We do not intend to collect personal data of children or persons under the age of 18 (eighteen) years old.
Please note that this Policy does not apply to information collected through third-party websites or that you submit to us through email, text message or other electronic message or offline.
If you are visiting the Sites from the European Union (EU), see our Notice to EU Data Subjects below for our legal bases for processing and transfer of your data.
WHAT WE COLLECT
We do not require you to register or log in. We do not have access to your funds (private keys). We do not require your name or email address.
We process the following categories of information:
1 – Information You Give Us
a – Subscription – The email address you give us to subscribe to the electronic mailing list if you wish. You will have the ability to opt-out of our marketing and promotional communications.
b – Issue Resolving – You can submit some data to support in case this data needed to resolve issues (for example, with partners).
c – Any information related to legal requirements – Information to comply with our anti-money laundering (AML) obligations under applicable law.
2 – Information We Collect When You Use Our Services
a – Device information – Technical details, such as information about your hardware, device manufacturer, unique device identifiers, information about software, the operating system, and version running on your system or device, browser and plug-ins, and mobile network information.
b – Your activity – Information about your experience while using our Services, such as response time, crash reports and errors, length of visit, the information provided to our support team. This is statistical non-personified data about our users’ browsing actions and patterns.
3 – Information Automatically Collected
a – Log Data – We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“). Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics. We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding it’s features and functionality and tailoring it to our users’ needs and preferences.
c – Analytics – We also may use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here: https://www.google.com/analytics/terms/us.html. Please note that Enno Wallet does not use Google Analytics in its wallet.
USE OF PERSONAL INFORMATION
We will only process information that is necessary for the purpose for which it has been collected.
1 – Consent rules and related purposes
Where you have provided your consent, we may use and process your information to contact you about offers, promotions, events, services or information which we think will be of interest to you. We also process personal data we obtain from optional cookies that we set on the App based on your consent. In case if the legal basis is consent, you can withdraw your consent at any time via available options.
If you do withdraw your consent, and if we do not have another legal basis for the processing of your data, then we will stop the processing of your personal data and will delete in specific situations, including in case if you request the deletion of your personal data and we are obliged to delete your personal data according to the applicable law.
If we have another legal basis for the processing of your data, then we will continue to do so, subject to your legal interests and rights.
2 – Contract rules and related purposes
We use and process your personal data where this is necessary to perform a contract or the Terms of Service with you and to fulfill and complete your transactions entered into with us or provide the Services.
3 – Legitimate interests’ rules and related purposes
We use and process your personal data as set out below where it is necessary for us to carry out activities for which it is in our legitimate interests as a business to do so.
a – User support – to respond to correspondence you send to us and fulfill the requests you make to us; to help you through live-chat. Promotion of our business: to contact you with marketing information in certain cases; to contact you with targeted advertising delivered online through social media, search engines, third party websites or apps and applications, and other platforms operated by other companies unless you object or such activity requires your consent.
b – Communicate with you – to communicate with you including to respond to queries, complaints, or claims and to manage legal and regulatory requests and requirements; to enforce or protect our legal rights or to establish, bring or defend legal claims. Administrative and technical aspects: for network and information security purposes; to comply with a request from you in connection with the exercise of your rights; to inform you of updates to our terms and policies; for cookies that are essential for our App to function properly.
4 – Legal obligation’ rules and related purposes
We will process your personal data to comply with our legal or regulatory requirements, for example, anti-money laundering (AML), and know your client (KYC) rules.
SHARING AND PROCESSING OF PERSONAL INFORMATION
1 – Disclosure of personal data
a – Companies or organizations to which we pass the responsibility to handle the Services on our behalf, or business partners or contractors with which we have a data processing agreement or addendum;
b – Government or law enforcement officials or court in cases provided by law.
2 – Sharing of personal data
a – to provide our Services to you or to administer them;
b – to comply with any applicable laws or regulations,
c – to detect and investigate fraudulent or unlawful activity and respond to claims and legal process;
d – to prevent or stop activity we consider to be, or to pose a risk of being, illegal, unethical or legally actionable or that poses a threat to the safety of you, another person, or the public generally;
e – in case of any reorganizations of our company or transfer of control with the transfer of all information to the relevant third party.
3 – Purposes of the processing of personal data
a – Providing services. Legal basis: Contract.
b – Providing newsletters/offers/updates which may be interesting to you. Legal basis: Consent for newsletters; Legitimate Interests for offers and updates.
c – Compliance with applicable anti-money laundering and know your client rules. Legal basis: Legal obligation.
e – Operating and improving the App (testing features, interacting with feedback platforms, managing landing pages, heat mapping the App, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your data and in some cases using third parties to do this). Legal basis: Legitimate Interests.
d – Customer support (notifying you of any changes to the App, services, solving issues, any bug fixing sending you announcements, updates, and security alerts, which we send through a push notification, and responding to your requests, questions, and feedback). Legal basis: Legitimate Interests.
NOTICE TO EU DATA SUBJECTS
We protect your personal data also in accordance with EU legal requirements.
1 – Personal Information
2 – Sensitive Data
Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents.
3 – Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us at [email protected]
a – To provide our service. Legal basis: Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Service.
b – To communicate with you / To optimize our platform / For compliance, fraud prevention, and safety / To provide our service. Legal basis: These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
c – To comply with law. Legal basis: We use your personal information to comply with applicable laws and our legal obligations, including anti-money laundering (AML) laws and know-your-customer (KYC) requirements.
d – With your consent. Legal basis: Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us at [email protected]
4 – Use for New Purposes
5 – Your Rights
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
a – Opt-out – Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
b – Access – Provide you with information about our processing of your personal information and give you access to your personal information.
c – Correct – Update or correct inaccuracies in your personal information.
d – Delete – Delete your personal information.
e – Transfer – Transfer a machine-readable copy of your personal information to you or a third party of your choice.
f – Restrict – Restrict the processing of your personal information.
g – Object – Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You can submit these requests by email to [email protected] We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
6 – Cross-Border Data Transfer
Whenever we transfer your personal information out of the EEA to the Hong Kong or countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.
NOTICE TO CALIFORNIA RESIDENTS
Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.
This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”
For more details about the personal information we collect from you, please see the “What We Collect” section above. We collect this information for the business and commercial purposes described in the “Use of Personal Information” section above. We share this information with the categories of third parties described in the “Sharing of Personal Information” section above. Company does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out). Please refer to our Cookies Policy for more information regarding the types of third-party cookies, if any, that we use.
Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.
California consumers may make a request pursuant to their rights under the CCPA by contacting us at [email protected] Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.
LAST UPDATED: 15.07.2021