AppCoins Wallet Privacy Policy

Last updated: June 2021

1. Introduction

Welcome to the AppCoins Wallet privacy notice.

AppCoins Wallet is a software developed by Aptoide S.A. (“Aptoide”), a company with ID 509987184 and principal place of business at Rua Soeiro Pereira Gomes, Lote 1, 3D, 1649-031 Lisboa, and its registered office at Rua Fernanda Seno n. 6, 7005-484, Évora, Portugal, 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.

2. Important information and who we are

Aptoide, S.A., a Portuguese company, with the identification number ID 509987184 and principal place of business is at Rua Soeiro Pereira Gomes, Lote 1, 3D, 1649-031 Lisboa, and its registered office is at Rua Fernanda Seno n. 6, 7005-484, Évora, 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.

3. 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.

4. 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 and transaction location
• Financial Data: Payment processor account email, Wallet address
• Transaction Data: includes details about payments and transactions made by you using the AppCoins Wallet, including the date, time and amount of the transaction.
• Technical Data: includes internet protocol (IP) address, unique device identifier, browser type and version, time zone setting and location, browser plug-in typesand versions, operating system and platform and other technology on the devices you use to accessour 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.

5. 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:
  1. apply for our products or services;
  2. create a Wallet Account by using AppCoins Wallet;
  3. 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:
  1. Technical Data from the analytics providers, based inthe EU and outside the EU;
  2. Identity, Financial and Transaction Data from providers of technical, payment and delivery services based in the EU and outside the EU.

6. 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.

7. 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.

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 tohow 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 whichallows 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.

8. COOKIES

A cookie is a small file placed onto your device that enables the website features and functionality. We only use cookies on the website.

At any moment, you can set your browser to accept or reject new cookies or to deactivate cookies already installed in your computer or mobile device. This action could retrieve on an unsatisfying use of the website.

• How do we use cookies: On our website we use cookies for performance, analytics and research purposes. That means that cookies help us learn how well our website performs in different locations. We also use cookies to understand, improve, and research products, features, and services, including when you access the website from other websites, applications, or devices such as your work computer or your mobile device.

• Types of cookies we use: We only use “Third Party Cookies”, which are cookies placed by a third party (including, for example, providers of external services like web traffic analysis services) in the website, over which we have no control. These cookies are likely to be analytical/performance cookies.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

*Please note that the names of cookies, pixels and other technologies may change over time.

• Controlling cookies: Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information. If you don’t want to receive cookies, you can change your browser settings on your computer or other device you’re using to access our websites. If you use our website without changing your browser settings, we’ll assume that you’re happy to receive all cookies related with the website. Most browsers also provide functionality that lets you review and erase cookies. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.wikipedia.org, www.allaboutcookies.org, www.aboutcookies.org.

9. 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 in the website. Such data include: your WalletAccount, 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:

  1. Hosting, provided by, namely, Leaseweb and Amazon;
  2. Security, provided, namely, by Cloudfare;
  3. Analytics, provided by, namely, Google;
  4. Payment processing, provided by, namely Adyen, Paypal, Dimoco and Coda Payments Pte Ltd.
• 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.

10. 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.

11. 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.

12. 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 you can contact us.

13. 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:

1. 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.
2. 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.
3. 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.
4. 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.
5. 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.
6. 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.
7. 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.

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.