIDED "AS IS" AND "AS AVAILABLE," WITHOUT WARRANTY OF ANY KIND. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE DISCLAIM ALL WARRANTIES, EXPRESS OR IMPLIED, INCLUDING IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT, AND ANY WARRANTY THAT THE SERVICES WILL BE UNINTERRUPTED, SECURE, ACCURATE, OR ERROR-FREE.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE WILL NOT BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, EXEMPLARY, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF PROFITS, REVENUE, DATA, GOODWILL, OR DIGITAL ASSETS, WHETHER IN CONTRACT, TORT, STRICT LIABILITY, OR OTHERWISE, EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

TO THE MAXIMUM EXTENT PERMITTED BY LAW, OUR TOTAL AGGREGATE LIABILITY ARISING OUT OF OR RELATING TO THIS AGREEMENT OR THE SERVICES WILL NOT EXCEED THE GREATER OF (A) THE TOTAL FEES YOU PAID TO US IN THE TWELVE MONTHS PRECEDING THE EVENT GIVING RISE TO THE CLAIM, OR (B) ONE HUNDRED U.S. DOLLARS (US$100).

Without limiting the foregoing, we are not liable for loss arising from: your loss or disclosure of a Recovery Phrase; a transaction you signed, including one signed in error or as a result of deception; the conduct, insolvency, or failure of any Third-Party Service; any defect or exploit in a Smart Contract we did not author; or any Blockchain fork, congestion, reorganization, or halt.

Nothing in this Agreement excludes or limits liability for fraud, fraudulent misrepresentation, willful misconduct, or any liability that cannot be excluded or limited under applicable law. Some jurisdictions do not allow the exclusion of certain warranties or the limitation of certain damages; in those jurisdictions, the exclusions and limitations above apply only to the extent permitted.

14Governing Law

This Agreement and any dispute arising out of or relating to it or the Services are governed by the laws of the State of Delaware and, where applicable, the federal laws of the United States, without regard to conflict-of-laws principles. The United Nations Convention on Contracts for the International Sale of Goods does not apply.

The Federal Arbitration Act governs the interpretation and enforcement of Section 15.

15Dispute Resolution, Arbitration, and Class-Action Waiver

PLEASE READ THIS SECTION CAREFULLY. IT AFFECTS YOUR LEGAL RIGHTS, INCLUDING YOUR RIGHT TO FILE A LAWSUIT IN COURT AND TO HAVE A JURY TRIAL.

Informal Resolution First

Before commencing arbitration, you agree to notify us in writing at support@newone.io describing the dispute and the relief sought. We will attempt in good faith to resolve the matter with you for a period of sixty (60) days from receipt. Either party may commence arbitration only after that period has elapsed.

Binding Arbitration

Any dispute not resolved informally will be settled by final and binding arbitration administered by the American Arbitration Association under its Consumer Arbitration Rules, before a single arbitrator. The seat of arbitration is Wilmington, Delaware, and the language is English. The arbitrator has exclusive authority to resolve any dispute regarding the interpretation, applicability, or enforceability of this Section. Judgment on the award may be entered in any court of competent jurisdiction.

Your Right to Opt Out

You may opt out of this arbitration agreement by sending written notice to support@newone.io within thirty (30) days of first accepting this Agreement, stating your name and your intention to opt out. Opting out does not affect any other provision of this Agreement.

Exceptions

Either party may bring an individual claim in small claims court if it qualifies.
Either party may seek injunctive or other equitable relief in a court of competent jurisdiction to prevent actual or threatened infringement or misappropriation of intellectual property rights.

Class-Action Waiver

ALL CLAIMS MUST BE BROUGHT IN AN INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS, COLLECTIVE, CONSOLIDATED, OR REPRESENTATIVE PROCEEDING. THE ARBITRATOR MAY NOT CONSOLIDATE MORE THAN ONE PERSON'S CLAIMS OR PRESIDE OVER ANY FORM OF REPRESENTATIVE PROCEEDING. If this waiver is found unenforceable as to a particular claim, that claim must proceed in court and is severed from any arbitration.

Time Limit

Any claim arising out of or relating to this Agreement or the Services must be filed within one (1) year after it arose, or it is permanently barred, except where a longer period is required by applicable law.

16General Provisions

Acceptance

By downloading, accessing, or using the Services, you accept this Agreement. If you do not accept it, do not use the Services.

Amendments

We may amend this Agreement from time to time. The current version will always be published at this address with the date it took effect. Where a change materially reduces your rights or increases your obligations, we will provide notice through the App, the Site, or another reasonable means before it takes effect. Continued use of the Services after the effective date constitutes acceptance. If you do not accept a change, you must stop using the Services; your Digital Assets remain accessible to you through your Recovery Phrase.

Assignment

You may not assign or transfer this Agreement or any rights under it without our prior written consent. We may assign this Agreement to an affiliate or in connection with a merger, acquisition, reorganization, or sale of assets.

Severability and Waiver

If any provision of this Agreement is held invalid or unenforceable, that provision will be modified to the minimum extent necessary to make it enforceable, and the remaining provisions will continue in full force. Our failure to enforce any provision is not a waiver of our right to do so later.

Entire Agreement

This Agreement constitutes the entire agreement between you and CRYPTO FUND LLC regarding the Services and supersedes all prior understandings on that subject.

Electronic Communications and Notices

You consent to receive communications from us electronically, and you agree that electronic communications satisfy any legal requirement that a communication be in writing. Notices to us should be sent to support@newone.io. Notices to you may be provided through the App, the Site, or any contact address you have supplied.

No Third-Party Beneficiaries

Except as expressly stated, this Agreement does not confer rights on any person who is not a party to it.

Survival

Sections concerning intellectual property, indemnification, disclaimers, limitation of liability, governing law, and dispute resolution survive termination of this Agreement.

Part II

Privacy Statement

This Statement explains what information we collect, why, and what control you have over it. Because New One is non-custodial, your keys and recovery phrase are not among the information we hold.

1Nature and Scope of This Statement

This Privacy Statement is the primary document describing how CRYPTO FUND LLC handles personal information in connection with the Services. It applies to the App, the Site, and our support channels.

The single most important fact about our data practices follows from the Non-Custodial design of New One: we do not collect, receive, transmit, or store your Private Keys, Recovery Phrase, wallet password, or device passcode. These are generated on your device, encrypted by your device's secure hardware, and never sent to us. We therefore have no ability to access your Wallet or your Digital Assets, and no ability to disclose them to anyone else.

Core wallet functionality does not require you to create an account or submit identity documents to us. Identity verification arises only where you choose to use an optional feature operated by a regulated Third-Party Service, in which case that provider — not us — collects and controls that information.

2Who We Are and How to Contact Us

CRYPTO FUND LLC is responsible for the personal information described in this Statement. For privacy questions, requests, or complaints, contact us at privacy@newone.xyz. For general support, contact support@newone.io.

We aim to acknowledge privacy requests within ten (10) business days and to respond substantively within the period required by the law applicable to you.

3Definitions

Personal Information: Information that identifies, relates to, describes, or could reasonably be linked with an identified or identifiable individual or household. Equivalent to "personal data" under non-U.S. regimes.
Sensitive Personal Information: The subset of Personal Information given heightened protection under applicable law, such as government identifiers, precise geolocation, and account credentials.
Processing: Any operation performed on Personal Information, including collection, storage, use, disclosure, and deletion.
Service Provider: A third party that processes Personal Information on our behalf and under our instructions, such as an analytics, hosting, or customer support vendor.
Affiliate: An entity that controls, is controlled by, or is under common control with CRYPTO FUND LLC.

4Personal Information We Collect

Information you provide

Contact details and correspondence when you email support, submit feedback, or report a bug.
Optional profile settings you configure in the App, such as display currency, language, or address labels.
Information you volunteer in surveys, beta programs, or community channels.

Information collected automatically

Device and application data: device model, operating system version, App version, language, and time zone.
Log and diagnostic data: crash reports, error traces, performance metrics, and feature interaction events.
Network data: IP address, from which approximate (city- or country-level) location may be inferred.
Cookies and similar technologies on the Site, as described in Section 11.

Blockchain data

Public Blockchains are, by design, transparent and permanent. Wallet addresses, transaction amounts, timestamps, and contract interactions are recorded on-chain by the network itself, not by us. We may read this public data to display your balances and history. We cannot alter or erase it, and neither can you — a fact worth understanding before transacting.

Information from third parties

We may receive limited information from Service Providers such as analytics platforms, app stores, security vendors, and infrastructure providers.

What we never collect

Private Keys. Recovery Phrases. Wallet passwords. Device passcodes or biometric data. These are not transmitted to us under any circumstances.

5How We Use Personal Information

To provide, operate, and maintain the Services, including displaying balances and broadcasting transactions you have signed.
To diagnose faults, monitor performance, and improve the reliability and usability of the Services.
To detect, investigate, and prevent fraud, abuse, security incidents, and other harmful activity.
To respond to your support requests and communicate with you about the Services.
To comply with legal obligations and to establish, exercise, or defend legal claims.
To develop new features and understand aggregate usage patterns.
To send you marketing communications where you have consented, and to measure their effectiveness.

Where a legal basis is required (for example, for users in the European Economic Area or the United Kingdom), we rely on performance of a contract, our legitimate interests in operating and securing the Services, compliance with legal obligations, or your consent, as appropriate to the purpose.

7Automated Processing

We use automated systems to flag anomalous or potentially fraudulent activity, to filter abuse, and to prioritize support requests. These systems support human judgment rather than replace it: we do not make decisions producing legal or similarly significant effects concerning you based solely on automated processing without human involvement. Where applicable law grants you a right to obtain human review of such a decision, you may exercise it by contacting privacy@newone.xyz.

8International Data Transfers

We are based in the United States, and Personal Information we process may be stored or accessed in the United States and in other countries where we or our Service Providers operate. Data protection laws in those countries may differ from those in your own.

Where we transfer Personal Information from the European Economic Area, the United Kingdom, or another jurisdiction that restricts international transfers, we implement an appropriate safeguard, such as the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, or reliance on an adequacy decision. You may request further information about these safeguards at privacy@newone.xyz.

9Your Rights and Choices

Subject to the law applicable to you, you may have the right to:

Know what Personal Information we hold about you and how we use and disclose it.
Access a copy of that information, in a portable format where required.
Correct information that is inaccurate.
Delete information we hold about you.
Opt out of the sale or sharing of Personal Information — noting that we do not engage in either.
Limit the use of Sensitive Personal Information.
Object to or restrict certain processing, or withdraw consent you previously gave.
Not be discriminated against for exercising any of these rights.
Lodge a complaint with your data protection or consumer protection authority.

To exercise a right, contact privacy@newone.xyz. We will verify your request by reasonable means before acting on it, and you may use an authorized agent where the law permits. Please note that we cannot delete data recorded on a public Blockchain, because we do not control it, and that we may retain information where we have a legal obligation or a legitimate need to do so.

10Protection of Minors

The Services are not directed to, and may not be used by, anyone under 18. We do not knowingly collect Personal Information from children. If we learn that we have collected information from a person under 18, we will delete it promptly. A parent or guardian who believes we may hold such information should contact privacy@newone.xyz.

11Cookies and Similar Technologies

The Site uses cookies and similar technologies that are strictly necessary for it to function, together with analytics cookies that help us understand how the Site is used. We do not use advertising cookies.

You can manage or block cookies through your browser settings. Blocking strictly necessary cookies may prevent parts of the Site from working. The App itself does not use browser cookies, though embedded Third-Party Services accessed through the in-app browser may set their own.

12Security and Retention

We maintain administrative, technical, and physical safeguards designed to protect Personal Information, including encryption in transit and at rest, least-privilege access controls, audit logging, and periodic review. No system is perfectly secure, and we cannot guarantee absolute security.

We retain Personal Information only for as long as necessary for the purposes described in this Statement, or for a longer period where required by law. When information is no longer needed, we delete it or irreversibly anonymize it. Diagnostic and log data is typically retained for a limited period measured in months rather than years.

Your Recovery Phrase is not part of this analysis, because we never hold it. Its security depends entirely on how you store it.

13Marketing Communications

We send marketing communications only where you have opted in or where otherwise permitted by law. Every marketing message includes a means of unsubscribing, and you may also opt out at privacy@newone.xyz.

Operational messages — security alerts, changes to this Agreement, and responses to your support requests — are necessary to the Services and are not subject to marketing opt-out.

14Changes to This Statement

We may update this Privacy Statement to reflect changes in our practices or in the law. The effective date at the top of this page will always show the current version. Where a change is material, we will provide prominent notice before it takes effect. Continued use of the Services after that date indicates acceptance.

15Language

This Agreement is drafted in English. If we publish a translation and any inconsistency arises, the English version prevails to the extent permitted by applicable law.

16Governing Law and Disputes

This Privacy Statement is governed by the law identified in Section 14 of Part I, and disputes relating to it are resolved in accordance with Section 15 of Part I. This does not affect any independent right you may have to lodge a complaint with a data protection or consumer protection authority in your jurisdiction.

17Jurisdictional Appendices

Appendix A — California (CCPA/CPRA)

If you are a California resident, you have the rights to know, access, correct, delete, opt out of sale or sharing, and limit the use of Sensitive Personal Information, together with the right not to be discriminated against for exercising them. In the preceding twelve months we have collected the categories of information described in Section 4 — identifiers, internet and network activity, approximate geolocation, and information you voluntarily provide — for the business purposes described in Section 5, and have disclosed them to the categories of recipients described in Section 6. We have not sold or shared Personal Information and do not use or disclose Sensitive Personal Information for purposes requiring a right to limit. Requests may be submitted to privacy@newone.xyz and may be made by an authorized agent.

Appendix B — Other U.S. States

Residents of Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, and other states with comprehensive privacy statutes have rights to confirm processing, access, correct, delete, and obtain a portable copy of their Personal Information, and to opt out of targeted advertising, sale, and certain profiling. We do not engage in targeted advertising or in the sale of Personal Information. Where your state provides a right to appeal a denied request, you may appeal by replying to our response or writing to privacy@newone.xyz; we will inform you of the outcome and of your right to contact your state attorney general.

Appendix C — European Economic Area and United Kingdom (GDPR / UK GDPR)

If you are in the EEA or the UK, we process Personal Information on the legal bases identified in Section 5. You have the rights of access, rectification, erasure, restriction, portability, and objection, and the right to withdraw consent at any time without affecting the lawfulness of prior processing. International transfers are protected by the safeguards described in Section 8. You may lodge a complaint with your national supervisory authority or, in the United Kingdom, with the Information Commissioner's Office.

Appendix D — Asia-Pacific

Singapore: we handle Personal Information in accordance with the Personal Data Protection Act, including its consent, notification, access, correction, and transfer limitation obligations, and will notify affected individuals and the Commission of a notifiable data breach as required. Hong Kong: we observe the Data Protection Principles under the Personal Data (Privacy) Ordinance, including in relation to transfers outside Hong Kong. Australia: we handle Personal Information in accordance with the Australian Privacy Principles under the Privacy Act 1988, including in relation to overseas disclosure, and complaints may be directed to the Office of the Australian Information Commissioner.