Privacy Policy

HOT Labs Ltd. (BVI)
HOT Wallet, HOT Bridge, HOT MPC, HOT Protocol
Last Updated: 01/11/2025

This Privacy Policy forms an integral and legally binding component of the Terms of Service governing the use of HOT Wallet, HOT Bridge, HOT MPC, HOT Protocol interfaces, and any related Services provided by HOT Labs Ltd., a company incorporated under the laws of the British Virgin Islands. By using the Services, the User acknowledges that they have read, understood, and agreed to this Privacy Policy as if fully set forth in the main body of the Terms.

This Privacy Policy explains what information HOT Labs collects, how such information may be used or disclosed, and the rights and responsibilities of the User. Because HOT Labs provides non-custodial wallet software, HOT Labs does not collect or store private keys, seed phrases, passwords, key_shift, MPC key shares, or any digital asset credentials.

1. Scope of the Privacy Policy

This Privacy Policy applies to all Services provided by HOT Labs, including the website at https://hot-labs.org/, mobile applications, software tools, APIs, embedded HOT Bridge components, HOT MPC clients, and any interactions facilitated through the HOT Protocol. It also applies to any content, information, or data displayed or transmitted through the Services.

The Privacy Policy does not apply to third-party applications, decentralized protocols, blockchain networks, or external websites that the User may access through HOT Wallet. Those systems operate independently and are governed by their own privacy policies and data-handling terms.

2. Nature of the Services and Data Minimization

HOT Labs operates a strict data minimization principle. The Services are designed so that HOT Labs does not store or access sensitive wallet information, including private keys, seed phrases, key_shift, MPC key shares, or transaction signing credentials.

The Services are non-custodial by design. All wallet credentials remain exclusively under the User's control. HOT Labs does not collect, transmit, or process cryptographic materials required for accessing digital assets. HOT Labs cannot restore lost credentials.

3. Information HOT Labs Does Not Collect

HOT Labs does not collect, store, log, access, or process any of the following:

private keys;
seed phrases;
mnemonic phrases;
passwords or PINs;
biometric identifiers used on the User's device;
key_shift or other MPC User-side cryptographic components;
MPC key shares held by validators;
full wallet backup files;

This is a fundamental principle of the Services, and no exceptions are made.

4. Information HOT Labs May Collect

HOT Labs may collect certain non-sensitive information necessary for maintaining technical operation, improving product performance, and ensuring user experience quality. This information may include:

general device information such as device model, operating system version, language preferences, and software version;
log information related to application performance, crash diagnostics, and error reporting;
anonymous usage analytics related to feature adoption, user interface interactions, and application flows;
IP address, region-level geolocation, or network data used for optimizing connectivity or detecting abusive patterns such as bot activity or denial-of-service attempts;
information transmitted voluntarily by the User through customer communication channels or feedback mechanisms.

HOT Labs does not link collected analytics to specific wallets or blockchain addresses. HOT Labs does not profile Users based on digital asset activity.

5. Information Automatically Stored on the User's Device

HOT Wallet may store limited information locally on the User's device to enable functionality. This may include user preferences, interface settings, non-sensitive configuration information, cached price feeds, cached metadata, or non-private wallet descriptors. None of this information includes private keys, key_shift, or any cryptographic secret.

Local device data is under the User's control and is not transmitted to HOT Labs unless explicitly authorized.

6. Communications with the User

HOT Labs may collect the User's email address or other contact details when voluntarily provided through feedback forms, support requests, or community interaction. This information is used solely for responding to inquiries or providing important service-related notifications.

HOT Labs does not sell, rent, or share personal contact information with advertisers or unrelated third parties.

7. Data from Third-Party Providers

HOT Labs may integrate with third-party analytics, crash reporting, or error logging tools. These providers may collect anonymized performance information as part of their standard operations. HOT Labs ensures that integrated providers adhere to industry-standard privacy requirements and do not access cryptographic or personally sensitive information.

The User acknowledges that interactions with decentralized applications, bridges, staking platforms, or blockchain networks are governed by the privacy policies of those systems, not by this Privacy Policy.

8. How Information Is Used

HOT Labs may use collected information to maintain and improve the Services, including:

performing diagnostics, detecting bugs, and ensuring stability;
analyzing software performance and adoption trends;
improving user interface functionality;
preventing fraud, abuse, or harmful automated activity;
ensuring compliance with applicable laws and regulations;
responding to User inquiries or support requests.

HOT Labs does not use collected information for advertising, behavioral tracking, or creating behavioral profiles.

9. How Information Is Shared

HOT Labs does not sell, rent, or otherwise disclose personal information for commercial purposes.

HOT Labs may share limited operational information only in the following circumstances:

with service providers who assist with analytics or diagnostics;
to comply with legal obligations under BVI law, such as responding to lawful subpoenas or court orders;
to protect the rights, safety, or property of HOT Labs, Users, or third parties;
to prevent or investigate fraud or security threats.

HOT Labs does not share private keys, signing credentials, or any related information because HOT Labs never possesses such information.

10. No Access to Digital Assets or Wallet Contents

HOT Labs does not access the contents of the User's wallet, view digital asset balances, or monitor blockchain interactions tied to a specific User. Any wallet information displayed within the interface is retrieved directly from public blockchain networks and rendered locally.

HOT Labs has no ability to access or extract asset ownership data, NFT metadata, or transaction history.

11. Data Retention

HOT Labs retains only the minimal information necessary for operational or legal purposes. Retention periods differ depending on the type of data collected, but HOT Labs strives to limit retention to what is required for performance monitoring, compliance obligations, or security.

If the User provides contact information voluntarily, HOT Labs may retain such information for communication or safety purposes. HOT Labs does not retain blockchain data or wallet-related information.

12. User Rights Regarding Personal Information

Depending on jurisdiction, the User may have certain rights related to access, correction, deletion, data portability, or restriction of personal data. HOT Labs will make reasonable efforts to honor such rights in accordance with applicable privacy legislation, to the extent that such obligations do not conflict with the fundamental non-custodial design of the Services.

Because HOT Labs does not store sensitive wallet data, there is no mechanism for retrieving or deleting private keys, seed phrases, key_shift, or MPC key shares.

13. Protection of User Information

HOT Labs employs industry-standard security measures to protect information against unauthorized access, alteration, disclosure, or destruction. However, the User acknowledges that no method of electronic storage or transmission is entirely secure.

The User bears sole responsibility for protecting their wallet credentials and device security.

14. International Data Transfers

HOT Labs operates globally and may process information in multiple jurisdictions. By using the Services, the User consents to the transfer of information to the British Virgin Islands or other jurisdictions where HOT Labs or its service providers operate. All such transfers comply with applicable laws and protections.

15. Children's Privacy

The Services are intended for Users aged eighteen or older. HOT Labs does not knowingly collect personal information from individuals under the age of eighteen. If such information is inadvertently collected, HOT Labs will take steps to delete it.

16. Changes to This Privacy Policy

HOT Labs may update this Privacy Policy from time to time. Material changes shall be communicated through the Services or through public posting. Continued use of the Services following changes constitutes acceptance of the updated Privacy Policy.

17. Relationship to the Terms of Service

This Privacy Policy forms part of the Terms of Service. In the event of conflict between this Privacy Policy and other sections of the Terms, the Terms shall prevail except where prohibited by law.

18. Additional Provisions

The headings contained in these Terms are for reference purposes only and shall have no effect on the interpretation or construction of these Terms. References to singular terms include the plural, and references to the plural include the singular, unless the context clearly indicates otherwise. Any reference to "including" shall mean "including without limitation," unless expressly stated otherwise.

Nothing in these Terms shall be construed as creating a partnership, joint venture, employment relationship, agency relationship, fiduciary duty, or other form of legal association between the User and HOT Labs. The User agrees that HOT Labs is not acting as a broker, advisor, custodian, trustee, intermediary, or agent in connection with any digital asset activities.

If any governmental authority notifies HOT Labs of illegal or prohibited activities associated with a specific User, HOT Labs reserves the right, without obligation, to restrict the User's ability to access software interfaces or to provide notice to relevant authorities to the extent required by applicable law. However, due to the non-custodial design, HOT Labs cannot take possession of digital assets or freeze User funds.

19. Language of the Agreement

These Terms are written in English. If these Terms are translated into any other language, the English version shall prevail to the fullest extent permitted by law. Any ambiguity or dispute concerning translation shall be resolved in favor of the English version.

20. Contact Information

If the User has questions, concerns, or complaints regarding the Services, these Terms, or the Privacy Policy, they may contact HOT Labs at the following address:

HOT Labs Ltd.
Email: contact@hot-labs.org
Website: https://hot-labs.org/

HOT Labs will make commercially reasonable efforts to respond to legitimate inquiries but does not guarantee availability of support or turnaround time for responses.

21. Notices to Users

HOT Labs may deliver notices, updates, or service-related messages through email, application notifications, website publications, or any other method reasonably selected by HOT Labs. Notices provided through these channels are deemed effective when delivered or posted.

The User is responsible for reviewing all notices and maintaining the ability to receive communications through provided channels.

22. Acknowledgment by the User

By accessing or using the Services, the User acknowledges and agrees that:

they have read and understood all provisions of these Terms, including the embedded Privacy Policy;
they voluntarily accept the risks associated with blockchain technologies, MPC systems, and decentralized protocols;
they recognize that HOT Labs does not possess, store, or control their private keys, seed phrases, key_shift, or MPC key shares;
they accept that wallet access cannot be restored by HOT Labs under any circumstances;
they assume full responsibility for securing their credentials and devices;
they release HOT Labs from liability to the fullest extent permitted by law.

The User further acknowledges that no representation, statement, or marketing material shall modify the strict non-custodial nature of the Services.

23. Effective Date

These Terms of Service, including the embedded Privacy Policy, become effective on the date listed at the beginning of the document and apply to all use of the Services from that date forward. Continued use of the Services after updates to these Terms constitutes acceptance of the revised version.

24. Execution and Acceptance

No physical signature is required for these Terms to become binding. By accessing, downloading, or using HOT Wallet, HOT Bridge, HOT MPC, or any associated Services, the User is deemed to have executed and accepted these Terms in full.

The User's acceptance is legally equivalent to signing a written agreement and creates a binding and enforceable contract between HOT Labs Ltd. and the User under the laws of the British Virgin Islands.