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Fearless Wallet

Effective Date: 2021-02-02

PRIVACY POLICY

The Fearless Wallet app is built as an app by SORAMITSU, a company incorporated under the Japanese law, with a head office registered at Jingumae Tower Building, Jingumae 1-5-8, Shibuya-ku, Tokyo 1500001, Japan. For users in the European Economic Area (EEA), SORAMITSU is represented by its Switzerland entity, Soramitsu Helvetia AG, a company incorporated under the Switzerland law, with an office registered at Dammstrasse 16, 6300 Zug, Swizerland.

This service is provided by SORAMITSU at no cost and is intended for use as is. For the purposes of this Privacy Policy, 'we', 'us' and 'our' refers to SORAMITSU, and 'you' refers to you, the user of the Services.

This page is used to inform visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our Service.

If you choose to use our Service, then you agree to the collection and use of information in relation to this policy. We will not use or share your information with anyone except as described in this Privacy Policy.

The terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, which is accessible at Fearless Wallet unless otherwise defined in this Privacy Policy.

Information Collection and Use

While using our Fearless Wallet Service, we do not require you to provide us any personally identifiable information.

You can, however, opt into various additional Services, such as the Fearless Wallet mailing list and the SORAmbassadors program, which may require Personal Information. When offering such Services, we will ask for your consent to collect and process the Personal Information required. These data will be used solely for the purpose of managing the additional services offered. While operating such services, SORAMITSU may also collect and process Personal Information that is strictly necessary for the pursuit of legitimate interests, for instance fraud prevention and direct marketing (see GDPR Recital 47). The data collected is processed by SORAMITSU Helvetia AG on servers located in Switzerland. None of the data collected will be sold or otherwise transferred to third parties.

Please note that SORAMITSU will never ask you to reveal sensitive Personal Information, for instance data on your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sex life, sexual orientation, or criminal convictions. SORAMITSU will not collect genetic, health, or biometric data. Some SORAMITSU Services provide the option of utilising your own electronic devices' biometric identification functions; however, biometric data collected by your device will be processed locally and will not be collected nor processed by SORAMITSU.

Retention

Unless stated otherwise in this Privacy Policy, the Personal Information that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services. As a Swiss entity, Soramitsu Helvetia AG provides privacy protection adequate to the standard set by the General Data Protection Regulation (EU) 2016/679 (GDPR). Your rights under the GDPR include the following:

Exercising these rights will not subject you to any penalties, though it may affect your ability to use SORAMITSU Services. Note that exercising these rights may not affect the lawfulness of data processing based on consent before its withdrawal.

SORAMITSU adheres to the principles of data minimisation and data protection by design and default. This means that unnecessary Personal Information is not collected, and data protection is regarded as a core functionality of our Services. More information about data protection at SORAMITSU is available upon request.

Log Data

We want to inform you that whenever you use our Service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol ("IP") address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics. Log Data will be processed securely in compliance with all relevant regulations, and will not be sold or otherwise transferred to third parties without your explicit consent.

Cookies

Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.

This Service does not use these "cookies" explicitly. However, the app may use third party code and libraries that use "cookies" to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this Service.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Compliance with Law

Fearless Wallet may be compelled to surrender your personal information to legal authorities without your express consent if presented with a court subpoena or similar legal or administrative order, or as required or permitted by the laws, rules, and regulations of any nation, state, or other applicable jurisdiction.

Links to Other Sites

This Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Children's Privacy

These Services do not address anyone under the age of 18. We do not knowingly collect personally identifiable information from people under 18. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. But when we do, we'll let you know one way or another. Sometimes, we'll let you know by revising the date at the top of the Privacy Policy that's available on our website and mobile application. Other times, we may provide you with an in-app notification.

Contact Us

If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at security@soramitsu.co.jp.


The Data Controller, Data Processor, and Data Protection Officer Are:
Soramitsu Helvetia AG (“SORAMITSU”)
Soramitsu Helvetia AG c/o Diego Compostella
Oberneuhofstrasse 5, 6341 Baar, Switzerland
Email: dataprotection@soramitsu.co.jp

The Competent Supervisory Authority Is:
Office of the Federal Data Protection and Information Commissioner (FDPIC)
Feldeggweg 1
CH - 3003 Berne, Switzerland
Telephone: +41 (0)58 462 43 95 (Mon.-Fri., 10-12 am)
Telefax: +41 (0)58 465 99 96


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