BANCOLIBRE PRIVACY POLICY

This privacy policy (“Policy”) explains how Amboss Technologies, Inc. and our affiliates (collectively, “Amboss”, “we”, “us” or “our”) collects, stores, uses, and discloses personal data about you and how you can make requests or submit inquiries to us about your personal data.

Please read this Policy carefully. If you do not agree with this Policy or any part thereof, you should not access or use any part of the BancoLibre Services. If you change your mind in the future, you must stop using the BancoLibre Services.

WHAT DOES THIS POLICY COVER

This Policy applies to personal data we collect through our website located at https://bancolibre.com/ (opens in a new tab) and successor sites (collectively the “BancoLibre Sites”) in connection with digital wallet and messaging services that we provide you (and together with the BancoLibre Sites, the “BancoLibre Services”). This Policy does not apply to any products, services, websites, or content that are offered by third parties or have their own privacy policy.

In this Policy, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data or is otherwise defined as “personal data,” “personal information,” or “personally identifiable information” by applicable laws.

In general, we collect personal data in encrypted form as the BancoLibre Services are designed to encrypt data directly on your device e.g., on the client side. Therefore, we only receive the limited personal data that is sent from your device to our servers. This protects against us and third parties from being able to read your personal data. However, many jurisdictions still consider encrypted data as personal data protected under applicable laws. We may need to collect, use and share your personal data (even in encrypted form) in certain circumstances, which we explain in detail in this Policy.

HOW IS THIS POLICY UPDATED

We may modify this Policy from time to time. If we make changes, we will revise the “Last Updated” date at the top of the Policy on our BancoLibre Sites and use reasonable efforts to provide you additional notification by sending you an email notification. We encourage you to review this Policy each time you visit our BancoLibre Sites to stay informed of our privacy practices and the choices available to you.

INFORMATION WE COLLECT

The personal data we collect about you depends on how you interact with us or use the BancoLibre Services. However, we take your privacy seriously and adopt data minimization principles to collect the least amount of personal data that we can in order to provide you with the BancoLibre Services and fulfill our legal and contractual obligations. We describe below the categories of personal data we collect and the sources of this information.

Information You Provide to Us

We collect personal data from you when you use the BancoLibre Services (for example, when you create an account), request customer support, or otherwise communicate with us. The types of personal data we may collect include your email address, master password hash and other information you provide during the account creation process, information you provide during customer support interactions, and any additional information that you choose to provide.

The types of personal data we may collect depend on how you use the BancoLibre Services.

Account Creation:

During the account creation process, we may collect your master password hash or your passkey public key, and your email address.

Information Necessary to Process Transactions:

We may collect your wallet public keys and payment destination information (including your Blockchain address, Lightning address, and MIBAN Code) in order to process transactions on your behalf.

Information Necessary to Provide Support:

In order to provide support, we may collect contact information, including your name, email address, Lighting address, telephone number, mailing address, as well as any additional information that you choose to provide such as feedback and survey responses.

Information Necessary to Provide Chat:

In order to provide the BancoLibre messaging functions, we collect the encrypted message content (i.e. the encrypted message or encrypted file) as well as connections data, such as the MIBAN Codes of other users you choose to include in your contact list in the BancoLibre Services.

Information Necessary to Provide Third Party On- or Off-Ramp Services:

Government-issued identification such as social security number, driver’s license, or state-issued identification number;
Transactions and Payment Information such as your credit card or bank account number you provide to us if you use the BancoLibre Services to send payments, which we may share with third-party payment processors as described in this Policy.

Information Collected Automatically When You Interact With Us

We and our service providers may automatically log personal data about you, your computer or mobile device, and your interaction over time with the BancoLibre Services, such as:

Device information. We may collect information about your device(s) such as Internet Protocol addresses, browser type, domain names, access times, log information, error messages, device type, unique device identifiers, and other technical information such as protocol status and substatus, bytes sent and received and server information.
Usage information. We may collect information about your use of the BancoLibre Services, such as the pages you viewed, the BancoLibre Services you used or interacted with, the referring website addresses and details about any links or communications with which you interacted.
Analytics information. We currently use Plausible Analytics to provide analytics information, which may include device information. To learn more about Plausible Analytics’s data policy, please visit https://plausible.io/data-policy (opens in a new tab).
Information Collected by Cookies and Other Tracking Technologies. Please see our cookie policy in the section “Cookies and Other Information Collection Tools” for more details on the information we and our service providers collect about you.

Information We Infer or Derive

We may derive information or draw inferences about you based on the personal data we collect or have otherwise received about you. For example, we may infer your approximate location based on your IP address.

HOW WE USE YOUR PERSONAL DATA

Depending on how you interact with us and the BancoLibre Services you or your organization utilize, we use your personal data to:

Provide and Improve Products and Services. Provide, activate, operate, maintain, develop, enhance, improve, and manage the BancoLibre Services and your accounts on the BancoLibre Services, monitor and analyze trends, usage, and activities, and to perform services requested by you.
Respond to You. Provide technical, product and other support and respond to your requests, inquiries, comments and concerns.
Service Communications. Notify you about changes, updates and other announcements related to the BancoLibre Services and send you technical notices, updates, security alerts, support messages, and other transactional or relationship messages.
Safety and Security. For safety and security, including to detect and protect against fraud or illegal activities, security incidents, and harm to rights, property or safety of Amboss, our users or others;
Corporate Transactions. We process personal data if we are required to do so to conduct a merger, sale of our assets, financing or acquisition of all or a portion of our business to another company;
Comply with Legal and Financial Obligations. To comply with our legal and financial obligations, resolve disputes, enforce our agreements, and exercise our legal rights; and
Your Consent. We may process your personal data in accordance with your consent or when you intentionally direct or instruct us to do so.

DISCLOSURE OF PERSONAL DATA

We may disclose your personal data as follows or as otherwise described in this Policy:

Affiliates and Subsidiaries. We disclose your personal data to our affiliates and other organizations under common control for the purposes described in this Policy;
Other Users. We disclose your personal data to other BancoLibre users whom you choose to transact with through the BancoLibre Services to the extent necessary to complete your transaction e.g., if you use the BancoLibre Services to send messages to other users.
Third Parties You Intentionally Interact With. We disclose your personal data to third parties when you use the BancoLibre Services to intentionally interact with those third parties or direct us to interact with those third parties;
Vendors and Service Providers. We disclose your personal data to our vendors and service providers to perform the functions for which we engage them. For example, we may receive or disclose your personal data to third-party on- or off-ramp providers, if you choose to use these features that we make available through the BancoLibre Services;
Corporate Transactions. We disclose your personal data if we are required to do so during a merger, sale of our assets, financing or acquisition of all or a portion of our business to another company;
Professional Advisors. We disclose your personal data to our professional advisors like our lawyers, accountants, financial, insurance and other advisors in connection with the management of our business or operations;
Aggregated, Anonymized, or De-Identified. We disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you;
Law Enforcement and Individuals Involved in Legal Proceedings. We disclose your personal data when we believe doing so is reasonably necessary to comply with applicable law or legal process or other legal reasons.
With your Consent or Direction. We disclose personal data with your consent or at your direction, including if we notify you that your personal data will be shared in a particular manner and you provide such personal data.

We do not share your personal data with third parties for those third parties’ direct marketing purposes.

HOW WE PROTECT YOUR PERSONAL DATA

We implement commercially reasonable physical, technical and procedural measures like encryption to help protect personal data from unauthorized access or use; however, the transmission of information via the internet is not completely secure or private. If you have questions about the security of personal data we collect, please contact us using the information provided below.

COOKIES AND OTHER INFORMATION COLLECTION TOOLS

What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the online service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information.

Duration of cookies. We may use “session cookies” or “persistent cookies.” Session cookies are temporary and expire once you close your browser or once your session ends. Persistent cookies remain on your device for much longer or until you or your browser erases them. Persistent cookies have varying durations that are dependent on their expiration date.

What cookies do we use and why do we use them? We use necessary cookies to allow you to log in to the BancoLibre Services, as well as functional cookies to allow you to set your theme and language.

How do I control cookies? Web browsers allow some control of most cookies through the browser settings. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the BancoLibre Services or impair the functionality of the BancoLibre Services.

Where required by applicable law, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to provide the BancoLibre Site or the BancoLibre Services e.g., Necessary Cookies; or (ii) for the purpose of facilitating a communication.

THIRD PARTY LINKS AND SERVICES

Occasionally, at our discretion, we may include or offer third party products or services on our BancoLibre Sites or links to other websites. The privacy practices of these third parties will be governed by the parties’ own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy notices or policies applicable to these third party products and/or services. We have no responsibility or liability for the content and activities of these linked websites or the services they provide.

RETENTION OF PERSONAL DATA

We will retain your personal data for as long as is necessary to fulfill the purpose for which this data was collected and for the business purposes explained in this Policy.

Even after we stop providing BancoLibre Services directly to you, and even if you close your account, we may retain your personal data solely:

to comply with our legal and regulatory obligations.
to exercise, establish or defend legal claims.

In cases where we keep personal data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.

YOUR PRIVACY RIGHTS AND CHOICES

Consistent with applicable law, you may exercise the rights described in this section. Please note that the rights may vary depending on your country or state of residence. Please see the Region Specific Terms section below. To exercise your data protection rights please contact us as listed below.

While it is our policy to respect the rights of individuals, please be aware that your exercise of these rights is subject to certain exemptions and exceptions, and some of these rights might be limited (for example the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to deliver services to you, defend our rights or meet our legal and regulatory obligations.

If you contact us to exercise any of these rights, please note that we may only implement requests with respect to the personal data associated with you as an individual. We may need to verify your identity before implementing your request and will try to comply with your request as soon as reasonably practicable and in accordance with the timelines required under applicable law. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.

Access, Correct or Delete your Personal Data

You may have the right to request access to and receive details about the personal data we maintain about you and how we process it, correct inaccuracies, or request that we delete your personal data by contacting us as indicated below.

Withdraw Consent

Where you have provided your consent for us to use your personal data and subject to applicable law, you have the right to withdraw your consent and we will apply that preference going forward.

Additional Rights

Depending on your location and subject to applicable law, you may have the following additional rights regarding the personal data we control about you:

The right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data;
The right to request that we restrict the use of your personal data in certain circumstances, such as while we consider another request that you have submitted (including a request that we make an update to your personal data);
The right to request that we export your personal data that we hold to another company or organization, where technically feasible;
Where we process your personal data based on our legitimate interests, you may also have the right to object to the processing of your personal data. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your personal data when you object;
The right not to be discriminated against for exercising these rights; and/or
The right to appeal any decision by us relating to these rights.

CHILDREN’S PRIVACY

The BancoLibre Services are not aimed at children under the age of 18 or the age of majority defined under applicable law. We do not knowingly collect information from children under the age of 18 or the age of majority defined under applicable law.

INTERNATIONAL DATA TRANSFERS

We may process and store your personal data in the United States and other countries which may have less-protective data protection laws than the region in which you are situated. Please note that this processing, including storage, may involve cross-border transfers of your personal data. In certain situations, we may be required to disclose personal data in response to lawful requests from officials (such as law enforcement or security authorities).

Where applicable law requires a data transfer mechanism, we use one or more of the following:

Transfers to certain countries or recipients that are recognized as having an adequate level of protection for personal data under applicable law;
EU Standard Contractual Clauses approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office;
or other legal methods available to us under applicable law.

CONTACT US

You may contact us using the information below.

Attn: Amboss Technologies, Inc.
e-mail: [email protected]

Region Specific Terms

ADDITIONAL INFORMATION FOR RESIDENTS OF THE EEA, UK AND SWITZERLAND

If you are a resident of the European Economic Area (“EEA”), Switzerland or the United Kingdom, you may have certain rights and protections under applicable law regarding the processing of your personal data. In the event of a conflict between the rest of our Policy, this Additional Information for Residents of the EEA, UK and Switzerland notice will prevail as to data subjects and their rights under the applicable privacy law.

Legal Basis of Processing

When we process your personal data as described in this Policy, we are required to have a legal basis to do so. The legal bases we use are as outlined below:

Processing on the basis of performance of a contract: where your information is necessary to enter into or perform our contract with you or the organization you represent;
Processing data on the basis of consent: where you have given us consent for us to process your personal data for a specific purpose. When processing is based on consent, you have the right to revoke such consent at any time;
Processing data on the basis of our legitimate interests: where we use your information to achieve a legitimate interest, including providing, improving and maintaining the BancoLibre Services, communicating with our current and prospective customers, suppliers and partners, managing our relationships with our customers, vendors and partners, sharing your personal data with our affiliates as well as service providers and vendors, and developing new BancoLibre Services; and
Processing data because we have a legal obligation to do so: We process your personal data when it is necessary for us to defend a claim or resolve a dispute or when we need to use your personal data to comply with our legal obligations, including payment of taxes, responding to law enforcement agencies and other governmental bodies (when required by applicable law), retaining business records required to be retained under applicable law, and copying with court orders and other legal process.

If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see:

For individuals in the EEA: https://edpb.europa.eu/about-edpb/board/members_en (opens in a new tab)

For individuals in the UK: https://ico.org.uk/global/contact-us/ (opens in a new tab)

For individuals in Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html (opens in a new tab)