Effective date: 12/05/2023
Element Wallet, operated by Element Wallet, Inc., ("Element Wallet", "we", "us", or "our") respects your privacy and is committed to protecting it through our compliance with this policy. This Privacy Policy ("Policy") informs you of our policies regarding the collection, use and disclosure of personal information when you use our websites, mobile applications, emails we send, or any other service where we link to this Policy (collectively our "Services"). By using the Service, you agree to the collection and use of information in accordance with this Policy. Unless otherwise defined in this Policy, the terms used in this Policy have the same meaning as in our Terms of Use.
Information Collection
Types of Personal Information Collected
Depending on how you interact with the Services, we may collect the following information about or from you:
- Personal information and contact information, such as your name, e-mail address, and any other information you submit through the contact form on our Services.
- Basic account data, such as your profile name, profile picture, email address, phone number, and other information necessary to create an account.
- Your contacts, if you choose to share that data with us.
- Your email address when you enable 2-factor authentication and set up a password recovery email.
- Communications between you and us, including support emails and related records.
- Usage data and automatically collected technical information such as traffic data, non-precise location data, logs, and other communication data.
- Information about your computer and internet connection, including device type, IP address, operating system, browser type, unique device identifiers and other diagnostic data.
Sources of Personal Information
We collect personal information from various sources including data directly from you, from public sources, and from automated systems.
- Direct interactions such as signing up for Services, support requests, feedback, surveys, marketing requests, promotions, and customer experience activities.
- Public sources, including data from public blockchains that may reveal your personal information.
- Automated technologies and interactions, including cookies and similar technologies used as you interact with our Services.
Retention of Personal Information
Except to the extent prohibited by law, and subject to this Policy, we will retain and use your personal information for as long as it is needed for the relevant purpose, including to provide Services, communications, requested information, to document our business relationship with you, and as necessary to comply with legal obligations, resolve disputes, and enforce our agreements.
Please note that the nature of blockchain services is that certain data cannot be deleted or erased.
Providing us with Personal Information
If you do not provide the personal information that is necessary, we may be unable to respond to your query or provide our Services to you. In the case of email marketing, you can opt out at any time by following the instructions in those emails. For non-essential cookies, you can opt out, refuse, or stop the processing at any time.
Encrypted Messages
Certain parts of our Services allow you to send direct messages to other Service users. We do not see or retain the contents of your messages in the ordinary course of providing our Services. Instead, your messages are stored on your device and end-to-end encrypted while in transit.
We do not store your chats on our servers except as otherwise described, but we do maintain a log of communication between users, excluding the content of the communication.
Use of Personal Information
We, and our authorised third parties, will only process your personal information where we have the legal grounds to do so. We use the personal information that we collect for various purposes, including:
- To provide and maintain our Service.
- To notify you about changes to our Service.
- To allow you to participate in interactive features of our Service when you choose to do so.
- To provide customer support.
- To gather analysis or valuable information so that we can improve our Service.
- To monitor the usage of our Service.
- To detect, prevent and address technical issues.
- To provide you with news, special offers and general information about similar goods, services and events unless you have opted not to receive such information.
Under European Union and/or United Kingdom regulations, where we rely on legitimate interests for processing of personal information, we carry out a balancing test to ensure that our processing is necessary and that your privacy rights are not outweighed by our legitimate interests.
Transfer of Personal Information Overseas
We are a global company and will collect and process your personal information around the globe. Your information may be transferred to and maintained on computers located outside of your state, province, country or other governmental jurisdiction, where data protection laws may differ from those of your jurisdiction.
Disclosure of Personal Information
Personal information may be shared in the following circumstances:
- Service providers: hosting providers, auditors, advisors, consultants, customer service and support providers and similar service providers.
- Advertising and marketing partners: third parties providing advertising, campaign measurement, promotions, analytics, and related services.
- Legal requirements: when necessary to comply with legal obligations, valid court orders, prevent wrongdoing, protect against physical or financial loss, or protect against legal liability.
- Business transfers: companies or other entities that we plan to merge with or be acquired by.
- Protect our rights: where necessary to enforce our agreements, prevent fraud, assess risk, investigate issues, or protect our rights, property, or safety.
Cookies and Analytics
Cookies
We use cookies, pixels, tags, and other technologies, which may be provided by third parties, on our Services to enable certain functionality and for security and fraud detection and prevention, as well as to collect usage information, personalize content, and provide more relevant ads and information.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. If you block cookies, certain features on our Services may not be available or function properly.
Pixel tags and embedded script
Pixel tags are tiny graphics with a unique identifier, similar in function to cookies. We may use these to track activities of users, improve ads, personalize and manage content, and gather usage information about our website and HTML emails.
Third-Party Analytics Tools
Our Services use automated devices and applications operated by third parties, such as Google Analytics, which use cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.
Security of Data
The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.
Spam and Abuse
To prevent phishing, spam and other kinds of abuse and violations of Element's Terms of Service, our moderators may check messages that were reported to them by their recipients. If a spam report is confirmed, your account may be limited from contacting strangers, temporarily or permanently. In more serious cases, your account may be banned or the Messaging Feature disabled.
Links to Other Sites and Platforms
Our Service may contain links to other websites, plug-ins and applications that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
Children's Privacy
Our Services are not offered to users under the age of majority in the jurisdiction they are accessing the services from and we do not knowingly collect personally identifiable information from children under the age of 18.
Do Not Track
We do not currently recognize automated browser signals regarding tracking mechanisms, which may include "Do Not Track" (DNT) signals sent by web browsers, mobile devices, or other mechanisms. Third parties may be able to collect information about your online activities over time and across different websites or online services when you use the Services.
Your Data Rights
Depending on where you live, you may have certain rights, such as to request access to or correction of your personal information that we hold about you. To make a request, please email privacy@elementwallet.co.
European Union and United Kingdom
Where EU and UK regulations apply, you may have the right to:
- Request access to your personal information.
- Request correction of the personal information that we hold about you.
- Request erasure of your personal information, subject to legal and blockchain-related limitations.
- Object to processing based on legitimate interests or for direct marketing.
- Request restriction of processing in specific circumstances.
- Request the transfer of your personal information to you or a third party in a structured, machine-readable format.
- Withdraw consent at any time where we rely on consent to process your personal information.
We may need to request specific information from you to help confirm your identity and ensure your right to access your personal information. We try to respond to all requests within one month, although complex requests may take longer.
United States Residents
Where applicable, California Civil Code Section 1798.83 allows California residents to request certain information regarding our disclosure of personal information to third parties for direct marketing purposes. Please note that we do not disclose personal information to third parties for their direct marketing purposes.
If you are a resident of Nevada, you have the right to opt out of the sale of certain personal information to third parties who intend to license or sell that personal information. Please note that we do not currently sell your personal information as sales are defined in Nevada Revised Statutes Chapter 603A.
Changes to This Privacy Policy
We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We may also notify you via email and/or a prominent notice on our Service prior to any significant changes becoming effective and update the effective date at the top of this Privacy Policy.
Contacting us
If you have any questions about this Policy, including requests to exercise your legal rights, please contact us at privacy@elementwallet.co.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. Please contact the DPO by emailing privacy@elementwallet.co with "DPO" in the subject line.
We have appointed representatives pursuant to Article 27 EU and UK GDPR who can be contacted at CoreWallet.EURep@datarologie.com (EU) or CoreWallet.UKRep@datarologie.com (UK).
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO) in the UK or the Data Protection Commission (DPC) in Ireland, though we would appreciate the chance to deal with your concerns first.
