Savl Wallet is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your Personal Data to us to use the Savl Wallet. If you sign up for our newsletter or provide your Personal Data in a customer service ticket, that information will be collected by us. However, certain advanced services may require government-level compliance, and certain third-party API providers may require you to provide them with Personal Data to use their services through the Savl Wallet.
INFORMATION WE COLLECT
We may collect Personal Data from or about you or your devices from various sources, as described below.
Information You Provide to Us. When you contact us or sign up for our newsletter, we collect any Personal Data you provide to us, such as your name and email address.
Collection and Processing of Mobile App Data. When you download our mobile app from an app store, the necessary information is sent to the app store, in particular the user name, email address, and customer number of your account, the time of the download, the payment information, and the individual device code. Depending on the end device used, the app store will either be the iOS App Store by Apple Inc. (“Apple”) or Google Play Store by Google LLC. (“Google”). We have no influence on this data collection and are not responsible for it. We process such data only to the extent necessary for downloading the mobile app onto your mobile device.
APPLICATION INFORMATION WE COLLECT
When you use our mobile app, we collect additional personal data that we require to provide you with the functions of our mobile app as well as to improve it and to ensure the stability and safety of use. The nature and composition of the data processed and stored by us depend on the concrete use of our app by the end user. The data stored and processed by us are, for example:
AUTOMATICALLY COLLECTED INFORMATION
We may automatically collect information about you and your devices when you use our Site or Services. For example, when you visit our Website, we collect your internet protocol (IP) address, web browser type, web browser language, operating system type, the website you visited before browsing our website, a pseudonymous User ID that is unique to Savl for internal use in improving its products and services, the pages you view, the length of time you spend on a page, the dates and times of your visits, the hyperlinks you click on, and other information about your use of our Website. When performing an exchange through a third-party API provider, we log information such as the wallet addresses and transaction IDs.
Cookies. We (and third-party API providers) may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics or advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site.
For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Information We Receive From Third Parties. We may receive Personal Data about you from third parties, such as data or marketing partners, and combine it with other Personal Data we have about you.
Appsflyer. This website uses the Appsflyer web analytics service provided by AppsFlyer Ltd. ("Appsflyer''). A list of the data stored and processed by Appsflyer can be found here: https://www.appsflyer.com/services-privacy-policy/
Appsflyer will process this information in our commission in order to evaluate the use of our online services by the users and generate reports on user activities within these online services for the purposes of analysis and optimization of our services.
Appsflyer may need to transfer Customer Data to countries other than the country from which the Data originated. Any such transfer shall be done in compliance with all applicable laws. With regards to 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 as set forth by the U.S. Department of Commerce, by which Appsflyer demonstrates in accordance with chaps 45, 46 GDPR that it complies with the level of data protection in accordance with the GDPR. The data protection policy of Appsflyer can be found here: https://www.appsflyer.com/services-privacy-policy
Your IP address is stored by our partner only in an abbreviated form and evaluated for us so that only a rough localization of your IP down to the country of origin is possible. AppsFlyer provides End Users with the ability to opt-out of being measured by the Services by emailing a request to [email protected] or by completing the form here: https://www.appsflyer.com/optout/
Sum&Substance. Within the application of our mobile app we make use of the digital identification service Sum&Substance of the Sum and Substance Ltd. Sum&Substance will store and process the following information on our behalf, in order to adhere to the legal provisions relating to the services offered by us in our mobile app and to support the security of the transactions carried out via our mobile app.
Sum&Substance exclusively stores the personal data of users on a server within the area of application of the GDPR in the European Union.
Your IP address is stored by our partner only in an abbreviated form and evaluated for us so that only a rough localization of your IP down to the country of origin is possible.
The data protection policy of Sum&Substance can be found here: https://sumsub.com/security-compliance/
How we use this data:
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 when:
We do not share or otherwise disclose Personal Data we collect from or about you except as described below or otherwise disclosed to you at the time of collection:
INTERNATIONAL DATA TRANSFERS
Your information, including the Personal Data that you provide to us, may be transferred to, stored at, and processed by us outside the country in which you reside, including, but not limited to, the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By providing any information, including Personal Data, on our Site, you consent to such transfer, storage, and processing. We may also transfer Personal Data from the European Economic Area or the United Kingdom to the United States, as needed, to perform the Services that you have requested from us. We will take steps that we believe reasonably necessary to treat your Personal Data securely and in accordance with this Policy.
We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. However, as no electronic transmission or storage of Personal Data can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Data. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us via the “Contact Information” section below.
We will only retain your Personal Data as long as reasonably required for us to provide the requested customer support and inquiry services. In the context of customer support, we retain information sufficient to connect subsequent requests from the same user in order to provide efficient service unless a longer retention period is required or permitted by law (for example, for regulatory purposes).
DO NOT TRACK SIGNALS
Some Internet browsers may be configured to send "Do Not Track" signals to the online sites that you visit. There is no accepted standard for responding to Do Not Track signals, and we do not respond to such signals. To learn more about "Do Not Track," please visit http://www.allaboutdnt.com
Our website, our mobile app and the services offered by us are not conceived or designed for minors, children under the age of 16. We will not knowingly collect or store information from minors.
YOUR RIGHTS AND CHOICES
Under the General Data Protection Regulation (GDPR) as set out by the European Union (EU) and the European Economic Area (EEA), you have the following rights:
You also have the right to appeal to a data protection supervisory authority concerning the processing of your personal data. Before you take this path, however, we ask that you contact us directly with your concerns at [email protected]. Your right of appeal will not be affected by this.
The following rights apply to everyone irrespective of their geographical location:
Opt-out. You may contact us anytime to opt-out of: (i) automated decision-making and/or profiling; (ii) any new processing of your Personal Data that we may carry out beyond the original purpose; (iii) any consent you previously provided to us regarding the processing of your Personal Data; or (iv) the transfer of your Personal Data outside the EEA. We will apply your preferences going forward, and this will not affect the lawfulness of the processing before you withdraw your consent. Please note that using parts of our Website may be ineffective upon opt-out.
Access. You may access the information we hold about you by contacting us via the “Contact Information” section below.
Amend. You may 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 your Personal Data via the “Contact Information” section below.
Move. Your Personal Data is portable – i.e., you have the flexibility to move your data to other service providers as you wish.
Erasure. In certain situations, for example, when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data.
Exercising Your Rights. If you wish to exercise any of these rights, please contact us via the “Contact Information” section below. In your request, please clearly describe: (i) what Personal Data is concerned and; (ii) which of the above rights you would like to enforce. For your protection, we only process requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before processing your request. We will try to comply with your request as soon as reasonably practicable and, in any event, within thirty (30) days of your request. Please note that there are exceptions and limitations to each of these rights and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, the satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason for such retention.
Marketing Communications. You may unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.
190 Elgin Avenue, George Town, Grand Cayman KY1-9001, Cayman Islands [email protected]