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Privacy Policy

This Privacy Policy describes the policies and procedures of StarKey Wallet (“we,” “our,” or “us”) pertaining to the collection, use, and disclosure of your information on www.starkey.app and related applications and products we offer (the “Services” or “StarKey Wallet”).

Overview

Your right to privacy and the protection of your personal data is important to us. The following sections provide further details as to how we process your personal information through StarKey Wallet. We don’t share your information with third parties except to deliver you our Services and products, comply with the law, make StarKey Wallet better, protect our rights, or effectuate a business transfer. If you have any questions or concerns about this policy, please reach out to us at support@starkey.app.

Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through our services.

How do you accept this policy

By using StarKey Wallet, including downloading one of our applications or visiting our website, you agree to the use, disclosure, and procedures outlined in this Privacy Policy.

What information is covered under this policy

We do our best to minimize the amount of Personal Information that we collect from StarKey Wallet users. Your contact information, such as your phone number or email address (depending on how you contact us), may be collected when you communicate with us for support, or if you report a bug or other error related to StarKey Wallet or when you interact with us through social media. When you use our Services, we process PUBLIC wallet addresses that you generate through StarKey Wallet..

We never share your personal data with third parties

This Privacy Policy covers your personal information. Personal information is information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable. All personal information received in connection with our business is subject to strict rules of confidentiality.

Common examples may include your name, username, password, IP address, unique device identifiers, gender, signature, address, telephone number, email, date of birth, bank account and digital wallet details, billing and credit or debit card details, photos and videos of you, other identification credentials and biographical details, and commentary or opinions about you.

Personal information that we may collect from you

We may collect some or all of the following types of personal information:

  • Information that you give us through your dealings with us.
  • Information that we may collect from you; and
  • Information that we may receive from you from other third party sources.

By agreeing to this Privacy Policy, you consent to the fact that you are aware that we are collecting your personal information and disclosing it as required by us and in accordance with applicable privacy laws and principles.

How personal information is collected

"Personal information" is data that identifies, relates to, describes, can be used to contact, or could reasonably be linked directly or indirectly to you. For the purposes of this Privacy Policy, there is no meaningful distinction between the terms "personal information" and "personal data".

You may choose not to provide some of the personal information described above. Please note, however, that some of our services require some personal information to operate, so if you choose not to provide the personal information necessary to operate and provide you with a particular service or feature of that service, you may not be able to use that Service or feature.

Information that you give us

We may collect your personal information directly from our contact with you. This may include by you completing forms or parts of our website, Social Media, and/or other software and/or mobile applications, by you providing us with consent to access personal information such as photographs, videos or photo albums, by you providing us with consent to access the microphone and/or camera on your device, or by you contacting us via the email, telephone, through Social Media and other similar functions either directly through our website or through third party host websites, in person, through various marketing channels or competitions either directly through our website or through third party host websites, and surveys.

You understand that any personal information that you provide to us must be accurate and up to date. We will assume this to be the case.

Information that we collect about you

In this Privacy Policy "Social Media" means social media networking sites of any kind or nature including but not limited to web or internet based or mobile telephonic devices or medium such as Facebook, Twitter, Instagram and LinkedIn which enable the creation and exchange of user generated content.

Our website, Social Media, and/or other software and/or mobile applications may automatically collect the following information about you each time you visit or otherwise use our website, Social Media, and/or other software and/or mobile applications:

  • Technical information including but not limited to the Internet Protocol Address used to connect your device to the internet, the internet browser and version that you are using when accessing our website, Social Media, or other software and/or mobile applications, any additional plug-ins that you are using, and your device’s operating system and platform.
  • Information about the time and date you accessed our website, Social Media, or other software and/or mobile applications, and what you accessed on our website, Social Media, or other software and/or mobile applications. This includes links that you clicked on, what content you accessed, how long you accessed that content for, whether you downloaded any content, whether supplied by us or downloaded from a third party host, and how you navigated to and from our website, Social Media, or other software and/or mobile applications to other sites, apps or other pages hosted by us.
  • Details about the computer, device, hardware, or software used to access our services, such as IP address, device identifiers, internet service provider, plugins, device make and model, operating system, browser type, and other system specifications; and
  • General location of your device derived from your IP address.

We use technologies like cookies, log files, and web beacons to collect this information. These tools help us and our service providers recognize your device, manage authentication, remember preferences, personalize experiences, manage advertising, and conduct data analytics.

Sensitive information

Throughout the course of collecting your personal information, we may collect sensitive information about you. Sensitive information includes:

  • Information or an opinion about your racial or ethnic origin; or political opinions; or membership of a political association; or religious beliefs or affiliations; or philosophical beliefs; or membership of a professional or trade association; or membership of a trade union; or sexual orientation or practices; or criminal record that is also personal information; or
  • Health information about an individual; or genetic information about an individual that is not otherwise health information; or biometric information that is to be used for the purpose of automated biometric verification or biometric identification; or biometric template.

If we do collect any of your sensitive information, we will only collect this information with your consent and for reasons that are reasonably necessary or otherwise related to the provision of our services in accordance with applicable privacy laws and principles.

Where you consent to our collection of your sensitive information, you also consent to us using that sensitive information for the purpose/s for which it was collected, including its disclosure to third parties.

How we use the information we gather

You consent to the disclosure of your personal information to any of our related entities.

You consent to our collection of your personal information and disclosing it to third parties where necessary and for the purposes for which it was collected.

This may include:

  • Contact you when necessary
  • Respond to your comments, questions, or issues related to bugs or errors with StarKey Wallet.
  • Provide you with additional information.
  • Send you information and marketing materials about services and products available through StarKey Wallet, using push notifications or other means.
  • Train our team members
  • Providing our Services
  • Investigating and/or preventing suspected fraud or other criminal activities or misuse of our services.
  • Were we collect or disclose information that is or relates to the Internet Protocol Address used to connect your device to the internet, for the purpose of fraud detection and management of the integrity of the services. This may include detecting when users who engage in illegal activities or breach our Terms of Use.
  • Where information is or relates to system version information of your device, or the make and model of your device, for the purpose of our compatibility assessments with our software versions and other aspects of our services.
  • Using your personal information to provide you with information that you have requested from us, although we do not create a link between your user ID and your user email.
  • Notifying you about any changes to our products, website, and/or other software and/or mobile applications, brand or services offered.
  • For other general services such as website/software security, maintenance, identification of fraud or errors, internal accounting and administration, and for any other purpose that we are required or permitted to do by law. and
  • Managing our relationships with you and our other customers.

Aggregated Personal Data and Non-Personal Information

We may share or disclose aggregated Personal Data or Non-Personal Information with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the company. These service providers and other persons may also share with us aggregated Non-Personal Information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, and web beacons, with similar data we collect from other visitors to help us improve our Services. When doing so, we do our best to ensure that aggregated information cannot be linked back to you.

Agents or Third Party Partners We may provide your Personal Information to our employees, contractors, agents, service providers, and designees (“Agents”) to enable them to perform certain services for us, including improvement of website-related services and features, and performance of maintenance services.

Business Transfers We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your Personal Information could be one of the assets transferred to or acquired by a third party. By accepting this Privacy Policy, as outlined above, you consent to any such transfer.

Protection of Us and Others We will share personal information outside of StarKey Wallet if we have a reasonable belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request to cooperate with law enforcement; to enforce or apply our Terms of Use and other agreements; or to protect the rights, property, or safety of StarKey Wallet, our employees, our users, or others.

How do we share your personal data with third parties

Information about our users is an important part of our business and we are not in the business of selling our users’ personal information to others. We may transfer personal data to our service providers or third parties in connection with StarKey Wallet’s operation of its business, as certain features on StarKey Wallet rely on various third-party products and services (collectively “Third Party Services”). These third party services providers only have access to certain Personal Information, such as your public Wallet addresses, to perform their functions and may not use it for other purposes. Furthermore, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protections laws.

Business transfers: As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy notice (unless, of course, the user consents otherwise). Also, in the unlikely event that StarKey Wallet or substantially all of its assets are acquired, users’ information will be one of the transferred assets. We may share non-personally identifiable information publicly and with our partners- like publishers, advertisers, developers, or right holders.

Legal obligations to disclose

We may be required to disclose your personal information for the purposes for which it was collected and also subject to our legal obligations:

  • As required by law
  • To any person where necessary or desirable in connection with our provision of services. and
  • On a confidential basis to our external service providers and advisors.

To be clear, you consent to our disclosure of your personal information to any of our business partners, suppliers, subcontractors or the like, advertisers and other advertising networks, analytics and search engine providers and other third parties provided the disclosure of your personal information is for the purpose or ancillary to the services that we or these third parties offer you and for the purposes the information was originally collected.

We may share your information with other third party business partners for their own marketing purposes. These third parties include online advertisers or ad tech companies, who may provide you with targeted advertising and marketing communications, where permitted under law. The information we share includes information collected through your use of our services and information we collect about you through the use of cookies and similar technologies.

You understand that we are authorized to disclose your personal information to third parties if we buy or sell any business or assets, including our business, if we are under a duty to disclose your information, or if the disclosure of your personal information is necessary for us to conduct an investigation into any unlawful activity that we know or suspect has or may be engaged in.

Your rights with respect to the processing of personal data

Through our website, Social Media, and/or other software and/or mobile applications, we provide services to users throughout the world. As we process personal information of data subjects inside the European Economic Area (“EEA”) we are bound by Regulation (EU) 2016/679, the General Data Protection Regulation (“GDPR”).

The purpose of the following data protection information is to provide you with an understandable, transparent and concise explanation of how we intend to process your personal data in accordance with Articles 13 and 14 of the GDPR. However, should you require further explanations relating to our data protection or wish to exercise any of your rights, please do not hesitate to contact our Privacy Officer at support@starkey.app.

We recognize the below rights which you enjoy under the applicable data protection law with respect to your personal data:

  • Right to be informed: You have the right to be informed about the collection and use of your personal data. This information is set out in the terms of our Privacy Policy.
  • Right of access: You may request information from us at any time as to whether we have stored your personal data and which personal data it has stored. We are required to provide this information to you free of charge.
  • Right to rectification: If your personal data stored by us is inaccurate or incomplete, you have the right to demand at any time that we correct the information.
  • Right to erasure: You have the right to demand that we erase your personal data if and to the extent that the data is no longer needed for the purposes for which it was collected or if the data is processed on the basis of your consent and you have opted to revoke your consent. In such cases, we must cease processing your personal data and remove that data from our IT systems and databases.

You do not have a right to erasure if:

  • The data may not be deleted due to a statutory obligation or must be processed due to a statutory obligation.
  • The processing of data is necessary for the establishment, exercise or defence of legal claims.
  • Right to restriction of processing: You have the right to demand that we restrict the processing of your personal data.
  • Right to data portability: You have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format. You also have the right to request that we transmit this data to another controller, where technically feasible. This right applies only if the processing is based on your consent or a contract and is carried out by automated means.
  • Right in relation to automated decision-making and profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. This right does not apply if the decision is needed for a contract with us, is required by law, or is based on your consent.
  • Right to object to processing: If your data is processed by us on the basis of Article 6(1)(f) GDPR, you may object at any time to processing by us. You may assert any and all of the rights of data subjects described above against us by addressing your specific requests by contacting our Privacy Officer via support@starkey.app
  • Right to lodge a complaint with a data protection supervisory authority: Pursuant to Article 77 GDPR, you have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes data protection law.

Complaints

If you are concerned about a possible interference with your privacy or about the potential misuse of your personal information, please contact us at the above email address.

Data retention

We will only keep your information for as long as reasonably necessary to fulfill the purposes for which your personal information was originally collected.

We will delete your information after a reasonable time. You may be required to re-enter your personal information if it has been deleted.

You agree and acknowledge that we use third party servers to store and process data. As such, your personal information may be stored at on servers based around the world, including in North America, Europe or Asia, or transferred within any of these jurisdictions, or a destination outside of these jurisdictions. This will allow our staff (whether employed by us or by a third party engaged by us or otherwise authorized under this Privacy Policy to access your personal information) to process your information for the purposes of providing you with our services.

Please note that even If you delete your Wallet or addresses from the StarKey Wallet application, uninstall StarKey Wallet applications from your device, or request that your information be deleted, we still may retain some information that you have provided to us to maintain StarKey Wallet or to comply with the laws and regulations to which StarKey Wallet is subject. If you have any question or objection as to how we collect and process your personal information, please contact support@starkey.app.

Data security

We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. We have selected third-party vendors that use the Ethereum network, including Coinbase, Shapeshift, and Changelly, that help us keep your Personal Information safe. Unfortunately, we do not control these third parties and therefore cannot guarantee complete security. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information and secure all connections with industry standard transport layer security. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk.

Children

We are especially sensitive about children’s information. Our Services are not targeted towards children, and our users must be at least eighteen (18) years old to use our services. We don’t knowingly collect information from children under the age of 13. If you are a parent or legal guardian of a minor child, we will treat any information that you provide us while using StarKey Wallet on behalf of your minor child as Personal Information as otherwise provided in this Privacy Policy. If you have questions concerning our information practices with respect to children, or if you learn that a child under the age of 13 has used StarKey Wallet, created a user account, or provided us with personal information, please email us at support@starkey.app.

Collections of your information using cookies and other tracking technologies

Our website and/or other mobile applications use "cookies". Cookies are small pieces of data sent from a website and stored in your web browser. These pieces of data will allow our website and/or other mobile applications to remember who you are and to obtain information from you which allows us to deliver you a better and more customized service.

As a result of our website and/or other mobile applications’ use of cookies, we may collect information such as your IP address, online activity and your web browser details. Information that we will not collect or store includes your passwords or other sensitive information.

We will use both persistent cookies, which could remain on your device until their expiration (which can be, in some cases, up to 10 years), and session cookies, which are temporary files removed from your device once your browser is closed.

The types of cookies we may use include analytical and tracking cookies, which allow us to recognize and count the number of visitors and analyse use of the services, as well as to verify transactions, and advertising and re-targeting cookies, which allow us to generate appropriate advertising directed to you on our website.

If you enabled cookies when accessing our website and/or other mobile applications, we will take this as consent to our use of cookies and other technologies mentioned in our Privacy Policy.

Please note that you should also refer to our website’s Terms of Use for further information on this issue.

Conditions of use, notices, changes and updates to privacy notice

If you choose to use StarKey Wallet, your use and any dispute over privacy is subject to this Notice and our Terms of Use. If you have any concerns about privacy at StarKey Wallet, please contact us with a complete description, and we will try to resolve it. You also have the right to contact your local Data Protection Authority. We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of StarKey Wallet after an amendment to our Privacy Policy constitutes your acceptance to the revised or amended terms.

Questions

We’d be happy to answer them. Shoot us an email.

Email: support@starkey.app