Ternoa Wallet is offered to you by Ternoa Blockchain which is owned and operated by Capsule Corp, a simplified joint stock company (Société par actions simplifiée - SAS) under French law registered with the Bayonne Trade and Companies Register under the number 882 163 413, with its registered address located at Centre International d'Affaires 24 Boulevard Marcel Dassault 64200 Biarritz, France.
Your privacy is important for us. As a starting point, we follow the basic privacy principles when you use our App. For example, we do not request any personally identifiable information from you unless we really need it for the provision of services to you. However, when you get in touch with us or report a bug or other error linked to the App, your contact information, such as your phone number, social media handle, or email address depending on how you contact us, may be gathered by us. We do not disclose your information to third parties unless it is necessary (i) to provide you with our services, (ii) to comply with the applicable laws, (iii) to improve the App, (iv) to protect our rights, or (v) to complete a business transfer.
What is Personal and Non-Personal Information?
Personal information is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the French Law No 78-17 of 6 January 1978 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’. Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name, address, phone number and other contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Non-personal information is any information about our users that has been aggregated or anonymized, as well as any other information that does not directly or indirectly identify any individual. We collect non-personal information about your use of our App as well as aggregated data on app usage.
Information We Collect
We make every effort to avoid collecting any personal information from Ternoa Wallet users. However, we ask you to provide your name when you first create an account on Ternoa Wallet and collect this information. We also gather public wallet addresses generated using Ternoa Wallet.
Furthermore, when you engage with us, we may collect personal Information from you, such as your contact information, your phone number, social network handle, or email address depending on how you reach out.
We may also collect usage data of our App which does not reveal any personally identifiable information about any user. This information will not be used to identify or track you but could be used to generate anonymous statistics and troubleshoot the performance of our App, where necessary.
How We Use the Information We Collect?
The limited information we collect is primarily used to provide you with Ternoa Wallet and to improve the App. We do not rent, trade, or sell your personal information unless we sell all or part of our business, or as otherwise specified below.
We may use your personal information in the following ways: (i) contact you as needed, (ii) respond to your comments, questions, or issues with Ternoa Wallet related to bugs or errors, and (iii) provide you with additional information.
We may process any non-personal information or aggregated data, which does not identify any person directly or indirectly, for the purpose of exhibiting the company's performance. Occasionally, we may decide to share or reveal this non-personal or aggregated data with service providers or other persons with whom we do business. This information sharing does not risk your privacy and we will take all precautionary measures to safeguard your privacy and data protection rights.
Legal Basis of Processing
The Data Protection Legislation requires us to have a valid and lawful legal basis for processing personal data. We rely on the following legal basis:
Consent: We may rely on your consent for us to use your personal information. We rely on this legal basis, for example, when you reach out with any comments or questions. We believe that you expect us to get back to you with responses and thus consent to the use of your information for this particular purpose (GDPR Article 6.1(a)).
Legal obligations: We may rely on the legal obligations to process your personal data. This could include a court order, or to exercise or defend legal claims (GDPR Article 6.1(c)).
Legitimate interests: We may also rely on our legitimate interests to process your personal data. Our legitimate interests would include to run, grow, develop and deliver our App, enhance the security of our network and information systems, and enhance, modify, or otherwise improve our services and communications (GDPR Article 6.1(f)).
Rights of Data Subjects
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the link in section “How to contact us” to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the link in section “How to contact us” to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
Further information about your rights can also be obtained from the French Data Protection Authority - CNIL (Commission Nationale de l'Informatique et des Libertés). If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the CNIL. We would, however, welcome the opportunity to resolve your concerns ourselves. That is why we encourage you to contact us first, using the link in section “How to contact us”.
Data Subject Access Requests
As mentioned above, we do not have much information about you. We collect only the minimum information which could identify you, directly or indirectly. We also do not track you under any conditions. However, if you still want to know whether we have your personal data, or, as applicable, what personal data we have about you, you can ask us for details of that personal data and for a copy of it. This is known as a “data subject access request”.
You can exercise your right to access your personal data by contacting us through any means. Nevertheless, we would welcome any data subject access requests in writing and sent to us via the link in the section “How to contact us”. There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within 15 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
Retention of Your Data
We will store your personal data within the European Economic Area (“EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the Data Protection Legislation, the GDPR, and/or to equivalent standards by law.
Although we try our best to avoid it, we may, however, also store some of your personal data in countries that are not part of the EEA. Should this be the case, we will absolutely take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the EEA and under the Data Protection Legislation as follows: a) we will only transfer your personal data to third countries whose levels of data protection are deemed ‘adequate’ by the European Commission (more information is available from the European Commission), b) otherwise, we will rely on standard contractual clauses approved by the EU Commission.
How Long Will the Data Be Kept for?
The data we collect will be processed and stored securely, for no longer than is necessary in light of the reasons for which it was first collected by us.
If you delete your Ternoa Wallet account, uninstall the App from your device, or request that your information be deleted, we still may retain some information that you have provided to us to comply with relevant laws.
Changes and Updates
How to Contact Us
If you have any questions we would be happy to answer them. Do not hesitate to contact us for any inquiries you might have via this link.