The Company is the controller of the information provided or collected in the Wallet, Application or websites on which this Policy is posted and in the course of using the Applications of the Company which exist in the websites or platforms of other company. This Policy applies to websites, apps, events and other services we operate under the Wallet brand.
Through this Policy, the Company regards personal information of the users as important and inform them of the purpose and method of Company's using the personal information provided by the users and the measures taken by the Company for protection of those personal information.
If found to realize or possess minority personal information of the jurisdiction, the Company shall immediately delete all personal information available.
1. Information collected and Method of collection
(1) Personal information items to be collected
Personal information items to be collected by the Company are as follows:
- Information provided by the users including but not limited to your first and last name, Wallet and NURITOPIA ID/Username or similar identifier, title, email address, cryptography wallet address, phone number, password, date of birth, gender, SNS (Facebook, Apple, Google, etc.) information and/or friends list of SNS, interests, preferences, feedbacks, payment information, transaction information, usage information, marketing information, financial information, other people information,
Besides of information directly provided by the users, the Company may collect information in the course that the users use the Service provided by the Company including but not limited to equipment/device information, ads information and other information.
- Information collected while the users use Services including but not limited to usage information, hardware model name, operation system, hardware version, application programming interface (API)-key, type and set-up of browser, IP address, language of browser, information of the device being used such as mobile network information, installed application information, advertising information, etc.
Besides of information directly provided by the users or users’ system, the Company may collect information from others like other members, DApp, social media, affiliates and other partners.
(2) Method of collection
The Company collects the information of users in a way of the followings:
- webpage, written form, e-mailing, tools for collection of created information
- provided by partner companies; and
- and other means as developed or implemented from time to time
4. Cookies, Beacons and Similar Technologies
We may use tracking technology (such as "Cookies") on our websites and app to help us understand and improve our service, as well as to understand your preferences. A Cookie allows us to remember your actions and preferences on the website over a period of time.
We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed.
5. User’s right
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use and sharing of personal information by the Company:
- The right to access to personal information;
- The users or their legal representatives may access the information and check the records of the collection, use and sharing of the information under the applicable law.
- The right to rectification;
- The users or their legal representatives may request to correct inaccurate or incomplete information.
- The right to erasure;
- The users or their legal representatives may request the deletion of the information after the achievement of their purpose and the withdrawal of their consent.
- However, Company will not be able to erase some personal data due to following reasons in accordance with the article 17 of the EU GDPR (General Data Protection Regulation).
- The processing of your personal data is necessary for compliance with a legal obligation.
- The processing of your personal data is necessary for the establishment, exercise or defense of legal claims.
- The right to restriction of processing;
- The users or their legal representatives may make temporary suspension of treatment of personal information in case of the disputes over the accuracy of information and the legality of information treatment, or if necessary to retain the information.
- The right to data portability
- The users or their legal representatives may request to provide or transfer the information.
- The right to object
- The users or their legal representatives may suspend the treatment of personal information if the information is used for the purpose of direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.
- The right to automated individual decision-making, including profiling
- The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has critical impact or cause legal effect on them.
If, in order to exercise the above rights, you, as an user, contact the Company by sending a document or e-mails, or using telephone to the Company ( person in charge of management of personal information or a deputy if available), the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
6. User’s Obligations
The users shall keep their personal information up to date and be liable for the problems arising out of or in connection with the information incorrectly input by themselves.
The users have responsibility to ensure and maintain the security of their own information such as Wallet ID, private key, recovery phrase, email address, etc., and shall neither assign nor lend such information to a 3rd party. The Company shall not be held responsible for any problems related to personal information that may arise out of or in relation to the mistakes made by individual members or the cause not attributable to the Company.
The users shall appropriately manage their personal information and take full responsibility for such management and be liable for the cooperation with the request of the Company to change the password on a regular basis under this Policy.
The users shall comply with the applicable laws and statues of personal information protection in each country.
Our Applications and Services are intended for individuals who are 18 years of age or older or legal age of your residential jurisdiction.
No minority permitted and the Company does not knowingly collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in relevant jurisdiction. The Wallet app employs a compliant neutral age gate to prevent children from accessing the service. If the Application acknowledges during the course of business, that the app has collected personal information from a child, all information will be deleted from our records and the account will be closed.
If you'd like to report an account that you believe belongs to someone under 13, please contact the Company. We shall take appropriate action when we receive your report.
We are also committed to protecting the privacy of children (i.e., users under the age of 13 under COPPA). To learn more about COPPA, you can consult the US Federal Trade Commission’s COPPA website: https://www.ftc.gov/news-events/topics/protecting-consumer-privacy-security/kids-privacy-coppa.
10. Modification of Privacy Protection Policy
The Company has the right to amend or modify this Policy from time to time and, in such case, the Company may make a public notice of it through pop-up of its service (or through individual notice such as e-mail) and obtain consent from the users if required by relevant laws.
If this Policy is amended, such amendment shall become effective as of the date posted on the Platform, or such other date as may be indicated by the Company.
A. Data transfer to other countries
Considering it engages in global businesses, the Company may provide the users' personal information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained or processed, the Company takes reasonable measures for protecting personal information; however, your personal information may not be as protective as those in your jurisdiction.
B. For users residing in a specific jurisdiction
The Company may adapt a guidance to several additional matters to be disclosed as required by the local laws and regulations.
The user may reject the collection and use of optional items and, even in case of rejection, there is no limit on use of services
We may entrust part of its operations to third-party businesses to provide more convenient and improved services.
In order to bring the user our services globally and continuously, the Company may provide information and content to service providers located outside of residency of jurisdiction to process personal information.
In principle, the Company destroys personal information of users without delay after 90 days of preservation for the purpose of responding to recovery request after withdrawal when 1) the purpose of its collection and use has been achieved, 2) the legal or management needs are satisfied or users request, 3) Provided that, if it is required to retain the information by relevant laws and regulations, the Company will retain member information for certain period as designated by relevant laws and regulations.
If a user does not use the Service for more than one (1) year, the Company, after such period, may forthwith destroy the user’s personal information or manage and store the user’s information in a place separate from the personal information of the other users, and will inform the user of his/her information to be destroyed or stored separately, the expiration date and the items of his/her personal information thirty (30) days before the expiration of the above period.
In order to prevent the loss, theft, leakage, alteration or damage of personal information of the users, the Company may take technical, managerial and physical measures for securing safety as follows:
- The password set by a member is collected as encrypted (if necessary).
- The Company may implement protective measures to safeguard the personal information of users: the company employs the security measures necessary to prevent personal information from being leaked or damaged by hacking or computer viruses and strives to have all possible technical measures for better security.
- The Company may limit to a minimum number of personnel treating personal information, and complies with relevant Act and subordinate statue such as training of the personnel handling personal information, etc.
The Company may assign staff(s) responsible for managing personal information.