Account Abstraction Disclaimer

Data shared with Alchemy (Account Abstraction ONLY)

When you interact with your Smart Wallet, our system uses services provided by Alchemy Insights, Inc. (“Alchemy”) to enable certain technical functions. To operate these services securely and reliably, your device’s IP address is transmitted to Alchemy as part of the network request.

We do not share any directly identifying information (such as your name or real email address) with Alchemy. Email addresses used for authentication are automatically replaced with anonymized aliases generated by our system, ensuring that Alchemy cannot identify or contact you directly.

Only for services related to Account Abstraction and Smart Wallets, Alchemy acts as our data processor under the EU General Data Protection Regulation (GDPR). They process this limited technical data only to deliver the service and maintain security, in line with their Data Protection Addendum and standard contractual clauses for international data transfers.

We ensure that:

• only the minimum necessary data (your IP address and anonymized identifiers) is shared for service functionality,

• the transfer is covered by EU-approved safeguards (SCCs), and

• all other personal data remains controlled and anonymized within our infrastructure.