Safeguarding the privacy of our customers is paramount. We handle your personal data transparently and in strict adherence to legal standards. Our robust measures ensure the protection of your information from unauthorized access. This privacy policy delineates the circumstances under which we collect, process, and, if necessary, share your information with third parties.

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Savl Limited ("Savl," "we," "our," and/or "us") prioritizes the privacy of individuals who utilize our websites (including savl.com, referred to as the "Website" or "Site"), applications, or services, as well as any services linked to this Privacy Policy (collectively, our "Services"). This Privacy Policy delineates how we collect, utilize, and disclose Personal Data from users of our Software, Site, and Services. In the context of this Privacy Policy, "Personal Data" pertains to information relating to an identified or identifiable natural person.

Your use of our Site or Services implies consent to the collection, use, and disclosure of your Personal Data as outlined in this Privacy Policy. Additionally, it is subject to our Terms of Use.

Savl Wallet is a non-custodial digital asset software wallet, meaning we do not maintain customer accounts. Personal Data is not required to use Savl Wallet. We may request contact information for account, communications, and customer service purposes. Some advanced services may require compliance with government regulations, and certain third-party API providers may need Personal Data for service usage via Savl Wallet.

INFORMATION WE COLLECT

We may collect Personal Data from various sources, including:

Information You Provide to Us: When you contact us or sign up for our newsletter, we collect any Personal Data you provide, such as your name and email address.

Collection and Processing of Mobile App Data: When you download our mobile app from an app store, certain information is sent to the app store, including your user name, email address, account number, download time, payment details, and device code. The app store may be either the iOS App Store by Apple Inc. or Google Play Store by Google LLC. We have no control over this data collection and are not responsible for it. We process this data only as necessary for downloading the app onto your device.

For more information, please refer to:

Apple’s privacy policy: https://www.apple.com/legal/privacy/

Google’s privacy policy: https://policies.google.com/ 

APPLICATION INFORMATION WE COLLECT

When using our mobile app, we collect additional personal data necessary to provide app functionalities, improve it, and ensure stability and safety. The specific data processed and stored depends on app usage. Examples include:

• User's mobile phone number for certain app features
• Email address and country selected during registration for service security
• Preferred fiat currency (e.g., USD, GBP, EUR) to facilitate service use
• Registration date and last profile update for user security
• Individual blockchain addresses and public user addresses for cryptocurrency transactions
• Optional synchronization of contacts for transactions within the app
• User transactions within the app for security
• Technical usage information like hash values and tokens for login simplification. 

AUTOMATICALLY COLLECTED INFORMATION

We may automatically gather information about you and your devices during your use of our Site or Services. This includes your internet protocol (IP) address, web browser type, language, operating system, referring website, a unique pseudonymous User ID specific to Savl for internal enhancement of products and services, pages viewed, duration spent on pages, visit dates and times, clicked hyperlinks, and other website usage details. During exchanges via third-party API providers, we record data like wallet addresses and transaction IDs.

Cookies: We and third-party API providers may use cookies, pixel tags, or similar technologies to gather information. Our third-party partners, such as analytics or advertising partners, might utilize these technologies to collect data about your online activities across various services over time. Cookies are small text files containing alphanumeric characters. We may utilize both session cookies, which vanish after you close your browser, and persistent cookies, which remain after browser closure and may be used during subsequent visits to our Site. For further information on cookies, including how to view, manage, and delete them, please visit www.allaboutcookies.org.

You can restrict cookies by adjusting your internet browser settings to block some or all of them. However, blocking all cookies, including essential ones, may limit your access to parts of our Site and Services. You have the option to configure your browser to block or notify you about receiving cookies, delete cookies, or browse our Site anonymously. Please refer to your browser's instructions or help section for guidance on adjusting settings. If you disagree with our use of cookies or similar technologies storing information on your device, adjust your browser settings accordingly. Note that certain features of our Site or Services may not operate correctly without cookies or these technologies. In cases where applicable law mandates, you'll be prompted to consent to specific cookies and similar technologies before we use or install them on your device.

Information We Receive From Third Parties. We may receive Personal Data about you from third parties, such as data or marketing partners, and merge it with other Personal Data we already possess about you.

Appsflyer: This website utilizes the Appsflyer web analytics service provided by AppsFlyer Ltd. ("Appsflyer''). A list of the data stored and processed by Appsflyer can be found here.

Appsflyer will process this information on our behalf to assess the usage of our online services by users and generate reports on user activities within these online services for analysis and optimization purposes. Appsflyer may need to transfer Customer Data to countries other than the country from which the Data originated, ensuring compliance with all applicable laws.

Regarding the collection, use, and retention of personal data transferred from the European Economic Area or Switzerland to the United States, Appsflyer complies with the EU-U.S. and Swiss-US Privacy Shield Framework. Their data protection policy can be found here.

Your IP address is stored by our partner only in an abbreviated form and evaluated for us, allowing only a rough localization down to the country of origin. AppsFlyer provides End Users with the ability to opt-out of being measured by the Services via email request to [email protected] or by completing the form here.

Sum&Substance: Within our mobile app, we utilize Sum&Substance, a digital identification service provided by Sum and Substance Ltd., to ensure compliance with legal provisions and enhance transaction security. Sum&Substance stores and processes user personal data exclusively on servers within the GDPR's jurisdiction in the European Union. Additionally, your IP address is stored in an abbreviated form for rough localization. For further information, you can review Sum&Substance's data protection policy here.

How we utilize this data:

• To provide, maintain, debug, improve, and enhance our Site and Services.
• To understand and analyze your usage patterns, enabling us to develop new products, services, features, and functionalities.
• To communicate with you, providing updates, responding to inquiries, and delivering customer support.
• For marketing purposes, including the development of promotional materials tailored to your interests.
• To personalize your experience on our Site, recognizing you as a returning visitor.
• To integrate third-party services or applications seamlessly.
• To generate de-identified and/or aggregated data, enhancing our business operations and Services.
• To detect and prevent fraud, security incidents, and address trust and safety concerns.
• For compliance purposes, ensuring adherence to our Terms of Service and legal obligations.
• To engage with third-party API providers, delivering customer service, analytics, and other services.
• For any other specified purposes disclosed at the time of data collection.

LEGAL BASIS FOR PROCESSING EUROPEAN PERSONAL DATA

If you are located in the European Economic Area or the United Kingdom, we only process your Personal Data when we have a valid “legal basis,” including:

• Consent: You have given consent for specific uses of your Personal Data, such as receiving marketing communications or using cookies.
• Contractual necessity: We require your Personal Data to fulfill our contractual obligations, such as responding to your inquiries or providing Services.
• Compliance with a legal obligations: We process your Personal Data to comply with applicable legal obligations, such as tax and accounting requirements.
• Legitimate interests: We (or a third party) have legitimate interests in processing your Personal Data, such as for product development, internal analytics, and enhancing the safety, security, and performance of our Site and Services. We rely on legitimate interests only when they do not override your rights and interests.
   

DATA SHARING

We do not share or disclose Personal Data collected from or about you except as described below or disclosed to you at the time of collection:

• Affiliates: We may share any information received with our affiliates for purposes outlined in this Privacy Policy.
• Analytics Partners:  We utilize analytics services, like Google Analytics, to collect and process certain analytics data, which may extend to your use of other websites and online resources.
• As Required by Law and Similar Disclosures: We may access, preserve, and disclose your Personal Data if compelled to do so to comply with applicable laws, respond to law enforcement requests, or protect the rights, property, and safety of Savl and others.
• Merger, Sale, or Other Asset Transfers: Your Personal Data may be transferred to service providers, advisors, potential third-party API providers, or other parties in connection with corporate transactions such as mergers, acquisitions, or asset transfers.
• Vendors and Service Providers: We may share your information with vendors and service providers engaged in delivering our Services.
• Consent: Your Personal Data may be disclosed with your explicit consent.

International Data Transfer: Your information, including Personal Data, may be transferred to, stored at, and processed by us outside your country of residence, including in the United States, where data protection regulations may differ. By providing information on our Site, you consent to such transfers. We may also transfer Personal Data from the European Economic Area or the United Kingdom to the United States as needed to fulfill requested Services. We will take reasonable steps to treat your Personal Data securely and in line with this Policy.

Security: We employ reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. However, no electronic transmission or storage can be entirely secure. If you suspect a security issue, please notify us promptly.

Retention: We retain Personal Data only as long as necessary to provide customer support and inquiry services. For customer support, we retain information to efficiently handle subsequent requests, unless a longer retention period is required by law.

Third-Parties: Our Site may link to other websites, products, or services not owned or operated by us. We are not responsible for the privacy practices of these third parties. Please review their policies before disclosing Personal Data.

Do Not Track Signals: Some browsers may send "Do Not Track" signals. We do not respond to such signals. Learn more at http://www.allaboutdnt.com.

Minors: Our website, app, and services are not intended for minors under 16. We do not knowingly collect or store information from minors.
 

YOUR RIGHTS AND CHOICES

Under the General Data Protection Regulation (GDPR) of the European Union (EU) and the European Economic Area (EEA), you have the following rights:

• Right to information (chap. 15 GDPR)
• Right to rectification (chap. 16 GDPR) or deletion (chap. 17 GDPR)
• Right to limitation of processing (chap. 18 GDPR)
• Right to object to the processing (chap. 21 GDPR)
• Right to data portability (chap. 20 GDPR)

You also have the right to lodge a complaint with a data protection supervisory authority regarding the processing of your personal data. However, we encourage you to reach out to us directly with any concerns at [email protected] before doing so. Your right to lodge a complaint will not be affected by this. The following rights apply to everyone irrespective of their geographical location:

Opt-out: You have the right to opt-out of: (i) automated decision-making and/or profiling; (ii) any new processing of your Personal Data beyond the original purpose; (iii) any consent previously provided regarding the processing of your Personal Data; or (iv) the transfer of your Personal Data outside the EEA. Your preferences will be applied going forward, without affecting the lawfulness of previous processing. Please note that opting out may render some parts of our Website ineffective.
Access: You can access the information we hold about you by contacting us via the “Contact Information” section below.

Amend: You can update or correct any inaccuracies in your Personal Data by contacting us via the “Contact Information” section below.

Restrict or Object: You may request us to restrict the processing of your Personal Data or object to our processing of it via the “Contact Information” section below.

Move: Your Personal Data is portable, allowing you to move it to other service providers as desired.

Erasure:  In certain situations, such as when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data. Upon your request to delete your personal data, we may require re-verification to prevent unauthorized access or potential account compromise. Once your identity is confirmed, we will proceed with the deletion of your personal data.

Exercising Your Rights: To exercise any of these rights, please contact us via the “Contact Information” section below. In your request, clearly describe: (i) the Personal Data concerned; and (ii) which of the above rights you wish to enforce. For your protection, we only process requests related to the Personal Data associated with the particular email address you use to send us your request, and we may need to verify your identity before processing. We aim to comply with your request as soon as reasonably practicable and, in any event, within thirty (30) days. Please note that there are exceptions and limitations to each of these rights, and while changes you make will be reflected in active user databases instantly or within a reasonable period, we may retain information for backups, archiving, fraud prevention, legal obligations, or other legitimate reasons.

Marketing Communications: You can unsubscribe from our promotional emails using the link provided. Even if you opt-out of promotional messages, you will still receive administrative messages from us.
 

COMPLAINTS

We aim to address any complaints about our collection or use of your Personal Data. If you have a complaint about this Privacy Policy or our practices regarding your Personal Data, please contact us as indicated below. We will respond to your complaint as soon as possible and, in any event, within thirty (30) days. If you feel your complaint hasn’t been adequately resolved, you have the right to contact your local data protection supervisory authority.
 

CONTACT INFORMATION

 If you have questions about your privacy related to the Site or Services or this Privacy Policy, you may contact us at the address below.

Address: 190 Elgin Avenue, George Town, Grand Cayman KY1-9001, Cayman Islands

Email: [email protected]

Telegram: https://t.me/savl_support

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when posted. If we materially change how we use or share Personal Data previously collected, we will attempt to notify you by email or other means.