Last Updated: June 20, 2023

 

At Splitcoin Inc. ("Splitcoin," "we," "us," or "our"), your personal data's safety is paramount to us as you use the Splitcoin application.

 

This Privacy Statement provides an overview of the practices and principles guiding Splitcoin Inc., (also referred to as 'Splitcoin', 'we', or 'us'), in its handling of your personal information during the order process of purchasing products from our shop on www.splitcoin.com. This encapsulates our approach to gathering, using, disclosing, transferring, storing, retaining, and other types of processing your personal data.

 

We are introducing a new application for iOS and Android devices. This mobile application harnesses NFC (Near Field Communication) technology to split and store an encrypted secret key across a set of NFC tags. This key is used to generate a unique two-way codebook. This unique codebook enables you to manually encrypt a seed phrase – a secure function for individuals wishing to self-custody their cryptocurrencies. Importantly, the Splitcoin mobile application prioritizes your privacy, never asking for your financial data or your seed phrase. Furthermore, the application does not store any data used to encrypt your seed phrase. This includes user passwords, encryption keys, secret keys, ciphertext, or other related data. All data generated by the Splitcoin mobile application solely resides on your Splitcoins, which can be exported to QR codes or PDFs for user convenience. The Splitcoin mobile application does not retain any of this data, and serves as a secure tool for self-custody.

 

I. Collection and Usage of Your Data

 

Your personal information is collected when you order your pack of Splitcoin from our shop on www.splitcoin.com. We gather the following types of information:

 

• Identification and Contact Details: This encompasses your name and email address used for communication during the application process. It also encompasses your mailing address to receive a pack of Splitcoins to use with the mobile application.

• Device Specifications: Information regarding your mobile device, including its make/model and operating system, is collected to confirm compatibility with our application and to enable a diverse pool of iOS and Android users.

• Profiling Insights: We gather information about your experience with cryptocurrencies to extend our invitations to a broad range of users, from novices to experts.

 

II. Sharing of Your Data

 

We may share your personal data with specific external entities under certain conditions:

 

• With service providers: We utilize the services of reliable providers who manage your personal data on our behalf, under our instruction. Through our written contracts, we establish mutual commitments and responsibilities, including the technical and administrative measures that our processors must take to ensure adequate protection of the personal data they manage for us.

• For business transfers: We may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company.

• With business partners: We may share your information with our business partners to offer you certain products, services, or promotions.

• With law enforcement: Your personal data may be shared if we deem it reasonably necessary to: (i) adhere to any applicable laws, regulations, legal procedures or government mandates (e.g., requests from creditors, tax agencies, law enforcement authorities, in response to a legal claim, levy, or lien notice, etc.); (ii) uphold, exercise or protect our legal rights; (iii) enforce or abide by our terms of service or other relevant contracts or policies; (iv) secure our rights or property, or those of our customers, as well as the security or reliability of our Services; (v) investigate potential or actual unlawful activities; or (vi) safeguard us, our Services' users, or the general public from harm, fraud, or possible illegal activities.

• With your consent: We may disclose your personal information for any other purpose with your consent.

 

In certain cases, your data may be anonymized and merged with other data, thereby eliminating the possibility of identifying you. This anonymized, consolidated information may be shared with third parties. However, we do not sell your personal data.

 

III. Retention of Your Data

 

We retain your personal data only for the time required for its initial purpose or to meet legal obligations, resolve disputes, or enforce agreements. Where deletion isn't possible, we may store your data, but our goal is to erase your data within a reasonable timeframe upon receiving a request from you. By using our application, you accept and agree to the terms of this Privacy Policy.

 

IV. User Rights

 

The place of your residence may entitle you to certain rights under the prevailing laws, including the right to:

 

• Access the personal data we have collected about you.

• Ask for your data to be transferred to a third party.

• Demand that we correct or delete your personal data.

• Request that we stop processing or limit the processing of your data.

• Oppose profiling activities derived from our legitimate interests.

• Challenge processing that relies solely on automation.

 

Furthermore, if you've granted us permission to process your personal data, you can revoke this consent at any time. Please be aware that the revocation of consent doesn't affect any processing that occurred before the revocation. If you wish to exercise your rights, including withdrawing consent, you can contact us at hello@splitcoin.com. Before we can grant access or make changes to your data, we may need to confirm your identity. If you choose an authorized representative to make a request on your behalf, we'll need written permission from you and confirmation of your identity before we can process that request.

 

V. Children’s Privacy

 

We have a steadfast policy of not knowingly gathering data from children under the age of 18. If we become aware that we have inadvertently collected personal information from a child under 18 without parental consent, we will promptly delete that information.

 

VI. Ensuring Data Security

 

We employ a variety of measures to protect the integrity of your data. However, please note that no digital storage or transmission method is infallible. Thus, while we do our best to safeguard your personal information, any data transmission between us is carried out at your own risk. Please bear in mind that the Splitcoin app will never request, access, or be aware of your seed phrase. We use reasonable safeguards, including administrative, technical, and physical measures, to protect your data from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Despite the internet's inherent vulnerabilities, we are dedicated to protecting your data on our premises and through our third-party service providers. Only our employees, contractors, and service providers who need to access your personal data for the purposes outlined in this Privacy Notice will have access to it.

 

VII. Physical Security of NFC Tags

 

You will receive a pack of Splitcoins, which are NFC tags. The physical security of these tags is paramount, and you should keep them safe. However, Splitcoin does not take responsibility for the physical security of these tags once they are in your hands.

 

VIII. International Users

 

If you are accessing our services from outside the region where our company is based, rest assured that your data will still be handled according to this Privacy Policy. We abide by data protection laws applicable in our region, which might be different from those in your location.

 

IX. Data Breach Notification

 

In the unlikely event of a data breach, we will notify you promptly via the email address you provided during your order. This notification will include details of what data was compromised, what actions we're taking to address the breach, and steps you can take to safeguard yourself.

 

X. Revisions to the Privacy Notice

 

We retain the right to modify this Privacy Notice as needed. We will provide reasonable advance notice of any significant changes in our data use practices, including via email if you have provided one. If you disagree with these changes, you may terminate your account at any time. We will make updated versions of the Privacy Notice available by posting a revised version and updating the "Effective Date" at the top. The changes become effective as of the listed "Effective Date".

 

XI. Contact Information

 

For any queries or concerns regarding this Privacy Notice, feel free to contact us at hello@splitcoin.com. Please be aware that we may need you to provide additional information and follow certain procedures to confirm your identity when you make a request to exercise your rights. Whenever possible, we will try to cross-reference the information provided in your request with the information we already have on file to confirm your identity. Upon verifying your request, we will proceed with it. We evaluate requests to exercise these rights on an individual basis. We will respond to your request within the timeframe specified by relevant data protection laws. However, we may not always be able to fully comply with your request, in which case we will notify you.