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Privacy Policy Generator for crypto

Written for wallet addresses as personal data, on-chain permanence and the KYC that erasure cannot touch.

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A crypto privacy policy has to be honest about two things generic templates get wrong: that a wallet address is personal data, and that erasure stops at the chain boundary. Getting those two paragraphs right is worth more than the rest of the document combined.

The foundational problem in crypto privacy documentation is that a wallet address is usually personal data. Once an address is linked to an identity - through KYC, an exchange deposit, or on-chain analysis - every transaction that address ever made becomes attributable, permanently and publicly.

That collides directly with erasure. On-chain data cannot be deleted, and a privacy policy that promises deletion of everything on request is describing something the technology cannot do. The honest position explains what can be deleted off-chain and what cannot be touched on-chain, and why.

Regulated activity adds the opposite pressure. Where you perform KYC under anti-money-laundering rules, retention is mandatory, the Travel Rule requires transmitting originator and beneficiary information with transfers, and sanctions screening runs continuously against identity data you are obliged to keep.

What a privacy policy for a crypto or Web3 product has to cover

Wallet addresses treated as personal data, with what that means for transaction history
The on-chain and off-chain boundary, and exactly what erasure can and cannot reach
RPC providers, custody partners and on-chain analytics vendors, named as recipients
KYC data and the statutory retention that overrides deletion requests
Automated screening decisions and the route to human review

How a crypto or Web3 product actually moves personal data

Wallet connection

Connecting a wallet exposes the address and its full history to the application, which is a collection event most interfaces do not describe.

KYC and identity verification

Documents, selfies and liveness checks through a specialist vendor, retained under AML rules.

On-chain analytics

Chainalysis, TRM and similar services cluster addresses and attribute them, which is profiling of an identifiable person.

RPC providers and node infrastructure

Every read and write passes through an RPC endpoint that sees the address and the IP behind it.

Off-chain user accounts

Email, preferences and support history held conventionally alongside on-chain identity.

Airdrops and eligibility snapshots

Eligibility analysis links addresses to behaviour and often to identity, and the snapshot persists.

Third parties the draft will ask you about

Alchemy or Infura · Chainalysis or TRM Labs · Sumsub or Persona · Fireblocks · AWS · Intercom · Stripe for fiat on-ramps

The rules that apply

Wallet addresses as personal data

An address linked or linkable to an individual is personal data, which brings the whole transaction history it anchors into scope.

On-chain immutability versus erasure

Data written to a public chain cannot be deleted. The policy has to explain the boundary rather than promising deletion it cannot deliver.

AML and KYC retention

Where you are a regulated entity, identity and transaction records must be retained for statutory periods regardless of an erasure request.

Travel Rule obligations

Transfers above thresholds require originator and beneficiary information to travel with the transaction between providers.

Sanctions screening

Continuous screening against identity and address data, with restrictions on what may be disclosed to the customer.

What the generated privacy policy contains

Identity and contact details of the controller
Your legal entity, trading name, registered address and a working contact route - plus a representative or DPO where one is required.
Categories of personal data and their sources
What you collect directly, what you observe automatically, and what you receive from third parties such as payment providers or ad platforms.
Purposes and lawful basis, purpose by purpose
A table that pairs each processing purpose with its lawful basis rather than listing all six bases and hoping one fits.
Recipients and sub-processors
The categories of recipient, and for the ones that matter to users - payment, hosting, analytics, support - the named provider.
International transfers and their safeguards
Where data leaves its home jurisdiction, and the mechanism relied on: adequacy, standard contractual clauses, the UK addendum or IDTA.
Retention periods per data category
Concrete periods or the criteria used to set them, which is what regulators ask for first when a complaint lands.
Rights and how to exercise them
Access, rectification, erasure, portability, objection and restriction, with the actual route to make a request and the deadline you work to.
Complaints and supervisory authority
The regulator a user can escalate to, named, with a link - not a generic "your local authority".

Crypto compliance essentials

State plainly that wallet addresses are personal data
And explain what that means for the transaction history behind them.
Draw the on-chain and off-chain boundary
What you can delete, what you cannot, and why.
Disclose the infrastructure chain
RPC providers, analytics vendors, custody partners and KYC processors.
Document AML retention as a legal obligation
With the period, so erasure refusals can be explained.
Explain on-chain analytics and any Article 22 position
Where screening outcomes restrict or freeze accounts automatically.
Identify who the controller actually is
Even where the protocol is decentralised, the front end and the accounts are not.

Where this usually goes wrong

Claiming wallet addresses are anonymous

Pseudonymous is not anonymous, and once linked the whole history is attributable. Regulators have said so directly.

Promising erasure of on-chain data

It is technically impossible, and promising it is a misrepresentation as well as a compliance failure.

Not disclosing RPC providers

They see the address and the connecting IP on every interaction.

Silence on on-chain analytics

Clustering and attribution services are profiling, and users are entitled to know they are used.

KYC deletion promises that AML law forbids

Retention is mandatory for regulated entities, and the policy should explain why rather than promise otherwise.

Treating a DAO or protocol as having no controller

Someone determines the purposes of the front end, the analytics and the user accounts, and that party is the controller.

Frequently asked questions

Is a wallet address personal data?

Usually yes. It is pseudonymous rather than anonymous, and once linked to an identity - through KYC, an exchange, or chain analysis - it and the transaction history behind it are personal data.

How does the right to erasure work with a blockchain?

It does not reach the chain. You can delete off-chain records, close accounts and stop processing, but on-chain data is immutable. The policy should explain that boundary honestly rather than promise deletion it cannot deliver.

Can I delete KYC records on request?

Where you are a regulated entity, no - anti-money-laundering law requires retention for a statutory period. That is a legal obligation basis that overrides erasure, and the refusal needs explaining.

Does a decentralised protocol need a privacy policy?

The protocol may not, but the front end, the analytics, the RPC relationship and the user accounts have a controller - and that party does.

Is a privacy policy legally required?

If you process personal data, in almost every market yes. GDPR and UK GDPR require the disclosure at the point of collection, CCPA/CPRA requires a notice at collection plus an annually reviewed policy, and app stores and payment processors require a public policy URL before they will list or onboard you.

Can I copy another company’s privacy policy?

It is both a copyright problem and a compliance problem. A copied policy describes someone else’s data flows, processors and retention periods, so it is inaccurate the moment you publish it - and an inaccurate transparency notice is itself a breach of GDPR Article 13.

How often does a privacy policy need updating?

Whenever your processing changes - a new analytics tool, a new payment provider, a new market - and as a backstop, review it annually. CPRA makes the twelve-month review explicit.

Does PolicifyAI give legal advice?

No. PolicifyAI is a technology provider, not a law firm. The output is a structured, jurisdiction-aware draft that a qualified adviser should review before you rely on it.