Privacy Policy

Last Reviewed and Updated: 2023/11/15

XDB Foundation (“we,” “our,” and/or “us”), values the privacy of individuals who use our websites (including the “Website”), Software, or Services, including the XDB WALLET that is downloadable from the Website, and any services that link to this Privacy Policy (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Data from users of our Website, Software, and Services.

For the purposes of this Privacy Policy, “Personal Data” means information that relates to an identified or identifiable natural person.

By using our Website, Software, or Services, you agree to the collection, use, and disclosure of your Personal Data as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Site or Services is also subject to our Terms of Service.

As the XDB WALLET is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your Personal Data to us to use the XDB WALLET. However, certain third party API providers may require you to provide them with Personal Data, in order to use their services through the XDB WALLET.


INFORMATION WE COLLECT

We may collect limited Personal Data from or about you or your devices from various sources, as described below.
Information You Provide to Us. If you contact us with questions, or to seek technical assistance, you may choose, but we will not require, to provide Personal Data such as your email address, name, wallet address, etc. You may also provide Personal Data in connection with transactions that occur through the XDB WALLET. This data, such as your wallet address, counterparty wallet address, details of the transaction, will not be collected by us, rather it will be recorded on the blockchain which will be publicly accessible.

Information We Collect Automatically. We may automatically collect information about you and your devices when you use our Website, Software, or Services. For example, when you visit our Website, we collect your internet protocol (IP) address, you click on, and other information about your use of our Website.
Cookies. We do not use cookies, pixel tags, or similar technologies on our Website or Software.
Information We Receive from Third Parties. We do not receive information about you from third parties.


HOW WE USE THE PERSONAL DATA WE COLLECT

  • To communicate with you, provide you with updates and other information relating to our Site and Services, provide information that you request, provide you with our newsletter, respond to comments and questions, and otherwise provide customer support.
  • For compliance purposes, including enforcing our Terms of Use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
  • For other purposes for which we provide specific notice at the time the Personal Data is collected.
  • LEGAL BASIS FOR PROCESSING EUROPEAN PERSONAL DATA
  • If you are located in the European Economic Area or the United Kingdom, we only process your Personal Data when we have a valid “legal basis”, including when:
  • Consent. You have consented to the use of your Personal Data.
  • Contractual necessity. We need your Personal Data to provide you with the Services, for example, to respond to your inquiries.
  • Compliance with a legal obligation. We have a legal obligation to use your Personal Data, for example, to comply with tax and accounting obligations.
  • Legitimate interests. We or a third party have a legitimate interest in using your Personal Data.


HOW WE SHARE THE PERSONAL DATA WE COLLECT


We do not share or otherwise disclose Personal Data we collect from or about you except as described below or otherwise disclosed to you at the time of collection.

  • Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy.
  • As Required by Law and Similar Disclosures. We may access, preserve, and disclose your Personal Data if we believe doing so is required or appropriate to: (i) comply with applicable laws; (ii) respond to law enforcement requests and legal process, such as a court order or subpoena; or (iii) protect the rights, property, and safety of XDB Foundation, our employees, agents, customers, and others, including to enforce our agreements, policies, and Terms of Use.
  • Merger, Sale, or Other Asset Transfers. We may transfer your Personal Data to service providers, advisors, potential third-party API providers, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.
  • Vendors and Service Providers. We may share your information with vendors and service providers retained in connection with the provision of our Services.
  • Consent. We also may disclose your Personal Data with your consent.


INTERNATIONAL DATA TRANSFERS

Your information, including the Personal Data that you provide to us, may be transferred to, stored at and processed by us outside the country in which you reside, including, but not limited to the Cayman Islands, or any country where a blockchain node operates, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By providing any information, including Personal Data, you consent to such transfer, storage, and processing. Personal Data may be transferred from the European Economic Area or the United Kingdom to one or more countries that do not provide “adequate measures”, as needed, to perform the Services that you have requested.


SECURITY

We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. However, as no electronic transmission or storage of Personal Data can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Data. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us via the “Contact Information” section below.


RETENTION

We will only retain your Personal Data as long as reasonably required for us to provide the requested customer support and inquiry services. In the context of customer support, we retain information sufficient to connect subsequent requests from the same user in order to provide efficient service, unless a longer retention period is required or permitted by law (for example for regulatory purposes). Data recorded to the blockchain, as will be the case if you conduct any transactions using your XDB WALLET, cannot be deleted or altered.


THIRD-PARTIES

Our Website may contain links or API connections to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party API providers or any Personal Data you disclose to these third parties. We encourage you to read their privacy policies before providing any Personal Data to them.


DO NOT TRACK SIGNALS

Some Internet browsers may be configured to send “Do Not Track” signals to the online sites that you visit. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com


YOUR RIGHTS AND CHOICES

Opt-out. You may contact us anytime to opt-out of: (i) automated decision-making and/or profiling; (ii) any new processing of your Personal Data that we may carry out beyond the original purpose; (iii) any consent you previously provided to us regarding the processing of your Personal Data; or (iv) the transfer of your Personal Data outside the EEA. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent. Please note that your use of the Software will most likely be ineffective upon opt-out.

Access. You may access the information we hold about you by contacting us via the “Contact Information” section below.
Amend. You may update or correct any inaccuracies, to the extent is technologically possible, in your Personal Data by contacting us via the “Contact Information” section below. Data recorded to the blockchain, as will be the case if you conduct any transactions using your XDB WALLET, cannot be deleted or altered.
Restrict or Object. You may request us to restrict the processing of your Personal Data, or object to our processing of your Personal Data via the “Contact Information” section below.
Move. Your Personal Data is portable – i.e. you to have the flexibility to move your data to other service providers as you wish.
Erasure. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data, if such erasure is technologically possible. Data recorded to the blockchain, as will be the case if you conduct any transactions using your XDB WALLET, cannot be deleted or altered.
Exercising Your Rights. If you wish to exercise any of these rights, please contact us via the “Contact Information” section below. In your request, please clearly describe: (i) what Personal Data is concerned and (ii) which of the above rights you would like to enforce. For your protection, we only process requests with respect to the Personal Data associated with the particular email address that you use to send us your request, and we may need to verify your identity before processing your request. We will try to comply with your request as soon as reasonably practicable and, in any event, within thirty (30) days of your request. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason for such retention.
Marketing Communications. We will not be sending any marketing communications using Personal Data collected through use of the Software.

COMPLAINTS

We are committed to resolve any complaints about our collection or use of your Personal Data. If you would like to make a complaint regarding this Privacy Policy or our practices in relation to your Personal Data, please contact us as set forth below. We will reply to your complaint as soon as we can and, in any event, within thirty (30) days. We hope to resolve any complaint brought to our attention; however, if you feel that your complaint has not been adequately resolved, you have the right to contact your local data protection supervisory authority.

CONTACT INFORMATION

We welcome your comments or questions regarding our privacy practices. If you have questions about your privacy related to the Website or Services or this Privacy Policy, you may contact us at: wallet@xdbchain.com

CHANGES TO THIS PRIVACY POLICY

We will post any adjustments to the Privacy Policy on this page (https://www.xdbchain.com/wallet/privacy-policy/), and the revised version will be effective when it is posted.

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