1. Agreement to Terms

1.1. Agreement to Terms

1.2. These Terms are a binding agreement between INWAY AG, a company incorporated under the laws of the Principality of Liechtenstein, with a registered office at Vaduz, (the “Company”, “us,” “our”, or “we”) and you, the person who uses the Services and the App (the “Client”, “you”, “your”, or “yourself”).

1.3. By using the App, you expressly acknowledge that: (i) you have read and understood these Terms; (ii) you agree to comply with the Terms governing your use of the App and the services offered through the App (the “Services”).

1.4. It is your own responsibility to read the Terms carefully before you start to use the App or the Services. In addition to the Terms, you should also read our Privacy Policy (the “Privacy Policy”) carefully, which sets out how we collect and use your personal data and information.

1.5. We may suspend, modify, remove or add to the Services at any time.

1.6. The Company has no obligation to check whether users are using the Services and/or the App in accordance with the Terms, as updated from time to time.

2. Changes to Terms

2.1. We reserve the right to update or modify these Terms at any time at our sole discretion. If we do so, we will let you know by either posting the revised Terms on our website, on our App, or through other methods of communication which we deem reasonable. Such revised Terms as posted will take effect immediately on the date of publication on the website unless otherwise indicated. You should regularly check our website to inform yourself of any such changes and decide whether or not to accept the revised version of these Terms.

2.2. If you continue to use the App following any update or modification of the Terms, you shall be deemed to have accepted the revised Terms. If you do not agree to the Terms or any update or modification to the Terms, you must cease to access or use our App and Services.

2.3. We may change or discontinue all or any part of the provided services through the App at any time, without prior notice, at our sole discretion and without any liability.

3. Changes to software/App

3.1. The software and the App develop over time, and it is required to install updates to the Apps in order to keep using the App software having access to the latest features, services, and security updates.

3.2. You waive all claims and agree not to hold liable INWAY AG for any damages occurred due to third-party software that you have been using but was not partially or fully compatible with the App.

3.3. We may update IW software/the App at any time, without provision of notice.

4. Eligibility

4.1. If you are using the App as a natural person, you are of the age of majority in your jurisdiction of residence, or older, and are not barred from using the App and the Services under all applicable laws.

4.2. If you are using the App on behalf of a legal entity, you represent and warrant that you have the legal authority to bind that entity to these Terms.

4.3. For the avoidance of doubt, you may not use IW Services/the App if you are located in, or a citizen or resident of any state, country, territory, or other jurisdiction where your use of IW Services and the App would be illegal or otherwise violate any applicable laws.

4.4. It is your obligation and responsibility to make sure that these Terms are in compliance with all laws, rules, and regulations that apply to you.

4.5. By using our Services, you represent and warrant that you meet all eligibility requirements that we outline in these Terms. We may still refuse to let certain people access or use the App and IW Services, however, and we reserve the right to change our eligibility criteria at any time, without any liability and provision of notice.

5. Description of scope of services provided through the IW and the App

5.1. IW allows you to:

5.1.1. generate wallet addresses and associated private keys that you may use to send and receive Digital Assets;

5.1.2. import associated private keys with a recovery phrase on other crypto wallets;

5.1.3. browse and access third-party application(s) and third-party service(s);

5.1.4. digital assets service(s) through third-party functionality made available by third-party service provider(s);

5.1.5. view Digital Asset price information made available by third-party service provider(s); and

5.1.6. broadcast Digital Asset transaction data to various blockchains supported by IW without requiring you to download or install the associated blockchain-based software to your local device.

6. Security of your Private Information

6.1. We do not store your passwords, wallet address, private keys, and recovery phrase (“Private Information”).

6.2. It is your responsibility to secure your Private Information. Losing Private Information could result in a loss of access to Digital Assets. INWAY AG is not liable for any loss or theft of such data due to any reasons.

6.3. You acknowledge your full responsibility to secure and retain your recovery phrase. In case of losing it, it may result in the inability to access your Digital Assets. INWAY AG is not liable for the security of your recovery phrase.

7. Digital Asset Transactions

7.1. IW is a solution that gives access to your wallets on blockchains that store your respective Digital Assets and allows you to send your Digital Assets. IW supports Digital Assets via its software/the App provided by INWAY AG, and the latter may amend the list of supported Digital Assets at any time at its sole discretion without any liability.

7.2. INWAY AG does not provide any virtual asset services or other services subject to a notification, registration, or license with the Financial Market Authority Liechtenstein (FMA) pursuant to Article 5 of the Liechtenstein Act on Financial Market Supervision (FMAG). INWAY AG only provides a technological software platform for non-custodial wallets.

7.3. Any transaction created is confirmed and recorded in the respective blockchain. Transactions on any blockchain are final and will not be settled, brokered, or solicited by INWAY AG due to the decentralized nature of the blockchain. Likewise, the transactions cannot be undone, cancelled, withdrawn, or refunded. There may be transaction fees (e.g., mining fees) associated with your Digital Asset transactions.

7.4. INWAY AG has no control over the blockchains and does not guarantee that initiated transactions of Digital Assets shall be processed by the respective blockchain.

7.5. INWAY AG is not responsible for any loss incurred by you caused in whole or in part, directly or indirectly, by a network disruption within a respective blockchain or incorrectly initiated by you transaction of Digital Assets.

8. Blockchains

8.1. The Company is not the creator of and does not have any control over any of the Digital Assets that the App allows you to use. Your balance and actual transaction history are supported by each Digital Asset block explorers.

9. Third Party Services

9.1. You acknowledge and agree that all cryptocurrency services and information provided through the App are executed by third-party service providers, and that IW does not itself provide data on prices or Digital Assets.

9.2. Third-Party Service providers have their own terms and conditions, policies, and INWAY AG does not control the terms, policies, or performance of any third party, and is not responsible for any performance or failure to perform of any third-party software, site, or services, including pricing information, rates, processing of transactions, and similar activities.

9.3. INWAY AG does not provide customer support for transactions performed on third-party API provider’s software, site, or services. When you leave the IW software/the App and access the third-party’s software, their terms of service govern.

9.4. INWAY AG retains the exclusive right to add to, modify, or cancel the availability of any third-party service.

10. Third-party Applications, Third-party Service(s) & Cross-Chain Swaps

10.1. If you access or use third-party applications or third-party service(s), including, without limitation, third-party application functionality embedded within the Services, you acknowledge and agree that:

10.1.1. You expressly and without exception meet the requisite eligibility criteria as set out in section 4 of these Terms.

10.1.2. IW is not responsible for your access or use of third-party applications or third-party service(s), and shall have no liability whatsoever in connection with your use of third-party applications or third-party service(s), including, without limitation, any transactions you dispute.

10.1.3. The limits of amounts that you may use via third-party service(s) per day shall be subject to any requirements of the third-party-developed Smart Contracts.

10.1.4. Blockchain operations are irrevocable, meaning when you conduct any transactions via third-party applications or third-party service(s), you shall be solely responsible for the consequences of any issues associated with such transactions, including, without limitation, your transfer to an incorrect address or problems associated with the node servers selected by you.

10.1.5. When you use third-party applications or third-party service(s), third-party developed Smart Contracts may charge you handling fees and/or service fees, and any information displayed on the App relating to such fees is for your reference only as the App cannot and does not guarantee its accuracy, applicability, reliability, integrity, or appropriateness, nor shall IW be liable for any loss or damage that may be caused directly or indirectly by your use of these contents.

10.1.6. IW does not charge transaction or handling fees; however, standard blockchain transaction fees may apply, which vary by network.

11. Intellectual Property

11.1. By agreeing to these Terms, you are granted, for your personal or internal business use, a non-exclusive, non-transferable, non-sublicensable license to use IW/the App.

11.2. You are not permitted to:

11.2.1. Copy, redistribute, publish, reverse engineer, decompile, disassemble, modify, translate, or make any attempt to access the source code to create derivative works of the source code, or otherwise of IW;

11.2.2. Rent, lease, distribute, sell, sublicense, or transfer IW;

11.2.3. Make the App and IW Services available to any third party through a computer network or otherwise;

11.2.4. Incorporate IW into a product or service you provide to a third party without our prior written consent;

11.2.5. Make the IW Software available to any third party through a computer network or otherwise use IW for competitive analysis, as part of any other software or project of any kind, or to build competitive products.

12. Risk Factors

12.1. IW specifically disclaims and shall have no liability to you for the following risks:

12.1.1. Operating system failures (mobile); and,

12.1.2. Interactions between your hardware, software, and the App; and,

12.1.3. Malware, viruses, or other malicious software on your device that is able to take control of or interfere with the App; and,

12.1.4. Communication delays between the IW and a node or relay service for a Digital Asset (and vice versa); and,

12.1.5. Failure to achieve a certain market value/price for a Digital Asset, whether through a third-party service or any other kind of transaction; and, theft of Digital Assets.

12.1.6. Losing your device on which you use IW;

12.1.7. Using IW you did not setup password;

12.1.8. Losing your backup without password.

13. Disclaimer

13.1. Inway AG/IW does not provide any digital asset services or any financial services, nor does it provide any advisory, mediation, brokerage, or agent services. Digital asset services are provided to IW customers by third-party service providers, whose activities and services are beyond our control. We urge all our customers to familiarize themselves with the terms and conditions of third-party digital asset service providers before engaging in a business relationship. We also note that IW is not a creator and does not have any control over any of the virtual assets that our App allows IW customers to use. Balances and actual transaction history of our customers are supported by separate blockchain explorers of each digital asset. We do not collect or store any private keys, backup phrases, or passwords. Furthermore, IW does not hold, collect, or transfer any assets from or to its customers’ wallets in any form.

14. No Warranty

14.1. IW Services are provided to you at no cost, “as-is” and without any warranty whatsoever, to the maximum extent permissible by law. Without limiting the generality of the foregoing, the Company does not warrant that IW is fit for your purpose, even if you have previously provided notice.

15. Limitation of Liability

15.1. IN NO EVENT WILL IW BE LIABLE TO YOU FOR: ANY LOST PROFITS, REVENUE OR DATA, INDIRECT, INCIDENTAL, SPECIAL, OR CONSEQUENTIAL DAMAGES, OR DAMAGES OR COSTS DUE TO LOSS OF PRODUCTION OR USE, BUSINESS INTERRUPTION, OR PROCUREMENT OF SUBSTITUTE GOODS OR SERVICES ARISING OUT OF OR IN CONNECTION WITH THE SERVICES, WHETHER OR NOT IW HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES, AND REGARDLESS OF THE THEORY OF LIABILITY ASSERTED, WHICH HAVE RESULTED FROM: (I) YOUR USE OF, OR CONDUCT IN CONNECTION WITH, OUR SERVICES; (II) ANY UNAUTHORIZED USE OF YOUR WALLET ADDRESS AND/OR PRIVATE KEY DUE TO YOUR FAILURE TO MAINTAIN THE CONFIDENTIALITY OF YOUR WALLET; (III) ANY INTERRUPTION OR CESSATION OF TRANSMISSION TO OR FROM THE SERVICES; OR (IV) ANY BUGS, VIRUSES, TROJAN HORSES, OR THE LIKE THAT ARE FOUND IN THE IW SOFTWARE OR THAT MAY BE TRANSMITTED TO OR THROUGH OUR SERVICES BY ANY THIRD PARTY (REGARDLESS OF THE SOURCE OF ORIGINATION).

16. Force Majeure

16.1. The Company will not be liable for any delay or failure to perform resulting from causes outside its reasonable control, including, but not limited to, acts of God, war, terrorism, riots, epidemics, embargoes, acts of civil or military authorities, fire, floods, accidents, strikes or shortages of transportation facilities, fuel, energy, labour or materials.

17. Indemnity

17.1. You agree to defend, indemnify and hold harmless the Company and its affiliates, and any of their respective employees, officers, directors, agents, joint ventures, and consultants, and of any registered user, from any claims, demands, liabilities, damages, or costs (including attorneys’ fees, fines, or penalties) suffered by any of them that may arise in connection with:

• Any breach by you of the Terms;
• Your use of the Company Services or use by a third party using your user identification and/or account, whether or not with your authorization;
• Any violation by you of any law, rule, regulation, and/or directive; and/or
• The rights of any third party.

18. Non-Waiver

18.1. No action or inaction on the part of the Company shall be considered a waiver of any right or obligation by the Company.

19. Assignment

19.1. The Company may assign its rights without restriction, without prior notice to you. In the event of a merger or acquisition between the Company and a third party, the Company reserves the right to transfer or assign the information you provided to the Company as part of such merger, acquisition, sale, or other change of control.

20. Severability

20.1. If any provision of the Terms shall be declared by any court of competent jurisdiction to be illegal, void, or unenforceable, all other provisions of these Terms shall not be affected and shall remain in full force and effect. In such cases, the part deemed invalid or unenforceable shall be construed in a manner consistent with applicable law to reflect, as closely as possible, the original intent of the parties.

21. English Language

21.1. Any translation of the Terms, if provided, is provided for your convenience alone. The meanings of terms, conditions, and representations herein are subject to definitions and interpretations in the English language. Any translation provided may not accurately represent the information in the original English.

22. Governing Law

22.1. The Terms and the relationship between the parties shall be governed by, and interpreted in accordance with, the laws of Liechtenstein under exclusion of the law of collision as well as the CISG and you irrevocably submit, for the benefit of the Company, to the exclusive jurisdiction of the courts of Liechtenstein to settle any disputes (including claims for set off and counterclaims) which may arise in connection with the creation, validity, effect, interpretation or performance of, or the legal relationships established by, the Terms or otherwise arising in connection with the Terms, subject to any mandatory statutory provisions to the contrary.

23. Dispute Resolution

23.1. Any dispute arising out of or relating to these Terms shall be resolved on an individual basis, and not as a class, consolidated, or representative action. You waive any right to participate in a class action lawsuit or seek relief on a class-wide or representative basis.

24. Discontinuance of Services

24.1. We may, in our sole discretion and without cost to you, with or without prior notice, and at any time, modify or discontinue, temporarily or permanently, any portion of our Services. You are responsible for storing your backup phrase outside of the App. Saving your backup phrase and private keys pairs associated with your IW wallet will allow you to access the blockchain and your funds at any place and time. The Company shall not be held responsible or liable for any loss of Digital Assets in the event that we discontinue or deprecate the Services.

25. No Third-Party Beneficiaries

25.1. You agree that, except as otherwise expressly provided in these Terms, there shall be no third-party beneficiaries to the Terms.

26. Notices, Questions, Complaints, Claims

26.1. If you have any questions, complaints or claims with respect to the App or the Services, please contact us at info@ironwallet.io. We will do our best to address your concerns.

27. Entire Agreement

27.1. These Terms constitutes the final, exclusive, and complete understanding and agreement between you and us and supersedes all prior understandings and agreements between you and us.

Last Updated: 23.06.2023

Present privacy policy (hereinafter “Policy”) describes how INWAY AG (hereinafter “Company”, “we”, “our”, or “us”) collects, uses, shares, and stores personal data of users of our website/-es: ironwallet.io (hereinafter “Sites”).

This Policy applies to the Sites, applications, products and services (collectively, “Services”) on or in which it is posted, linked or referenced.

By using the Services, you accept the terms of this Policy and our Terms of Use, and consent to our collection, use, disclosure, and retention of your information as described in this Policy. If you have not done so already, please also review our Terms of Use.

This Privacy Policy explains how information about users is collected, used, and disclosed by us and to set out the basis on which we will process personal data when providing our services.

IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY OR OUR TERMS OF USE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

Purpose of this Privacy Notice

We process personal data in an appropriate and lawful manner, in accordance with the laws of Liechtenstein which shall be applicable to this Policy, unless this conflicts with mandatory consumer protection provisions of any other EU/EEA member state and to the exclusion of collision laws; in particular we process personal data in accordance with the Liechtenstein Data Protection Act (the “Act”) as amended, and the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”), as well as subsidiary legislation and regulations promulgated thereunder. For the avoidance of doubt, it is noted that Liechtenstein has fully implemented the GDPR.

The Services are not intended for minors (i.e., persons under age of majority in respective jurisdiction of residence) and we do not knowingly collect personal data relating to minors.

It is important that this Policy is read together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about in order to become fully aware of how and why we are using personal data. This Policy supplements the other notices and is not intended to override them, unless otherwise stated.

Data controller

INWAY AG as defined above is the controller and responsible for user’s personal data.

Concerning any questions or requests, including any requests to exercise legal rights as a data subject, please use the details set out below:

Full name of legal entity: INWAY Aktiengesellschaft

Email address: info@ironwallet.io

Postal address: c/o Codex Treuhand Aktiengesellschaft, Landstrasse 1, 9495 Triesen.

Third-Party Links

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about customers. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies.

We encourage to read the privacy policy of every website visited.

What and How Do We Collect Data?

With respect to data subjects, “data”, “information”, “personal information”, “personal data”, as used in this Policy, is equivalent to “personal data” as defines in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter “GDPR”).

We collect information about you in the following way:

Information we collect from you may include:

• Identity information, such as your first name, last name in case of correspondence;
• Contact information, such as your email address and telephone number;
• Feedback and correspondence, such as information you provide in your responses to surveys, when you participate in market research activities, report a problem with Service, receive customer support, or otherwise correspond with us;
• Transaction information, such as details about status and amount of transaction;
• Marketing information, such as your preferences for receiving marketing communications and details about how you engage with them;
• Technical information, such as your crypto wallet address and network information regarding transactions.

Information That is Collected Automatically

We may automatically record certain information about how you use our Sites (we refer to this information as “Log Data“).

Log Data may include information such as a user’s Internet Protocol (IP) address, device and browser type, operating system, the pages or features of our Sites to which a user browsed and the time spent on those pages or features, the frequency with which the Sites are used by a user, search terms, the links on our Sites that a user clicked on or used, and other statistics.

We use this information to administer the Service and we analyze (and may engage third parties to analyze) this information to improve and enhance the Service by expanding its features and functionality and tailoring it to our users’ needs and preferences.

We may use cookies, local storage, or similar technologies to analyze trends, administer the Sites, track users’ movements around the Sites, and to gather demographic information about our user base as a whole. Users can control the use of cookies and local storage at the individual browser level.

We also may use Google Analytics to help us offer you an optimized user experience. You can find more information about Google Analytics’ use of your personal data here. Please note that Iron Wallet does not use Google Analytics in its wallet.

We also may use Apple Store by Apple Inc. to help us offer you an optimized user experience. You can find more information about Apple Store services in use of your personal data here. Please note that Iron Wallet does not use Apple Store services in its wallet

We also may use Apple Store by Apple Inc. to help us offer you an optimized user experience. You can find more information about Apple Store services in use of your personal data here. Please note that [IronWallet] does not use Apple Store services in its wallet.

Sensitive Data

Some of the information you provide us may constitute sensitive data as defined in the GDPR (also referred to as special categories of personal data), including identification of your race or ethnicity on government-issued identification documents. Should we receive sensitive personal data, we will only process that data where there is a legitimate reason and purpose as set down in article 9 para. 2 of the GDPR to do so and, in all circumstances, in accordance with our obligations at law and under the appropriate safeguards.

Information We Will Never Collect

WE WILL NEVER ASK YOU TO SHARE YOUR PRIVATE KEYS OR WALLET RECOVERY (SEED) PHRASE. NEVER TRUST ANYONE OR ANY SITE THAT ASKS YOU TO ENTER YOUR PRIVATE KEYS OR WALLET RECOVERY (SEED) PHRASE.

How We Will Use Your Data?

We only use your personal data as permitted by law. We are required to inform you of the legal basis of our processing of your personal information, which are described in the table below. We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. If you have questions about the legal basis under which we process your personal data, contact us at info@ironwallet.io. Most commonly, we will use personal data in the following circumstances:

• Where we need to perform our contractual obligations and duties we are about to enter into or have entered into with users in respect of customer relationships with us.
• Where it is necessary for our legitimate interests (or those of a third party) and user interests as well as fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

Opting Out

Users can ask us to stop sending such advertising and marketing communications at any time by:

• Following the opt-out links on any marketing message sent;
• Contacting us at any time

Where users opt out of receiving such communications, this will not apply to personal data processed or provided to us as a result of customers’ entry into a customer relationship with us and our Services for the other respective purposes.

Disclosure of Personal Data

We may have to share personal data with the parties set out below for the purposes set out in the table above:

• External third parties
• Suppliers and external agencies that we engage to process information on our and/or customers’ behalf, including to provide information and/or materials that have been requested
• Our subsidiaries, associates, and agents where necessary to facilitate customer relationship with us
• The Liechtenstein Tax Administration (Steuerverwaltung), the Office for Data Protection, regulators, law enforcement agencies, and other authorities who require reporting of processing activities or may request information from us, in terms of applicable law and in certain circumstances
• Professional advisers such as lawyers, bankers, professional indemnity insurers, brokers, and auditors
• Other organizations where the exchange of information is for the purpose of fraud protection or credit risk reduction
• Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). 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 personal data in the same way and for the same purposes as set out in this Policy

We require all third parties to respect the security of personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties access and process personal data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.

We may also disclose customers’ data:

1. If we are under a duty to disclose or share personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority
2. If we believe customers’ actions are inconsistent with our user agreements or policies, or to protect the rights, property, and safety of us or others
3. In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company
4. If we have consent or at a customer’s direction

We may also share aggregated or anonymized information, which cannot reasonably be used to identify you.

How We Will Store and Secure Your Data

We will only retain personal data for as long as necessary to fulfill the purposes we collected it for (i.e. the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax, and other requirements or obligations to which we may be subject and/or to the extent that we may also need to retain personal data to be able to assert, exercise, or defend possible future legal claims against or otherwise involving customers.

We employ industry standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.

What Are Your Data Protection Rights?

• The Right to Opt-out. Stop sending you direct marketing communications which you have previously consented to receive. We may continue to send you Service-related and other non-marketing communications.
• The Right to Access. Provide you with information about our processing of your personal data and give you access to your personal information.
• The Right to Rectification. Update or correct inaccuracies in your personal data.
• The Right to Erasure. Erase your personal data under certain conditions.
• The Right to Restrict Processing. Restrict the processing of your personal data under certain conditions.
• The Right to Object to Processing. Object to our reliance on our legitimate interests as the basis of our processing of your personal data that impacts your rights.
• Right to Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Right to withdraw consent.

You can submit these requests by email info@ironwallet.io. Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override a data subject request, the user will be informed of this by us along with the reasons for our decision.

We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.

Users normally don’t have to pay a fee to exercise their rights as a data subject. However, we may charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with requests in the above circumstances.

We will need to request specific information from a user to help us confirm the user’s identity and ensure the user’s right to access the personal data (or to exercise any of the other rights as a data subject). This includes name, address, date of birth, and (in case of a passport/identity card being requested) its validity period.

We try to respond to all legitimate requests within the period of one month from receipt of the request. Occasionally, it may take us longer than a month if a request is particularly complex or a number of requests have been made. In this case, we will give notification within four weeks and keep customers updated on the handling of their request.

What Are Cookies?

A cookie (hereinafter “Cookie”) is a small text file that is placed on your hard drive by a web page server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Some of the cookies will only be used if you use certain features or select certain preferences, and some cookies will always be used.

Web beacons, tags, and scripts may be used in the Sites or in emails to help us deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our service/analytics providers on an individual and aggregated basis.

We may link the information collected by Cookies with other information we collect from you pursuant to this Policy and use the combined information as set forth herein. Similarly, the third parties who serve cookies on our Sites may link your name or email address to other information they collect, which may include past purchases made offline or online, or your online usage information.

If you are located in the European Economic Area, you have certain rights that are described above under the header “WHAT ARE YOUR DATA PROTECTION RIGHTS?”

What Types of Cookies Do We Use?

Necessary Cookies: Some Cookies are necessary for certain uses of the Sites, and without such Cookies, we would not be able to provide many services that you need to properly use the Sites. These Cookies, for example, allow us to operate our Sites so you may access it as you have requested and let us recognize that you have created an account and have logged into that account to access content on our Sites. They also include Cookies that enable us to remember your previous actions within the same browsing session and secure our Sites.

Functional Cookies: We also use functional Cookies and Cookies from third parties for analysis and marketing purposes. Functional Cookies enable certain parts of the Sites to work properly and your user preferences to remain known.

Analysis Cookies: Analysis Cookies, among other things, collect information on how visitors use our Sites, the content and products that users view most frequently, and the effectiveness of our third-party advertising.

Advertising Cookies: Advertising Cookies assist in delivering ads to relevant audiences and having our ads appear at the top of search results. Cookies are either “session” Cookies which are deleted when you end your browser session, or “persistent,” which remain until their deletion by you (discussed below) or the party who served the cookie.

How to Manage Cookies?

You can always set your browser not to accept cookies or even remove cookies from your browser. However, in a few cases, some of the Sites’ features may not function properly or even may become inaccessible as a result.

To learn more about how to control cookie settings through your browser:

• For Firefox, click here to learn more about the “Private Browsing” setting and managing cookie settings.
• For Chrome, click here to learn more about “Incognito” settings and managing cookie settings.
• For Internet Explorer, click here to learn more about “InPrivate” settings and managing cookie settings.
• For Safari, click here to learn more about “Private Browsing” settings and managing cookie settings.

For more information about cookies, please visit: https://www.aboutcookies.org/.

Third-party advertising networks, like Google and others, permit users to opt out of or customize preferences associated with your internet browsing. To learn more about this feature from Google, click here.

Flash Cookies, which from time to time may be used by Sites, are not controlled by your browser and relevant settings. In order to manage Flash Cookies settings, click here.

Privacy Policies of Other Websites

Our Sites may have links to other websites which you can follow, due to that, our Policy applies only to our Sites and other websites have their own privacy policy which you should read.

Changes to Our Privacy Policy

We keep our Policy under regular review; that is why we may amend the Policy at any time. We encourage you to periodically review this page for the latest information on our privacy practices. If we make any changes, we will change the “Last Updated” date above.

Any modifications/amendments to the Policy will be effective upon our posting of the new terms and/or upon implementation of the changes to the Sites (or as otherwise indicated at the time of posting). In all cases, your continued use of the Sites or Services after the posting of any modified Policy indicates your acceptance of the terms of the modified Policy.

How to Contact Us

If you have any questions about the Policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us at: info@ironwallet.io.

How to Contact the Appropriate Authority

If you would like to submit a complaint about our use of your personal data or response to your requests regarding your personal data, you may contact us at info@ironwallet.io or submit a complaint to the data protection regulator in your jurisdiction.

You can find your data protection regulator here.