OWNR WALLET OÜ, registered at Harju maakond, Tallinn, Lasnamäe linnaosa, Punane tn 6-219, 13619, Estonia on 31.08.2018 (registration number 14555701) (the “OWNR”), collects Personal Data (as defined below) in compliance with the applicable law and regulations, in particular the General Data Protection Regulation (EU/2016/679) (“GDPR”).
The Information We Collect and Its Purposes
How We Use Your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances: * Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. It means our interest to conduct and manage our business affairs appropriately and responsibly, to protect the reputation of our business, and to provide our Users with the best possible Services of the Website and/or Software with a secure experience. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). We will use your technical information to: - provide and make improvements to the Website and/or our Software, system maintenance, support, reporting and hosting of data, and troubleshooting; - ensure that the Website and/or Software are secure; - analyse how Users interact with the Website. We may also use any or all of the information above to administer and manage our business in general. If you feel that your interests and fundamental rights outweigh our business purposes, and that we should therefore stop processing your data, please let us know. * To perform the Agreement. It means processing your data where it is necessary for the performance of the agreement which you are a party of, or to take steps at your request before concluding an agreement. This includes our Terms of Services. * Marketing. Collecting Personal Data for marketing purposes, we are able to improve our services and expand the functionality offered. This is how we then decide which of our Services may be relevant or of interest to you. * Where we need to comply with a legal or regulatory obligation. In certain circumstances, we may need to retain or use your data to comply with regulations and/or the law, especially AML laws and regulatory investigations. We will only retain these data for as long as is necessary to fulfill the purposes for which it was collected or to comply with legal, regulatory or internal policy requirements.
Transfer and share information
International Data Transfers
We store your information primarily within the European Economic Area. However, some features and requirements of the Services may involve transferring your information to third-party service providers outside the European Economic Area when it may be necessary to process your transactions, subscriptions, purchases and/or trading activity: a. Provide the requested Services, b. Exercise and enforce our contractual rights and Terms of Service, c. comply with our legal and/or regulatory obligations or assert, file or exercise a legal claim We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. In the absence of an adequacy decision, we will use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe.
How We Store and Secure Collected Information
For OWNR Users all Personal Data is processed in the EEA. It has to be noted that OWNR is a cryptocurrency wallet service and offers trading virtual currencies. Trading virtual currencies takes place on the blockchains (Ethereum, Bitcoin, etc.) which are decentralized database software platforms for virtual assets. Blockchains are a list of records, called blocks, which are linked and secured using cryptography. Each block typically contains a cryptographic hash of the previous block, a timestamp and transaction data. By design, a blockchain is inherently resistant to modification of the data.Data are dispersed among nodes all around the world in encrypted version. If you trade virtual currencies you agree that your Personal Data may be collected, stored, processed and that you will not be able to delete it or invoke the right to be forgotten. Your data are encrypted, meaning they are coded (anonymized). With trading virtual assets via OWNR you expressly agree to give your Personal Data on the (public) blockchain that these data (even though encrypted) cannot be deleted and that Personal Data may be transferred outside European territory. OWNR takes the security of the data that it collects very seriously. OWNR has implemented a number of technical, organizational and administrative measures to ensure the confidentiality, integrity, availability and privacy of your Personal Data and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction which are generally accepted by the industry to protect the Personal Data in its possession. You should never disclose your private keys, seed phrases, pass phrases, PINs and other means of authentication to unauthorized parties. We use certain security measures to help keep your personal information safe, but we cannot guarantee that these measures will stop any users try to get around the privacy or security settings on the Website and/or Software through unforeseen and/or illegal activity.
Processing in Accordance with General Data Protection Regulation
The processing of Personal Data is performed in accordance with privacy rights and regulations following the EU Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 (the Directive), and the implementations of the Directive in local legislation. From May 25th, 2018, the Directive and local legislation based on the Directive will be replaced by the Regulations (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, known as the General Data Protection Regulation (GDPR), and our processing will take place in accordance with the GDPR.
Retention and Deletion of Personal Data
To use the Services, you must be over the age of eighteen (18). OWNR does not knowingly collect Personal Information from children under the age of eighteen (18). We do not process any Personal Information of children under this age. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of eighteen (18) are not using the Services. In the event that it comes to our knowledge that a person under the age of eighteen (18) is using the Services, we will prohibit and block such User from accessing the Services and will make all efforts to promptly delete or effectively anonymize any Personal Data stored with us with regard to such a User.
Your principal rights under data protection law are: - Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it if it is possible to identify the User. You may send an email to email@example.com requesting information as the Personal Data which we process. - Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where: a) there is no good reason for us continuing to process it; b) you have successfully exercised your right to object to processing (see below); c) we may have processed your information unlawfully; or d) we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. These may include instances where the retention of your Personal Data is necessary to: a) comply with a legal or regulatory obligation to which we are subject; or b) establish, exercise or defend a legal claim. - Request correction or rectification of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your Personal data which may occur during the course of your relationship with us. - Object to processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purpose. In some cases, we may demonstrate that we have compelling legitimate grounds to process your personal information that override your rights and freedoms. - Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: a) if you want us to establish the data's accuracy; b) where our use of the data is unlawful but you do not want us to erase it; c) where you need us to hold onto the data even if we no longer require it, as you need it to establish, exercise or defend legal claims; or d) where you have objected to our use of your Personal data, but we need to verify whether we have overriding legitimate grounds to use it. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. - Request to withdraw your consent at any time where we are relying on consent to process your Personal data (which will generally not be the case). This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.
If you have any further questions regarding the data OWNR collects, or how we use it, then please feel free to contact us by email at: firstname.lastname@example.org.