Here are the parts I saw that could expose personal information while using the wallet.
  • Email Address Association with Wallet:
    • Linking your wallet address with an email address (Section 1.1) may reveal identifiable information if a non-anonymous email (e.g., personal or work email) is used.
  • Account Registration (Section 4):
    • Account creation might require providing personal information to access certain features, though specific data required for the account (beyond being old enough or legal in your jurisdiction) is not detailed.
  • Payment Information via Proton AG (Section 6 and 9):
    • Proton AG handles billing and payments for paid services, meaning Proton might collect payment details (e.g., credit card info, transaction history) when processing subscriptions.
  • Third-Party Integrations (Section 8):
    • When using services like on-ramps (e.g., Ramp, Moonpay, or Banxa) or price information providers (e.g., CoinMarketCap), these third-party providers may collect personal information or require identity verification (under KYC regulations). This would be handled according to their privacy policies, which could involve collecting personal identification data.
  • Bitcoin via Email Feature (Section 3):
    • The feature that allows users to send Bitcoin to an email address could expose both the sender’s and recipient’s email identities in relation to the transaction.
  • Legal Compliance and Enforcement (Section 5):
    • Account suspension or legal orders may compel Proton Financial AG to comply with law enforcement or government authorities, potentially exposing user identities if legal action is required or subpoenas are issued.
  • Use of Proton AG Services (Section 9):
    • In cases where users employ Proton AG services (e.g., Proton Mail, Proton Visionary) alongside Proton Financial AG, Proton AG's Terms of Service and policies apply, which might collect more personal data (such as email metadata, account activity logs, or payment info).