AppCoins Wallet Terms of Service
Last updated: Nov, 2020
AppCoins Catappult Wallet (“AppCoins Wallet”) is a mobile application developed by Aptoide, S.A. its affiliates and subsidiaries (collectively referred to as “Aptoide”, “we”, “us” or “our”). Before using AppCoins Wallet, please read these Terms of Service, together with any other policies or notices made available on AppCoins Wallet and our Privacy Policy, available here (together referred to as the “Terms” or the “Agreement”).
Capitalized terms shall have the following meaning:
- AppCoins: an open standard protocol and a cryptocurrency created for the app economy.
- AppCoins are ERC-20 compatible tokens distributed on the Ethereum blockchain pursuant to a related ERC-20 smart contract, as detailed in https://www.appcoins.io.
- AppCoins Credits: are a specific category of AppCoins which may be purchased by Users or which may be granted to Users as a reward for participating in campaigns promoted by Aptoide.
- AppCoins Wallet: a mobile application developed by Aptoide consisting on software that generates a Wallet Account or allows you to import an existing Wallet Account where you can self-custody ERC-20 compatible tokens, transact and receive such tokens and view transaction history.
- Users: The person who download the AppCoins Wallet to their devices and create, access and transact virtual currencies using the AppCoins Wallet.
- Virtual Currency: means a cryptocurrency, digital currency, digital asset, cryptoasset or other such similar term, which is supported by AppCoins Wallet, excluding a derivative of a virtual currency or a security.
- Wallet Account: a digital wallet account which supports virtual currencies owned by Users, including the Wallet Account generated by AppCoins Wallet for the Users or the Users’ existing Wallet Account(s) imported by Users to AppCoins Wallet.
General Use
By using AppCoins Wallet, you acknowledge that you have read, understood and agreed to the Terms. We reserve the right to change the Terms at any time. Any such changes will take effect when posted on AppCoins Wallet. Your continued use of AppCoins Wallet following any such change shall signify your acceptance to be bound by the current Terms. Please check the “Last update” date above to determine if there have been any changes since you have last reviewed the Terms. If you do not agree with the Terms or any modifications, you should not use, or cease to use, AppCoins Wallet. Our failure or delay in enforcing or partially enforcing any provision under the Terms shall not be construed as a waiver of our rights.
Eligibility
You are only eligible to use the AppCoins Wallet if you are of legal age to, and have the capacity to, enter into a binding contract with Aptoide and agree to be legally bound by the Terms. If you are using AppCoins Wallet on behalf of a legal entity, you further represent and warrant that the legal entity that you are representing is dully organised and existing under the applicable laws of the jurisdiction of its organization and that you are duly empowered by such entity to act on its behalf.
Services
By using the AppCoins Wallet you may have access to the following services (the “Services”):
- Purchase Virtual Currencies supported by the AppCoins Wallet.
- Store Virtual Currencies (whether purchased by using the AppCoins Wallet or transferred from another digital wallet account).
- Transfer Virtual Currencies stored in your Wallet Account to another digital wallet account.
- Exchange a Virtual Currency, except AppCoins Credits, which cannot be exchange, as provided for in paragraph 5.2. below, stored in your Wallet Account for another Virtual Currency.
- Ask someone to top-up your AppCoins Wallet, by sending them a link requesting a payment to your AppCoins Wallet.
Additional services may be made available to you from time to time. Such additional services shall be provided under terms and conditions separate to this Agreement.
Use of AppCoins Wallet
General
The use of AppCoins Wallet is only permitted if the laws of your jurisdiction allow such use. You agree to use AppCoins Wallet only for purposes that are permitted by the Terms. You agree not to access (or attempt to access) to AppCoins Wallet by any means other than through the interface that is provided by Aptoide, unless you have been specifically allowed to do so in a separate agreement with Aptoide. You specifically agree not to access (or attempt to access) to AppCoins Wallet through any automated means (including use of scripts).
You agree that you will not engage in any activity that interferes with or disrupts AppCoins Wallet (or the servers and networks which are connected to AppCoins Wallet).
You agree that you are solely responsible for (and that Aptoide has no responsibility to you or to any third party for) any breach of your obligations under the Terms and for the consequences (including any loss or damage which Aptoide may suffer) of any such breach.
Creating a Wallet Account
When you create a Wallet Account, AppCoins Wallet generates a cryptographic private and public key pair that you may use to send and receive AppCoins. When you create a Wallet Account, you must: (a) provide accurate and truthful information; (b) protect and keep secret all credentials to access the Wallet Account; (c) protect access to your device and your Wallet Account; (d) promptly notify us if you discover or otherwise suspect any security breaches related to your Wallet Account; and (e) use the backup functionality provided through the Wallet Account and safeguard your backup files.
Responsibility for transactions and backups
By using AppCoins Wallet, you acknowledge that you have read, understood and agreed to the Terms.
Responsibility for transactions and backups
You agree to take responsibility for all activities that occur under your Wallet Account and accept all risks of any authorized or unauthorized access to your Wallet Account, to the maximum extent permitted by law.
You accept and acknowledge that we are not responsible for any errors or omissions that you make in connection with any Virtual Currency transaction initiated through the use of AppCoins Wallet. We recommend that you review the transaction details carefully before completing a transaction.
You are solely responsible for maintaining the security of your private key and for storing, outside AppCoins Wallet, a backup of any Wallet Account, private key or transaction information that you maintain in AppCoins Wallet. If you do not maintain a backup of your Wallet Account data outside of AppCoins Wallet, you will not be able to access to your virtual currency previously accessed using your Wallet Account in the event that we discontinue or no longer offer access to AppCoins Wallet. We are not responsible for maintaining this data on your behalf.
No password retrieval
Aptoide does not receive or store your Wallet Account password or related keys. We cannot assist you with Wallet Account password retrieval. You are solely responsible for remembering, storing and keeping secret your Wallet Account password. Any Virtual Currency you have associated with such Wallet Account may become inaccessible if you do not know or keep secret your Wallet Account password. Any third party with knowledge of one or more of your credentials (including, without limitation, a backup phrase, wallet identifier or password) can dispose of virtual currency in your Wallet Account.
Virtual Currency Transactions
In order to be completed, any Virtual Currency transaction created with the Wallet Account must be confirmed and recorded in the Virtual Currency’s associated public blockchain. Such networks are decentralized, peer-to-peer networks supported by independent third parties, which are not owned, controlled or operated by Aptoide.
Aptoide has no control over any Virtual Currency network and therefore cannot and does not ensure that any transaction details you submit via AppCoins Wallet will be confirmed on the relevant Virtual Currency network. You agree and understand that the transaction details you submit via AppCoins Wallet may not be completed, or may be substantially delayed, by the Virtual Currency network used to process the transaction. We do not guarantee that the Wallet Account can transfer title or right in any Virtual Currency or make any warranties whatsoever with regard to title.
Once transaction details have been submitted to a Virtual Currency network, we cannot assist you to cancel or otherwise modify your transaction or transaction details. Aptoide has no control over any Virtual Currency network and does not have the ability to facilitate any cancellation or modification requests.
Fees
Aptoide does not currently charge a fee for the use of AppCoins Wallet, receiving, sending or controlling Virtual Currency. However, we reserve the right to do so in the future, and in such case any applicable fees will be displayed prior to you incurring the fee.
Network fees (including, without limitation “miner’s fees”) required to use a Virtual Currency network may apply to a transaction. We may attempt to calculate such a fee for you. Our calculation may not be sufficient, or it may be excessive. You may select a greater or lesser fee. You are solely responsible for paying any such fee and we will neither advance nor fund such a fee on your behalf, nor be responsible for any excess or insufficient fee calculation.
Taxes
You are solely responsible to determine what, if any, taxes apply to the transactions that you have executed by using AppCoins Wallet and it is your sole responsibility to report and remit the correct tax to the competent tax authorities.
You acknowledge and agree that Aptoide is not responsible for determining whether taxes apply to the Virtual Currency transactions executed by using AppCoins Wallet or for collecting, reporting, withholding or remitting any taxes arising out of such transactions.
AppCoins кредити
Acquiring AppCoins Credits
You may have access to AppCoins Credits as follows:
- By purchasing AppCoins Credits in your Wallet Account (“Top-Up”). Purchases of AppCoins Credits is made by topping-up your AppCoins Wallet. You may choose to top-up your AppCoins Wallet in fiat currency or in AppCoins. The conversion, from fiat currency to AppCoins or from AppCoins to fiat currency, will be displayed as you insert the amounts to be toped-up, before you complete the transaction. Please note that the conversion showed in respect to AppCoins to be credited in your AppCoins Wallet may vary due to the fact that it is not possible to convert in fiat currency the decimal units in which AppCoins may be represented (e.g. the top-up service shows you that for the acquisition of 1 (one) AppCoin you will pay € 0,09 but you will receive 1,6 AppCoins. Please note that the conversion rate hereby presented is a theoretic example in which you cannot rely on to complete transactions). You may pay the top-up by using your credit card or any other payment service provider available at any time. After confirmation of the transaction, the AppCoins Credits are automatically credited in your AppCoins Wallet.
- By gaining a reward for participating in campaigns promoted by Aptoide. From time to time Aptoide, or third parties with partnerships with Aptoide, may launch promotional campaigns which may entitle you to receive AppCoins Credits (e.g. by using a specific App, by topping-up your AppCoins Wallet or by paying in-app purchases with AppCoins, for example). You will be informed about the specific conditions applicable to such promotional campaigns, whenever they are running. Please note that it is upon Aptoide, or third parties running the campaigns, solely discretion to launch, suspend and end each and any promotional campaign.
Terms of Use
AppCoins Credits are a category of AppCoins subject to the following specific usage terms and conditions:
- AppCoins Credits can only be used/spent in In-App Purchases.
- AppCoins Credits may be transferred to other Wallet Accounts, as long as such Wallet Accounts support AppCoins Credits.
- AppCoins Credits cannot be exchanged (either to another cryptoasset or into fiat currency).
- Developers cannot spend AppCoins Credits to buy in-app products of their Apps to increase the sale of their own products. If such behavior is detected, Aptoide may suspend the distribution of the App and may terminate the distribution agreement entered into with the Developer.
- AppCoins Credits cannot be used, spent or transferred in an abusive and/or fraudulent manner (e.g. use of AppCoins Credits to obtain: (i) additional AppCoins Credits; (ii) higher revenue shares; (iii) transaction savings and/or any other advantage/bonus which is not the attribution of AppCoins Credits). If such behavior is detected, Aptoide may retrieve the AppCoins Credits granted as a result of such conducts and/or suspend payment of any revenue generated with such behavior.
- AppCoins Credits expire after 24 (twenty-four) months as from the date in which they were credited in the User account.
Chargebacks
Chargebacks are applicable in relation to in-app purchases paid with AppCoins Credits purchased by the User. A chargeback is a process that may lead to the return of funds to a User. This process is initiated by the User, asking to the issuing bank the refund. Issuing bank will then contact the payment processor which will then notify Aptoide to provide information. Please note that the chargeback process is managed and resolved by the payment processor and the issuing bank, in accordance with the respective terms and conditions, and that Aptoide does not have any power to dispute the decisions taken.
Third Party Services and Content
In using AppCoins Wallet you may view content or utilize services provided by third parties, including hyperlinks to other web sites or content or resources (“Third-Party Content”). Sometimes when you use the Third-Party Content, you may use a service or download a piece of software, or purchase goods, which are provided by another person or company. Your use of these other services, software or goods may be subject to separate terms between you and the company or person concerned. If so, the Terms do not affect your legal relationship with these other companies or individuals. You acknowledge and agree that Aptoide is not responsible for the availability of any such external sites or resources, and does not control, endorse or adopt any advertising, products or other materials on or available from such web sites or resources. Users who conduct transactions or take part in other activities through the Third-Party Content do so at their own risk. You acknowledge and agree that Aptoide is not liable for any loss or damage which may be incurred by you as a result of the availability of those external sites or resources, or as a result of any reliance placed by you on the completeness, accuracy or existence of any advertising, products or other materials on, or available from, such web sites or resources.
General Risk Factors
You agree and understand that there are risks associated with utilizing AppCoins Wallet including, but not limited to, the risk of failure of hardware, software and internet connections, the risk of malicious software introduction, and the risk that third parties may obtain unauthorized access to information stored within your Wallet Account, including, but not limited to your public and private keys. You agree and understand that we will not be responsible for any communication failures, disruptions, errors, distortions or delays you may experience when using AppCoins Wallet, however caused. You accept and acknowledge that there are risks associated with utilizing any Virtual Currency network, including, but not limited to, the risk of unknown vulnerabilities in or unanticipated changes to the network protocol. You acknowledge and accept that Aptoide has no control over any cryptocurrency network and will not be responsible for any harm occurring as a result of such risks, including, but not limited to, the inability to reverse a transaction, and any losses in connection therewith due to erroneous or fraudulent actions. The risk of loss may be substantial and losses may occur over a short period of time. In addition, price and liquidity are subject to significant fluctuations that may be unpredictable. Virtual Currencies are not legal tender and are not backed by any sovereign government. In addition, the legislative and regulatory landscape around Virtual Currencies is constantly changing and may affect your ability to use, transfer, or exchange Virtual Currencies.
AppCoins Wallet updates, changes or discontinuance
The software you use may automatically download and install updates from time to time. These updates are designed to improve, enhance and further develop AppCoins Wallet and may take the form of bug fixes, enhanced functions, new software modules and completely new versions. You agree to receive such updates (and permit Aptoide to deliver these to you) as part of your use of AppCoins Wallet. Aptoide is constantly innovating in order to provide the best possible experience for Users. As part of this continuing innovation, you acknowledge and agree that Aptoide may stop (permanently or temporarily) providing AppCoins Wallet (or any features within AppCoins Wallet) to you or to Users generally at Aptoide’s sole discretion, without prior notice to you. You may stop using AppCoins Wallet at any time. You do not need to specifically inform Aptoide when you stop using AppCoins Wallet.
Proprietary rights
You acknowledge and agree that Aptoide (or Aptoide’s licensors) own all legal right, title and interest in and to AppCoins Wallet, including any intellectual property rights which subsist in AppCoins Wallet (whether those rights happen to be registered or not, and wherever in the world those rights may exist). Unless you have agreed otherwise in writing with Aptoide, nothing in the Terms gives you a right to use any of Aptoide’s trade names, trademarks, service marks, logos, domain names, and other distinctive brand features.
Intellectual Property
AppCoins Wallet was developed under a GPL 3 open source license. Information regarding AppCoins Wallet current software is available at https://github.com/fastlane/fastlane/blob/master/LICENSE. Please be aware that GPL 3 is a copyleft license, which means that any derivative works can only be distributed under the same license terms as the original software. For more information, you should review the GNU’s terms and conditions available at https://www.gnu.org/licenses/gpl-3.0.en.html. AppCoins Wallet also contains copyright material and trademarks which are protected by intellectual property rights (the “Content”) which are owned by Aptoide (or its licensors). Your use of AppCoins Wallet does not grant you any right, title or interest in the Content. You agree that you will not copy, transmit, distribute, sell, license, create derivative works from, or in any other way, exploit any of the Content, in whole or in part.
EXCLUSION OF WARRANTIES
NOTHING IN THESE TERMS SHALL EXCLUDE OR LIMIT APTOIDE’S WARRANTY OR LIABILITY FOR LOSSES WHICH MAY NOT BE LAWFULLY EXCLUDED OR LIMITED BY APPLICABLE LAW. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF CERTAIN WARRANTIES OR CONDITIONS OR THE LIMITATION OR EXCLUSION OF LIABILITY FOR LOSS OR DAMAGE CAUSED BY NEGLIGENCE, BREACH OF CONTRACT OR BREACH OF IMPLIED TERMS, OR INCIDENTAL OR CONSEQUENTIAL DAMAGES. ACCORDINGLY, ONLY THE LIMITATIONS WHICH ARE LAWFUL IN YOUR JURISDICTION WILL APPLY TO YOU AND OUR LIABILITY WILL BE LIMITED TO THE MAXIMUM EXTENT PERMITTED BY LAW. YOU EXPRESSLY UNDERSTAND AND AGREE THAT YOUR USE OF APPCOINS WALLET IS AT YOUR SOLE RISK AND THAT APPCOINS WALLET IS PROVIDED ON AN “AS IS“ AND “AS AVAILABLE.” WITHOUT ANY REPRESENTATATION OR WARRANTY, WHETHER EXRESS OR IMPLIED, INCLUDING, BUT NOT LIMITED TO THE IMPLIED WARRANTIES AND CONDITIONS OF TITLE, MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE AND NON-INFRINGEMENT. WE DO NOT MAKE ANY REPRESENTATIONS OR WARRANTIES THAT ACCESS TO THE SERVICES WILL BE CONTINUOUS, UNINTERRUPTED, TIMELY OR ERROR-FREE. IN PARTICULAR, APTOIDE, ITS SUBSIDIARIES AND AFFILIATES, AND ITS LICENSORS DO NOT REPRESENT OR WARRANT TO YOU THAT:
- YOUR USE OF THE SERVICES WILL MEET YOUR REQUIREMENTS,
- YOUR USE OF THE SERVICES WILL BE UNINTERRUPTED, TIMELY, SECURE OR FREE FROM ERROR,
- ANY INFORMATION OBTAINED BY YOU AS A RESULT OF YOUR USE OF THE SERVICES WILL BE ACCURATE OR RELIABLE, AND
- THAT DEFECTS IN THE OPERATION OR FUNCTIONALITY OF ANY SOFTWARE PROVIDED TO YOU AS PART OF THE SERVICES WILL BE CORRECTED.
LIMITATION OF LIABILITY
TO THE FULLEST EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT WILL APTOIDE, ITS SUBSIDIARIES AND AFFILIATES, AND ITS LICENSORS BE LIABLE TO YOU UNDER CONTRACT, STRICT LIABILITY, NEGLIGENCE, OR ANY OTHER LEGAL OR EQUITABLE THEORY, FOR ANY LOST PROFITS, DATA LOSS, COST OF PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES, OR DIRECT, INDIRECT, INCIDENTAL, SPECIAL, PUNITIVE, COMPENSATORY, OR CONSEQUENTIAL DAMAGES OF ANY KIND WHATSOEVER RESULTING FROM:
- YOUR USE OF, OR CONDUCT IN CONNECTION WITH, APPCOINS WALLET;
- ANY UNAUTHORIZED USE OF YOUR WALLET ADDRESS AND/OR PRIVATE KEY DUE TO YOUR FAILURE TO MAINTAIN THE CONFIDENTIALITY OF YOUR WALLET;
- ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM APPCOINS WALLET;
- ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT ARE FOUND IN THE SOFTWARE OR THAT MAY BE TRANSMITTED TO OR THROUGH APPCOINS WALLET BY ANY THIRD PARTY (REGARDLESS OF THE SOURCE OF ORIGINATION),
- ANY RELIANCE PLACED BY YOU ON THE COMPLETENESS, ACCURACY OR EXISTENCE OF ANY ADVERTISING, OR AS A RESULT OF ANY RELATIONSHIP OR TRANSACTION BETWEEN YOU AND ANY ADVERTISER OR SPONSOR WHOSE ADVERTISING APPEARS ON THE SERVICES;
- ANY CHANGES WHICH APTOIDE MAY MAKE TO APPCOINS WALLET, OR FOR ANYPERMANENT OR TEMPORARY CESSATION IN THE PROVISION OF APPCOINS WALLET (OR ANY FEATURES WITHIN APPCOINS WALLET).
THE LIMITATIONS ON APTOIDE’S LIABILITY TO YOU SHALL APPLY WHETHER OR NOT APTOIDE HAS BEEN ADVISED OF OR SHOULD HAVE BEEN AWARE OF THE POSSIBILITY OF ANY SUCH LOSSES ARISING.
Miscellaneous
-
Entire Agreement
The Terms constitute the whole legal agreement between you and Aptoide and govern your use of AppCoins Wallet (but excluding any services which Aptoide may provide to you under a separate written agreement), and completely replace any prior agreements between you and Aptoide in relation to it. -
Severability
If any court of law, having the jurisdiction to decide on this matter, rules that any provision of these Terms is invalid, then that provision will be removed from the Terms without affecting the rest of the Terms. The remaining provisions of the Terms will continue to be valid and enforceable. -
Beneficiaries
You acknowledge and agree that each member of the group of companies of which Aptoide is the parent shall be third party beneficiaries to the Terms and that such other companies shall be entitled to directly enforce, and rely upon, any provision of the Terms which confers a benefit on (or rights in favour of) them. Other than this, no other person or company shall be third party beneficiaries to the Terms. -
Governing Law
This Agreement will be governed by the laws of Portugal. You consent to the exclusive jurisdiction and venue of the courts in Lisbon, Portugal. -
Questions or comments
We welcome comments, questions, concerns or suggestions. Please send us a message on our contact page at support@catappult.io.
AppCoins Wallet Privacy Policy
Effective as of May 25, 2018. Last updated on Fev, 2020
Introduction
Welcome to the AppCoins Wallet privacy notice. AppCoins Wallet is a software developed by Aptoide S.A. (“Aptoide”), which allows you to generate a Wallet Account and manage your ERC-20 compatible tokens. AppCoins Wallet is a product developed and owned by Aptoide. Aptoide respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you use AppCoins Wallet and the website https://appcexplorer.io/ (the “website”), and tell you about your privacy rights and how the law protects you. PLEASE NOTE THAT APPCOINS WALLET IS A SOFTWARE THAT IS BASED ON BLOCKCHAIN SOFTWARE AND, BECAUSE OF THAT, RECORDS INFORMATION IN PUBLIC BLOCKCHAINS. BY MAKING TRANSACTIONS USING APPCOINS WALLET YOU AGREE AND UNDERSTAND THAT SUCH INFORMATION WILL BE PUBLICLY AVAILABLE. THIS ALSO MEANS THAT APTOIDE WILL NOT BE ABLE TO ERASE OR CHANGE ANY OF THE DATA THAT IS RECORDED IN THE BLOCKCHAIN.
Important information and who we are
Aptoide, S.A., a Portuguese company, with the identification number ID 509987184 and principal place of business at Rua Soeiro Pereira Gomes, Lote 1, 3D, 1649-031 Lisboa, Portugal is the controller and responsible for your personal data (collectively referred to as Aptoide, “we”, “us” or “our” in this privacy notice). This privacy notice aims to give you information on how Aptoide collects and processes your personal data through your use of AppCoins Wallet, including any data you may provide through the website or the use of the software, create a wallet account or purchase AppCoin Credits. Please also read AppCoins Wallet Terms of Service (”Terms”), which describe the terms under which you use AppCoins Wallet. We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
Contact Details
- Full name of legal entity: Aptoide, S.A.
- Name or title of data privacy manager: Data Privacy Manager
- E-mail: personal-data@aptoide.com
You have the right to make a complaint at any time to the Portuguese Data Protection Commission (CNPD), the Portuguese supervisory authority for data protection issues (www.cnpd.pt). We would, however, appreciate the chance to deal with your concerns before you approach CNPD so please contact us in the first instance.
Third-party links
AppCoins Wallet may include links to third-party websites, App Stores, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and we are not responsible for their privacy statements. When you leave AppCoins Wallet, we encourage you to read the privacy notice of every website or app you use.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data: Wallet Address, cell phone number
- Financial Data: Payment processor account, Wallet address
- Transaction Data: includes details about payments and transactions made by you using the AppCoins Wallet.
- Technical Data: includes internet protocol (IP) address, unique device identifier, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services, device model, mobile app version.
- Usage Data: includes information about how you use our website, mobile apps, products and services.
- Aggregated Data: we also collect, use and share Aggregated data, such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website or mobile app feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. IF YOU FAIL TO PROVIDE PERSONAL DATA where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to provide you the services or to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you, including through:
Direct interactions. You may give us your Identity and Financial Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create a Wallet Account by using AppCoins Wallet;
- give us some feedback or contact us.
Automated technologies or interactions. As you interact with AppCoins Wallet and the website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out:
- Technical Data from the analytics providers, based in the EU and outside the EU;
- Identity, Financial and Transaction Data from providers of technical, payment and delivery services based in the EU and outside the EU.
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 we need to provide you the services or to perform the contract we are about to enter into or have entered into with you.
- 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.
- Where we need to comply with a legal or regulatory obligation.
- Where you have given to us your consent to use your personal data.
- Whenever we need your consent to proceed with any usage of data, we will collect it. You have the right to withdraw consent to marketing at any time by Contacting Us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing |
|---|---|---|
| To create a new Wallet Account |
|
Provision of services to you |
| To process your transactions |
|
Performance of a contract with you |
| To register your transactions in the public blockchain |
|
Provision of services to you |
| To manage our relationship with you which will include notifying you about changes to our terms or privacy policy. |
|
Provision of services to you. |
| To administer and protect our business and our website and Aptoide Apps (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
|
|
| To use data analytics to improve our website, apps, products/services, customer relationships and experiences. |
|
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to study how customers use our products/ services and to develop our business). |
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact Us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Disclosures of your personal data
We may share your personal data with data processors to allow us to provide you with our services. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our processors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions. We also use cookies in our website which allow third parties, including Facebook, to use cookies, web beacons, and other storage technologies to collect or receive information from our websites and elsewhere on the Internet and use that information to provide measurement services and target ads. The categories of third parties having access to your personal data are the following:
Public Blockchain: due to the particular nature of AppCoins Wallet software, data about the transactions performed by you using AppCoins Wallet will be recorded in public blockchains and on the website. Such data include: your Wallet Account, the date and time in which the transaction was made and details about the transaction.
Service providers, based in the EU and outside the EU, acting as processors, to provide us with the following services:
- Hosting, provided by, namely, Leaseweb and Amazon;
- Security, provided, namely, by Cloudfare;
- Analytics, provided by, namely, Google;
- Payment processing, provided by, namely Adyen, Paypal, Dimoco and Codapay;
- .
Recipients of your personal data, namely Google LLC, who use cookies to collect or receive information from our websites and elsewhere on the Internet and use that information to provide measurement services and target ads.
Regulators and other authorities who require reporting of processing activities in certain circumstances.
Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
International transfers
Some of our data processors are external third parties which are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA which may not be regarded as providing the same level of protection as the jurisdiction you are based in. Safeguards for international transfers of personal data: In cases where we need to transfer personal data outside the EEA, we will ensure that the following adequate safeguards, as required by applicable data protection laws, are implemented to ensure a similar degree of protection is afforded to it:
- Where we use certain suppliers or service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe, known as the European Commission’s Standard Contractual Clauses. For further details, see European Commission: Model contracts for the transfer of personal data to third countries (https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en).
Please Contact Us if you want to obtain a copy of the specific mechanism used by us when transferring your personal data out of the EEA or if you want further information on them.
Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. PLEASE NOTE THAT, IN WHAT RELATES TO THE DATA RECORDED IN PUBLIC BLOCKCHAINS, DUE TO THE NATURE OF SUCH BLOCKCHAINS, WE WILL NOT BE ABLE TO ERASE, DELETE OR CHANGE THE DATA RECORDED. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data. We may also anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. If you want further information about details of retention periods for different aspects of your personal data, please Contact Us.
Your legal rights
PLEASE NOTE THAT, IN WHAT RELATES TO THE DATA RECORDED IN PUBLIC BLOCKCHAINS, DUE TO THE NATURE OF SUCH BLOCKCHAINS, WE WILL NOT BE ABLE TO SATISFY SOME OF THE RIGHTS GRANTED TO DATA SUBJECTS. Under data protection laws in relation to your personal data you are entitled to exercise the following rights:
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.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where 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.
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 purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which 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 the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your 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.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please Contact us.
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NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. -
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. -
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.