This Privacy Notice describes the procedures of 3Commas Technologies OÜ, registry code 14125515, address Laeva tn 2, Kesklinna linnaosa, Tallinn, Harju maakond, 10111 (“we,” “our,” or “us”) collection, use, and disclosure of your information in the product and related mobile application we offer (the “Services” or “Wallet”).
Your right to privacy and the protection of your personal data is important to us. The following sections provide further details as to how we process your personal information through Wallet. We don’t share your information with third parties except to deliver you our Services and products, comply with the law, make Wallet better, protect our rights, or effectuate a business transfer.
WHAT PERSONAL INFORMATION DO WE COLLECT FROM OUR USERS?
We do our best to minimize the amount of personal information that we collect from Wallet users.
When you use our Services, we process public wallet addresses that you generate through Wallet and your personal identifiers under the performance of contract legal basis. Under the same basis we also keep commercial information records of any contractual agreements between yourself and Wallet.
We also process system and application access data and internet and electronic network activity information, the internet protocol (IP) address used to connect your computer or mobile device to the Internet, the occurrences of technical errors, your interactions with service features and content and your setting preferences to be able to provide the service and troubleshooting under the performance of contract legal basis.
Under the legitimate interest legal basis we also process personal information and system information to analyse performance, fix errors, improve the usability and effectiveness of Wallet services and to detect and prevent fraud and abuse in order to protect the security of our users, ourselves, or others.
Your name, identifiers and contact information, such as your phone number, or email address (depending on how you contact us), may be collected when you communicate with us for support, or if you report a bug or other error related to Wallet or when you interact with us through social media. We process this data under legitimate interest legal basis to ensure proper communication and handling within the organization.
When we ask your consent to process your personal information for a specific purpose, we communicate this to you. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your data for that purpose.
We may also collect personal information and/or system information to comply with any applicable law, regulation, legal process, or enforceable governmental request; to cooperate with law enforcement under the basis of legal obligation.
WILL WE SHARE YOUR PERSONAL DATA WITH THIRD PARTIES?
Information about our users is an important part of our business and we do not sell our users’ personal information to others. We may transfer personal data to our service providers or third parties in connection with Wallet’s operation of its business, as certain features on Wallet rely on various third-party products and services (collectively “third party services”). These third party services providers only have access to certain personal information, such as your public Wallet addresses, to perform their functions and may not use it for other purposes. Furthermore, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protections laws.
As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy notice (unless, of course, the user consents otherwise). Also, in the unlikely event that Wallet or substantially all of its assets are acquired, users' information will be one of the transferred assets. We may share non-personally identifiable information publicly and with our partners, like publishers, advertisers, developers, or right holders.
HOW WE USE THE INFORMATION WE PROCESS
We primarily use the limited information that we collect to enhance Wallet. Except if we sell all or a portion of our business, or as otherwise described below, we do not rent, trade, or sell your personal information.
Some ways we may use your personal information are to:
- Contact you when necessary;
- Respond to your comments, questions, or issues related to bugs or errors with Wallet;
- Provide you with additional information;
- Send you information and marketing materials about services and products available through Wallet, using push notifications or other means;
- Train our team members;
- Other internal business purposes.
Aggregated personal information and non-personal information
We may share or disclose aggregated personal iinformation or non-personal information with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the company. These service providers and other persons may also share with us aggregated non-personal information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, and web beacons, with similar data we collect from other visitors to help us improve our Services. When doing so, we do our best to ensure that aggregated information cannot be linked back to you.
Agents or third party partners
We may provide your personal information to our employees, contractors, agents, service providers, and designees (“Agents”) to enable them to perform certain services for us, including improvement of website-related services and features, and performance of maintenance services.
We may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that would be transferred. Also, if we (or our assets) are acquired, or if we go out of business, enter bankruptcy, or go through some other change of control, your personal information could be one of the assets transferred to or acquired by a third party. By accepting this Privacy Notice, as outlined above, you consent to any such transfer.
Protection of Us and Others
We will share personal information outside of Wallet if we have a reasonable belief that access, use, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to cooperate with law enforcement; to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of Wallet, our employees, our users, or others.
YOUR RIGHTS WITH RESPECT TO THE PROCESSING OF PERSONAL DATA
Under data protection law, you have rights including:
- Right to be informed and to access. You may get information regarding your personal data processed by us.
- Right to data portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format. Moreover, you may request that the personal data is transmitted to another controller. Bear in mind that the latter can only be done if that is technically feasible.
- Right to erasure. You the right to have personal data we process about you erased from our systems if the personal data are no longer necessary for the related purposes. Wallet addresses created through the Wallet application cannot be deleted from the Ethereum blockchain, therefore we are unable to delete this personal information.
- Right to object and restrict. You have the right to object to the processing of your personal data and restrict it in certain cases.
- Right to rectification. You have the right to make corrections to your personal data.
- Right to withdraw consent. When you have given us consent to process your personal data, you may withdraw said consent at any time.
- Right to contact the supervisory authority. If you are not satisfied with our response to your request in relation to Personal Data or you believe we are processing your Personal Data not in accordance with the law, you can submit your claim with the Estonian Data Protection Inspectorate (in Estonian: Andmekaitse Inspektsioon) at [email protected] (https://www.aki.ee/).
To exercise any of the abovementioned rights, please contact our DPO via e-mail at [email protected] We will provide you with an answer within 30 days.
3Commas has appointed the Data Protection Officer (DPO) to guarantee high-level personal data protection safeguards and individuals’ rights regarding privacy and data protection. The DPO service for 3Commas is provided by Hedman Partners Law firm. In case you wish to contact our data protection officer, please write to [email protected].
Under California Consumer Protection Act (“CCPA”) you also have the right not to be discriminated against because of the exercise of your rights. Please note that we do not sell your personal data.
Please note that even If you delete your wallet or addresses from the Wallet mobile application, uninstall Wallet mobile applications from your device, or request that your information be deleted, we still may retain some information that you have provided to us to maintain Wallet or to comply with the laws and regulations to which Wallet is subject. If you have any question or objection as to how we collect and process your personal information, please contact us.
We are committed to making sure your information is protected in accordance with applicable laws and our data privacy policies. We have selected third-party vendors that use the Ethereum network, that help us keep your personal information safe. Unfortunately, we do not control these third parties and therefore cannot guarantee complete security. We work to protect the security of your personal information during transmission by using encryption protocols and software. We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of your personal information and secure all connections with industry standard transport layer security. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk.
If you have any questions or concernes regarding your privacy or personald data protection in 3Commas Wallet, please contact us via email [email protected] .
Please note that this privacy statement will regularly be updated to reflect any change in the way we handle your personal information or any changes in applicable laws.