What is Personal Data
“Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); 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.
How we collect Personal Data
If you install and use the Trinity Wallet App on your phone or other device, the IOTA Foundation may collect and process Personal Data required for the operation of the App and management and fulfilment of the App services.
Further, the IOTA Foundation may collect and process Personal Data like your email address or phone number when:
you contact IOTA, or request that IOTA contacts you, for any reason, or
you submit your Personal Data to IOTA for any reason.
Which Personal Data do we collect
It is crucial to note that private keys of the users are never transmitted to the IOTA Foundation, so it is not possible for the IOTA Foundation to access a user’s crypto assets in any case.
We may collect information relating to the general use of the Trinity Wallet App such as errors, log information concerning any errors encountered in the Trinity Wallet App and other related information relevant to IOTA's provision of the services, for the purpose of administration and error analysis to help IOTA improve its services.
Purpose of processing of Personal Data
We process the Personal Data in order to enable the operation and use of the Trinity Wallet App as well as for the administration and management of the Trinity Wallet App and the services offered via it.
Lawful basis for processing of Personal Data
we have obtained your explicit prior consent to the processing (this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way);
the processing is necessary in connection with any contractual relationship that you may enter into with us;
the processing is required by applicable law;
the processing is necessary to protect the vital interests of any individual; or
we have a legitimate interest in carrying out the processing for the purpose of managing, operating or promoting our business, and that legitimate interest is not overridden by your interests, fundamental rights, or freedoms.
How we protect and store Personal Data
We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
pseudonymisation and encryption of Personal Data;
the ability to ensure the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
the ability to restore the availability and access to Personal Data in a timely manner in the event of a physical or technical incident;
a process for regular testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing.
In assessing the appropriate level of security account shall be taken in particular of the risks that are presented by processing, in particular from accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to Personal Data transmitted, stored or otherwise processed.
How we share and disclose Personal Data
In order to properly operate the Trinity Wallet App and to be able to provide you the services offered via the Trinity Wallet App, we use the following analytics software during the operation of the App:
We use Bugsnag of Bugsnag Inc., 939 Harrison St, San Francisco, CA 94107, USA (“Bugsnag”) to collect crash and error logs that occur while a user is using the app. When an error occurs the unique identifier in an anonymized form and information about your settings will be transferred to Bugsnag. Further information you can find under http://docs.bugsnag.com/legal/privacy-policy.
Google SafetyNet Attestation API
We use Google SafetyNet Attestation API of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google SafetyNet”). Google SafetyNet provides device attestation to protect the app. It is used to check if an Android device is rooted, modified, or otherwise compromised. Hardware and software information, such as device and application data and the results of integrity checks are sent to Google where it is matched against a database of devices that have passed the Android Compatibility Test Suite. The data is sent directly to Google. Further information you can find under https://policies.google.com/privacy.
We use various websites to check your connection to the internet while using Trinity. Trinity Desktop may contact GitHub to check for app updates in order to provide the auto-update functionality. When accessing these websites, your data is handled in accordance with their respective privacy policies. If Trinity cannot connect to a website, it will attempt to connect to the next website in the list. The check is conducted in the following order:
Providers of Operating Systems and Telecommunication Services
Any transmission of data from your device depends on the operating system, the telecommunication network provider as well as other providers of data communication (e.g. Wi-Fi provider) used. Please observe the data protection notices of these companies.
We may use further data processors during the operation of the Trinity Wallet App. When we are involving data processors into the performance of our services and contractual obligations and such involvement requires the sharing of Personal Data, we have entered with the data processors into data processing agreements according to Art. 28 of the European General Data Protection Regulation 2016/679 (“GDPR”) and, as far as required, further appropriate safeguards according to Art. 46-49 GDPR. The list of actual data processors to which we disclose your Personal Data can be requested by e-mail to firstname.lastname@example.org
Please note that IOTA may collect your Personal Data directly from the country where you are based and store it on servers in Europe and the United States of America. For the USA there does not exist an adequacy decision by the European Commission, guaranteeing an adequate data privacy level. Therefore IOTA has implemented appropriate safeguards to protect your Personal Data in the USA. A copy of the safeguards may be obtained by e-mail to email@example.com
Processing of your sensitive Personal Data
We do not seek to collect or otherwise process your sensitive Personal Data, except where:
the processing is required or permitted by applicable law;
the processing is necessary for the establishment, exercise or defence of legal rights; or
we have, in accordance with applicable law, obtained your explicit consent prior to processing your sensitive Personal Data (as above, this legal basis is only used in relation to processing that is entirely voluntary – it is not used for processing that is necessary or obligatory in any way).
Consequences in case we may not collect your Personal Data
We need your Personal Data to enable your use of the Trinity Wallet App and to provide you with the services offered via the Trinity Wallet App in order to perform our contractual obligations towards you. Without providing such Personal Data, we may not be able to provide you the services you are intending to receive.
Consent and withdrawal
Any consent is provided freely. If you give your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. After your withdrawal we will stop processing your Personal Data, including storage, unless further data processing is required and legally permitted. This paragraph is only relevant for processing that is entirely voluntary – it does not apply for processing that is necessary or obligatory in any way, as is for example the case with regard to Personal Data required for the installation and the operation of the Trinity Wallet App.
To withdraw your consent, please send us an e-mail to firstname.lastname@example.org or a letter to IOTA Foundation, c/o Nextland, Strassburgerstr. 55, 10405 Berlin.
Legitimate Interest and Right to Object
You may object to the processing of your personal data based on legitimate interests of IOTA Foundation or third parties. Unless your objection is directed solely against direct marketing by IOTA Foundation, you have to explain your special situation, which makes the processing of your personal data based on legitimate interests unacceptable for you.
To object, please send us an e-mail to email@example.com or a letter to IOTA Foundation, c/o Nextland, Strassburgerstr. 55, 10405 Berlin.
When we erase your Personal Data
We erase your Personal Data automatically when they are no longer required for the purposes listed above. We also erase your Personal Data according to your request and if further storage is neither required nor permitted by applicable laws. Further storage only occurs as long as and as far as it is designated by the EU or Member States legislation in EU Acts, Law, or other regulations, that IOTA Foundation is subject to (e.g. transactional data may be stored for a period of 10 years).
Your rights related to data privacy
You have the right to request access to and rectification or erasure of your Personal Data, or restriction of their processing. Furthermore, you have the right to request data portability. If you are in the EU you have the right to file a complaint to the relevant data protection authority, e.g. the Berlin Data Protection Authority (Berliner Beauftragte für Datenschutz und Informationsfreiheit).
You have the right to obtain from us the information as to whether Personal Data concerning you are being processed, the purpose of the processing and the categories of Personal Data concerned.
A copy of the Personal Data undergoing processing can be requested.
Our contact information, data controller
If you have a direct business relationship with us, we are a data controller according to Art. 4 para. 7 GDPR. For any requests, you can contact us as follows:
IOTA Foundation, c/o Nextland, Strassburgerstr. 55, 10405 Berlin.
You can contact our data privacy officer as follows: