PRIVACY POLICY

Last Updated: December 25, 2022

This privacy policy (“Privacy Policy”) governs how we, FreeBraavos Ltd. (together, “Braavos” “we”, “our” or “us”), use, collect and store Personal Data we collect or receive from or about you (“you”).

Please read this Privacy Policy carefully, so you can understand our practices and your rights in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being and any information deemed as “Personally Identifiable Information” by applicable privacy laws. Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement. SOME OF YOUR DATA MAY OR WILL BE STORED ON A BLOCKCHAIN-BASED NETWORK AND, THEREFORE, WILL BE ACCESSIBLE TO ANYONE. WE ARE NOT RESPONSIBLE FOR THE BLOCKCHAIN ASPECTS NOR THE DATA PUBLISHED IN THE BLOCKCHAIN.

Table of contents:

  1. What Personal Data we collect, why we collect it, and how it is used
  2. How we protect and retain your Personal Data
  3. How we share your Personal Data
  4. Your privacy rights
  5. Use by children
  6. Interaction with third party products
  7. Analytic tools
  8. Contact us

This Privacy Policy may be updated from time to time and, therefore, we ask you to check back periodically for the latest version. If we implement significant changes to the use of your Personal Data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Product (as defined below) or by other means.

Braavos is a technology provider, and its Product and services are intended to assist customers to (i) store locally on their own devices, tokens, cryptocurrencies and other crypto or blockchain-based digital assets; (ii) link to decentralized applications, including, without limitation, decentralized exchanges; (iii) view addresses and information that are part of digital asset networks and broadcast transactions; and (iv) additional functionality as may be added from time to time to the Braavos mobile app (“Mobile Application”), Braavos Browser Extension (“Browser Extension”) and Braavos website (“Website”; the Mobile Application, Browser Extension and the Website are referred to collectively as the “Product”).

1. WHAT PERSONAL INFORMATION WE COLLECT, WHY WE COLLECT IT, AND HOW IT IS USED
  • 1.1 We Process the following Personal Information:
    • (a) Information You Provide Directly to Us:
      • (i) When you initiate transfers and/or manage lists of known addresses on your wallet, we collect Blockchain address and, if you choose to do so, also labels or names that you add to the counterparties you interact with through the blockchain;
      • (ii) When you communicate with Braavos (e.g., via email, website or telephone), we collect the contents of those communications, as well as feedback, and/or answers to surveys or questionnaires that you may submit. Note: as part of our products’ core functionality, any transactions that the user performs through our products may be sent to the blockchain. WE ARE NOT RESPONSIBLE FOR THE BLOCKCHAIN ASPECTS NOR THE DATA PUBLISHED IN THE BLOCKCHAIN.
    • (b) Information that we collect automatically: We may automatically collect certain information assigned to your device, such as browser type and language, geo-location, hardware type, operating system, internet service provider and other information about actions taken with the Product through small data files placed on a device that allow a collector to record certain pieces of information whenever you visit or interact with the Product. Such files are known as cookie identifiers, analytic tools, log files and tracking technologies (“Technologies”).
  • 1.2 We Process Personal Information for the following purposes:
    • (a) To provide you with the Product. Braavos will use your Personal Information to provide the Product, including: (i) to allow you to download and install the Mobile Application and Browser Extension; (ii) to allow you to make use of the Product; (iii) to allow you to create your admin user and to generate regular users and administer their privileges, (iv) to allow you to administer your wallet, your keys, addresses, and digital assets; (v) to allow you to administer your transactions, in particular to process, authenticate (e.g., via the Mobile Application), enable you to sign, send to the blockchain, and monitor your transactions (when activated and requested by you, for example, in the context of initiating transactions through the Browser Extension); (vi) to allow you to connect your wallet to decentralized applications; (viii) to communicate with you, provide you with support and maintenance; and (x) to personalize your experience with the Product.
    • (b) For Administrative Purposes. Braavos may use your information (i) to respond to your questions, comments, and other requests for support, or information; (ii) to provide you with the Product; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) for testing, research, analysis, and product development, including to develop and improve our Product, and in connection with providing and maintaining our Products and services; and (vi) to generally administer the Product.
    • (c) To Market Braavos and the Product. Braavos may use information to market Braavos and the Product. Such use includes (i) notifying you about offers and services that may be of interest to you that we offer and/or that we offer jointly with or on behalf of other organizations; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in Braavos Product and services; (v) other purposes disclosed at the time you provide Personal Data; and (vi) as you otherwise consent.
    • (d) Security purposes. Some of the abovementioned information will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.
    • (e) De-identified and Aggregated Information Use. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them).
    • (f) Cookies and Similar Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Product, may use Technologies to automatically collect information through the Products. If we employ any such Technologies on the Product and you would like to opt out of their use, you may do so by blocking, deleting, or disabling them as your browser or device permits.
2.HOW WE PROTECT AND RETAIN YOUR INFORMATION
  • 2.1 Personal Data stored by Braavos:With respect to Personal Data stored by Braavos:
    • (a) Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.
    • (b) Retention of your Personal Data. Your information will be stored until we delete the record and we proactively delete it or you send a valid deletion request. Please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Data or dealings.
  • 2.2 Data stored on the blockchain: Transactions that you perform through the Product will be sent to the blockchain. These transactions and their associated data will be stored on the blockchain perpetually, without any way for deletion, since the blockchain is a decentralized and open-source network. Please note that, given the nature of the blockchain, the effectiveness of the security measures depends on the efforts of a decentralized network of miners, validator nodes and proof-of-stake participants, among other participants in the blockchain network.
  • 2.3 IF YOU DISAGREE WITH THIS SECTION 2, PLEASE DO NOT USE OUR PRODUCT.
3. HOW WE SHARE YOUR PERSONAL DATA

In addition to the recipients described above, we may share your Personal Data as follows:

  • 3.1 Data stored by Braavos:
    • (a) With our business partners with whom we jointly offer products or services. We may also share Personal Data with our affiliated companies.
    • (b) We may use third party service providers to process your Personal Data for the purposes outlined above, including, without limitation:
      • (i) With cloud service providers for hosting purposes;
      • (ii) With email providers, marketing, customer relationship management and other similar tool providers; and
      • (iii) With analytic companies, in order to help us understand and analyze data we collect in accordance with this Privacy Policy.
      • (iv) Blockchain node providers, in order to send your transactions to the blockchain, monitor your blockchain addresses, and monitor the blockchain for any other transactions that affect your wallet.
      • (v) Data providers that provide information about blockchains, transactions, addresses, decentralized applications, and digital assets, in order to provide you with accurate and relevant information about your transactions and digital assets, and for security (e.g., to define security policies and implement access control around transactions)
      • (vi) Identity providers, in order to securely manage user accounts, and implement access control
      • (vii) Log-processing services in order to store and process logs to improve the product, detect and fix problems, and provide you with support.
    • (c) To the extent necessary, with regulators, courts or competent authorities, to comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order;
    • (d) If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we may disclose your Personal Data to such actual or potential third party in connection with the foregoing events;
    • (e) In the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your Personal Data in connection with the foregoing events, including, in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or to another company; and/or
    • (f) Where you have provided your consent to us sharing or transferring your Personal Data (e.g., where you provide us with marketing consents or opt-in to optional additional services or functionality).
  • 3.2 Data stored on the blockchain: The information stored on the blockchain will be shared with anyone accessing the blockchain network, since the blockchain is a decentralized and public protocol, which could include parties that are located outside from your country or jurisdiction. Please note these parties may be located in countries and jurisdictions that do not approach or protect your privacy rights as in your jurisdiction. In any event, please note that sharing data with such parties is necessary for use of the Product.
  • 3.3 IF YOU DISAGREE WITH THIS SECTION 3, PLEASE DO NOT USE OUR PRODUCT.
4.YOUR PRIVACY RIGHTS. HOW TO DELETE YOUR ACCOUNT
  • 4.1 Data stored by Braavos:
    • (a) Your Rights: Subject to applicable laws, you may have the following rights:
      • You have a right to access Personal Data held about you. In general, your right of access may be exercised free of charge; however we reserve the right to charge an appropriate administrative fee where permitted by applicable law;
      • You have the right to request that we rectify any Personal Data we hold that is inaccurate or misleading; and
      • You have the right to request the erasure/deletion of your Personal Data (e.g. from our records).⇨ Please note that there may be circumstances in which we are required to retain your Personal Data, for example for the establishment, exercise or defense of legal claims. Also, your future use of the Product may be affected if your Personal Data is erased or deleted.
    • (b) Exercise of Your Rights: You can exercise your rights by contacting us at privacy@test2. You may use an authorized agent to submit a request on your behalf if you provide the authorized agent written permission signed by you. To protect your privacy, we may take steps to verify your identity before fulfilling your request. Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfil your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request would adversely affect the rights and freedoms of others (for example, would impact the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.
4.2 Data stored on the blockchain:

IMPORTANT NOTE: TRANSACTIONS THAT YOU PERFORM THROUGH BRAAVOS’ PRODUCT WILL BE SENT TO THE BLOCKCHAIN. THESE TRANSACTIONS AND THEIR ASSOCIATED DATA WILL BE STORED ON THE BLOCKCHAIN PERPETUALLY, WITHOUT ANY WAY FOR DELETION, SINCE THE BLOCKCHAIN IS A DECENTRALIZED AND OPEN-SOURCE NETWORK.

4.3 IF YOU DISAGREE WITH THIS SECTION 4, PLEASE DO NOT USE OUR PRODUCT.

We and our services do not perform any processing activity for the purposes of making automated decisions or profile you in any manner.

5.USE BY CHILDREN.

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Data from, and/or about children under the age of eighteen (18). If you are under the age of eighteen (18), do not provide any Personal Data to us without involvement of a parent or a guardian. We do not intend to offer information society services directly to children. In the event that we become aware that you provide Personal Data in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at privacy@test2.

6.INTERACTION WITH THIRD PARTY PRODUCTS.

We enable you to interact with third party websites, mobile software applications and products or services that are not owned or controlled by us (each a “Third Party Service”). We are not responsible for the privacy practices or the content of such Third Party Services. Please be aware that Third Party Services can collect Personal Data from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

7.ANALYTIC TOOLS.

We currently do no use any analytic tools; however, we reserve the right to use analytic tools.

8.CONTACT US.

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at privacy@test2.