Privacy Notice

OneArt Wallet

Last update: 02 August 2023

OneArt Digital OÜ (“we”) care about your personal data, and we do everything to protect it. This Privacy Notice (“Notice”) was created to help you to understand how your personal data is collected, stored and processed and what happens if you use our mobile application.

Data subject	Description
User	The one who creates an account in our App

Context:

Purpose of this Privacy Notice

Who we are

Personal data we process

Technical data
Users’ data
Data provided by third parties

Period of data storage

Information on data transfer

General
Transfer outside the European Economic Area

Your privacy rights

Transfer of data outside the European Economic Area

Update

Purpose of this Privacy Notice

Privacy Notice is a document, practically a statement of us as a data controller to you (data subject) that describes how we collect, use, retain and disclose personal data.

Our Privacy Notice applies only to our OneArtWallet mobile application for iOS (“App”).

Who we are

Data controller	OneArt Digital OÜ, registration number: 12551952
Address	Estonia, Tallinn, Harju maakond, Mustamäe linnaosa, Retketee 26-25, 13419
Email	support@oneart.digital - for general questions
Email	privacy@oneart.digital - for privacy questions

Personal data we process

The data we process is divided into three categories: technical data, data provided to us by the users and data provided by third parties.

Please note: we do not knowingly process personal data of users under the age of 18 without consent from a legal representative(s). If you are such a user or the legal representative of the user, please let us know by email: [email protected].

Technical data. When you use our App, some data is collected automatically. We need technical data to operate, maintain, and improve our application.

This includes IP address, device type, session ID, account data, mobile operator, device operating system, phone model, serial number, APNs token, device ID, geolocation, UTM parameters, MAC, name of your internet service provider, browser type, device type, API and data about your interaction with the app – session ID.

Users: We may collect wallet information and transaction information.

Data obtained from third parties: Information we can get from AppStore and Appsflyer.

Once again, briefly about what personal data we collect:

Technical data

Type of data	Description of data	Legal basis	Reasons for processing
You use our App	technical data; IP address; device type; account data; mobile operator; device operating system; session ID; phone model; serial number; APNs token; API; device ID.	Legitimate interest	Analytics; Statistics.

Users’ data

Type of data	Description of data	Legal basis	Reasons for processing
You create an account	your wallet(s) public address(es).	Performance of the contract	Registration; provide a service.
You click “Import wallet”	your wallet(s) public address(es).	Performance of the contract	Provide a service
You click “Save Contact”	Contact’s wallet public address.	Performance of the contract	Provide a service

Data obtained from third parties

Type of data	Description of data	Legal basis	Reasons for processing
You leave a review on the Appstore	photo; name; email; comment; evaluation.	Legitimate interest	Analytics; support.

Period of data storage

We store only users’ wallet addresses. Due to the blockchain nature, your wallet address is stored there for a really long time. In our databases we store your data while you use our services and 3 years after.

We store automatically collected data for up to 3 years.

You can exercise your right to delete your data. In this case, we will delete your data from our servers within 30 days of your request.

Please note! The duration of data storage received from third parties is determined by the relevant privacy documents of such services.

The length of time we can retain data from third parties is determined by Apple Privacy Policy.

Please note! Some data contained in documents that are required by law to be stored for a longer period of time (for example, accounting documents).

Information on data transfer

General

We use your personal data to perform a contract and for communication between the user and us. We use and transfer your personal data to the extent it is necessary to perform a contract. Also, we transfer your data on the following grounds:

Consent. We transfer your personal data based on your explicit consent.

Compliance with the law. We will disclose your personal data to third parties to the extent that it is necessary:

to comply with a government request, court order, or applicable law;
to prevent unlawful use of our App or violation of the Terms of Use of our App and our policies;
to protect against claims of third parties;
to help prevent or investigate fraud.

Legitimate interest or performance of the contract. We transfer your personal data to third parties on the basis of a public offer for processing on our behalf, subject to technical and organizational measures to protect your personal data.

Transfer outside the European Economic Area

The personal data we collect is stored on Digital Ocean. The data is stored in France by default, but we may need to process your personal data in another country.

If we need a data transfer, we will use technical, administrative and physical security measures to protect against the loss and misuse of information under our control. However, if a data transfer is required to perform a contract or to provide you services, we have the right to do so without your consent.

Please note! We do not plan to transfer your data outside the EEA by default.

Your privacy rights

You, as subjects of personal data, have the following rights:

The right	Description
To access information	You can request an explanation of the processing of your personal data
To portability	You can request all the data that you provided to us, as well as request to transfer data to another controller
To restrict processing	You may partially or completely prohibit us from processing your personal data
To file complaints	If your request was not satisfied, you can file a complaint to the regulatory body
To be forgotten	You can send us a request to delete your personal data from our systems, unless there is a legal requirement to keep it
To withdraw consent	For data that you have previously consented to, you can always withdraw your consent and we will stop processing it
To exercise your rights, send us an email privacy@oneart.digital.

If your request was not satisfied, you can file a complaint to the Data Protection Inspectorate’s regulatory body at [email protected] or write a letter to 39 Tatari St., 10134 Tallinn.

Transfer of data outside the European Economic Area

The personal data we collect is stored on Digital Ocean. The data is stored in France by default, but we may need to process your personal data in another country.

Update

The GDPR regulates this Privacy Notice and the relationships falling under its effect.

Existing laws and requirements for the processing of personal data are subject to change. In this case, we will publish a new version of the Privacy Notice in our App.

If significant material changes are made that affect your privacy and confidentiality, we will notify you by email or display information on the App and ask for your consent.