Privacy Policy | Arctic Wallet

Introduction

The Privacy Policy (‘the Policy’) of the company ARCTIC SOFTWARE OÜ ( ’We’, ’Our’, ‘Us’ or ‘Arctic Wallet‘), registry code: 16260045, informs and explains You (‘You’ or ‘Your’) how We process any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for your identification or identifiability (‘Personal Data’) We receive from You, when you are using the Arctic Wallet’s computer software application (‘the Software‘). We use your Personal Data for operating and improving the Website and for the transfer to the Third Parties in case of using Exchange Services. By using the Website, you agree to the processing of Personal Data in accordance with the Policy.

This Policy sets forth the basic rules and principles by which we process your Personal Data, and mentions our responsibilities while processing your Personal Data according to transparency obligations. While using the Software You agree for Your Personal Data processing in accordance with the Policy and affirm that. In case when You do not agree with the Policy partially or fully, You must stop using the Software. All data collected before above-mentioned refusal will be processed in accordance with Policy until Your direct prohibition is received. We do not intend to collect Personal Data of children or persons under the age of 13 (thirteen) years old.

Definitions

‘Personal Data’ refers herein to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’– any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

’Third Party Services’ (or ’Exchange services’) refers herein to the possibility provided by the third-party software using API:

to exchange one type of Crypto Asset to another one;
to exchange Crypto Asset to fiat money and vice versa.

We do not provide exchange services by ourselves.

Personal data and its processing methods

While providing our services we may collect the following:

IP address;
Cookies on Our web site;
Your contact details, including, Your email address or details of other means of communication you choose to provide Us;
Device information, when You download the Software or visit Our website You may provide some information that may potentially identify You, such as the type (including identifiers) of the device, platform type, mobile phone number, Your internet service provider, operating system, geolocation information, browser You use, browser language, or the pages you visit.
Some of your behavior information may be provided by Our website, such as You visiting the Website, clicking on ads or other similar information. Such information may be received with additional related data (or metadata), such as the time, date, and location related to such information.

We collect Personal Data for the next targets and legal basis:

to provide services;
to perform transactions;
to provide You with information related to providing services;
to grant You access to Our services;
to keep the Software running (managing Your requests, remembering Your settings, hosting, and back-end infrastructure);
to provide newsletters/offers/updates/advertisements which may be interesting to You;
to collect statistical or technical non-personalized data about the use of the Arctic Wallet’s website and the Software;
for the Our justified interest, for the purpose of fulfilling a contract, including for establishing violations of the contract or legislation, as well as to confirm such violations.
in order to comply with legal requirements.

If Personal Data processing is carrying out in accordance with Our justified interests, You have a right to submit objections to such processes.

Arctic Wallet does not store Your private keys, backup phrases or passwords.

We do not store Your Wallet Address Information. When you create a wallet through our services, an encrypted private key pair is automatically generated and stored locally on your device via our software. Under no circumstances do we ever collect an unencrypted private key from you.

Personal data storage

We store Your Personal Data while it is necessary to process data, to protect Our interests or on the grounds provided by legal acts requirements.

Depending on the type of Personal Data, We store data for the following time:

for accounting documents: 7 years from the end of the fiscal year in accordance with the Law;
within the period set by law, if any;
in other cases: 10 years after agreement’s termination (including user agreement) between You and Company.

Our Cookies Policy is available on Our website.

Security

We have implemented various technical and organizational measures to be compliant with applicable Personal Data, privacy, and data security legislation in the countries where We operate or where the applicable law applies to Us. Arctic Wallet is not responsible for the Personal Data protection measures violations if such violations caused by actions performed by You or a third persons.

Links to Third-Party Websites

The Software may contain links to other websites, which are outside Our control and are not covered by the Policy. If You access other sites using the links provided, including the case of using Third Party Services, the operators of these sites may collect information about You that will be used in accordance with their privacy policy, which may differ from Ours.

Your rights and obligations

In accordance with relevant legal acts (primarily – GDPR) You can exercise the following rights by contacting Us:

request an access to Your own Personal Data;
request changes in Your own Personal Data;
request removal of Your own Personal Data;
submit objections to Your own Personal Data processing on any grounds.

Arctic Wallet replies to Your requests and requirements within 1 month and notifies about measures took to perform provided requests and requirements. If Your request or requirement is too complicated or has a large volume Arctic Wallet has a right to prolong the period for reply up to 2 months. If the requests or requirements of the You are obviously not justified or excessive, primarily due to their repetitive nature, Arctic Wallet has the right to refuse performing requests or requirements. You do not need to pay a fee to access information or other rights, but We may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive or refuse to comply with your request in these circumstances. In case when Personal Data is processed by Your consent, he/she always has a right to revoke his consent. If You revoke Your consent for Personal Data processing all the data processing performed before revoke considers to be legitimate and lawful. You must notify Us about changes in Your contact details to keep them up to date.

In case of Your rights violation, You have a right to ask Personal Data Protection Inspectorate or court to protect Your rights.

Your rights and obligations

Your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems.

Communication with Third-Party Servers

Exchange rates, balances, transactions, and other blockchain information may be read from or related to public blockchain nodes. We cannot guarantee the privacy of your transactions.

Legal Limitations

Notwithstanding anything to the contrary in the Policy, We may preserve or disclose Your information if We believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our Users’ rights or property. You acknowledge that the Website is not liable for any illegal or abusive use of your information. You acknowledge that in a case where You share Your information from the Software or the Website in social or other networks, or in other third-party sites and/or platforms, Your information is subject to the privacy policies of such third-party resources. Arctic Wallet may share Your Personal Data with law enforcement, data protection authorities, government officials, and other authorities only when Arctic Wallet is legally bound to do so or has to protect the safety of its users and the Website.

Policy changing

The Policy can be changed to comply with changes in Law, Personal Data processing or under instructions of supervisory authorities. In this case Arctic Wallet updates the Policy provided on the website and informs You about the changes when it is possible.

Contact details and questions

Any questions about this Policy, the processing of Personal Data or data subject’s requests shall be directed to:

ARCTIC SOFTWARE OÜ (registry code 16260045)

Address: Harju maakond, Tallinn, Kesklinna linnaosa, Tornimäe tn 7-50, 10145

Email: [email protected]

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