Unhosted Wallet Privacy Notice
Last Updated: May 2024
This Privacy Policy (“Policy”) describes and governs the information collection, use, and sharing practices of Anchorage Innovations, LLC (collectively, “Provider,” “we,” “us,” or “our”) solely with respect to your use of an unhosted Digital Asset software wallet that allows users independently to store and control their own Digital Assets (the “Wallet”). For clarity, the legal relationship between you and Provider is governed by the Unhosted Wallet Terms and Conditions between those two parties, not by this Policy. This Policy addresses our collection of information about you through the Wallet.
Before you use or submit any information through or in connection with the Wallet, please carefully review this Policy. By using the Wallet, you consent to the collection, use, and disclosure of your information as further outlined in this Policy. If we make material changes to this Policy, we will provide you with notice as required by law. Your continued use of the Wallet will signify acceptance of the terms of the updated Policy. Your use of the Wallet is also subject to our User Terms of Use. Undefined capitalized terms used herein shall have the definitions set forth in the User Terms of Use.
INFORMATION WE COLLECT
We collect information in multiple ways, including when you provide information directly to us, and when we passively collect information from you, as permitted by Apple.
We may collect information from you in a variety of ways, such as when you:
- Onboard to use the Wallet;
- Initiate or confirm a Transaction;
- Communicate with us;
- Request customer support or technical assistance through the Wallet; or
- Use any features that require your information to function.
Information You Provide Directly To Us
In addition to the information you provided for initial onboarding, which we use to conduct required diligence on you, we collect other information you directly provide to us in order to provide our services, such as information about transactions you request.
Information Collected Passively
We will also access, use, and/or store other information collected through your phone, including historical data:
- Precise and general location data, including altitude;
- Telemetry or usage data, such as button presses and controls used; and
- Biometric data, including voiceprints.
HOW WE USE YOUR INFORMATION
We may use the information we collect from and about you for the following purposes:
- For the purposes for which you provided it;
- To process and confirm Transactions;
- To recognize and authenticate you;
- To initiate or to provide features and services through the Wallet;
- For internal research and reporting;
- To improve the content and features of the Wallet or develop new services;
- To monitor and analyze trends, usage and activities in connection with the Wallet and services, and for statistical purposes;
- To detect, investigate, and prevent fraud and other illegal activities;
- To enforce legal terms;
- To block disruptive use;
- To comply with any procedures, laws, and regulations which apply to us;
- To establish, exercise, and defend our legal rights; and
- To administer and troubleshoot the Wallet; and
- To market to you and provide you with information about other products and services from us and/or our affiliates.
Please note that we may combine information that we collect from you and about you (including automatically-collected information) with information we obtain about you from our affiliates and/or non-affiliated third parties, and use such combined information in accordance with this Policy.
We may aggregate and/or de-identify information collected through the Wallet. We may use and disclose de-identified and/or aggregated data for any purpose previously stated.
WHEN WE DISCLOSE USER INFORMATION
We may disclose and/or share your information to or with any non-affiliated third parties under the following circumstances:
- Affiliates. We may disclose your information to our affiliates.
- Consent. We may disclose your information to any third parties with your consent to do so.
- Service Providers. We may provide access to or share your information with select third parties who perform services on our behalf, including without limitation data storage, analysis and processing, screening and diligence, and legal services.
- Protection of Provider and Others. You acknowledge, consent, and agree that Provider may access, preserve, and disclose your information if required to do so by law or in a good faith belief that such access, preservation, or disclosure is permitted by Provider’s Privacy Policy or reasonably necessary or appropriate for any of the following reasons: (1) to comply with legal process; (2) to enforce this Privacy Policy, our Terms of Service, or other contracts with you, including investigation of potential violations thereof; (3) to enforce our Unhosted Wallet Terms and Conditions ; (4) to respond to your requests for customer service; and/or (5) to protect the rights, property, or personal safety of Provider, its agents and affiliates, its users, and the public.
- Business Transfers. As we continue to develop our business, we may buy, merge or partner with other companies. In such transactions, (including in contemplation of such transactions, e.g., due diligence) user information may be among the transferred assets. If a portion or all of Provider’s assets are sold or transferred to a third-party, end user information would likely be one of the transferred business assets.
UPDATING YOUR INFORMATION
If you have questions regarding your information, you may contact us at privacy@anchorage.com. Please be advised that many of the data elements may be persistently collected by Provider, as persistent collection enables us to provide our features and services. TO STOP THE COLLECTION OF DATA FROM YOUR MOBILE DEVICE, YOU MUST DELETE THE WALLET. Closing the Wallet will not stop the collection of such data.
DATA RETENTION
We will retain your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We will not retain information that qualifies as personal data under applicable data privacy laws beyond what is necessary.
SECURITY
We have implemented administrative, technical, and physical security measures to protect against the loss, misuse and/or alteration of your information. These safeguards vary based on the sensitivity of the information that we collect and store. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information since despite our efforts, no Internet and/or other electronic transmissions can be completely secure. If you believe that your account has been compromised, you must contact us immediately.
CHILDREN'S PRIVACY
The Wallet is not intended for children or minors under the age of eighteen years. We do not knowingly collect personal information from, or market online to, children under 13. If we become aware that a child under 13 (or a higher age threshold where applicable) has provided us with personal information as defined by the Children’s Online Privacy Protection Act, we will take steps to comply with any applicable legal requirement to remove such information.
FOR CALIFORNIA RESIDENTS click here.
FOR CITIZENS OR RESIDENTS OF THE UNITED KINGDOM OR THE EUROPEAN UNION click here.
FOR CITIZENS OR RESIDENTS OF SINGAPORE click here.
CHANGES TO THIS POLICY
We reserve the right to change this Policy at any time to reflect changes in the law, our data collection and use practices, the features of the Wallet, or advances in technology. Please check this page periodically for changes. Your continued use of the Service following the posting of changes to this Policy will mean you accept those changes.
QUESTIONS ABOUT THIS POLICY
If you have any questions about our Policy, you can contact us by emailing us at privacy@anchorage.com.
