" 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.
If you install and use the Trinity Wallet App on your phone, 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:
If you enable email notifications, IOTA Foundation could store your email address on its servers.
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.
The IOTA Foundation keeps access logs to our servers, which may contain IP address, time and access details.
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 Foundation's provision of the services, for the purpose of administration and error analysis to help IOTA Foundation improve its services.
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.
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We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, including inter alia as appropriate:
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.
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:
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.
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.
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 data processors to which we disclose your Personal Data can be requested by e-mail to email@example.com
Please note that IOTA Foundation may collect your Personal Data directly from the country where you are based and stores 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 Foundation has implemented appropriate safeguards to protect your Personal Data in the USA. A copy of the safeguards may be obtained by e-mail to firstname.lastname@example.org
We do not seek to collect or otherwise process your sensitive Personal Data, except where:
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.
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 email@example.com a letter to IOTA Foundation, c/o Nextland, Strassburgerstr. 55, 10405 Berlin.
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.
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 object to processing as well as to request data portability. If you are in the EU you have the right to file a complaint to 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.
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: