Last update: 03.06.2019
This notice describes how Valccom collects and processes users’ data through the Porto Crypto-wallet, including all services and functions of the Porto Application and its Website version (the “Platform”). The terms “we”, “us”, “our” refer to Valccom.
We are committed to safeguarding privacy of our users. We are not going to sell or otherwise misuse your data.
Information we collect from you
We ask you to provide your telephone number and email address.
We use the account information (a) to verify your identity when you log in to your wallet and (b) to contact you regarding your account or work of the Platform. Also, we identify a country code of your telephone number to settle an interface language and for our statistical and marketing purposes.
The Platform will create your wallet address (public key), private key, which gives access to the currencies, and seed phrase for restoring the access if necessary.
The transactions between the Platform users are processed Off-Chain. Thus, the users’ private keys are stored on the Platform, protected against unauthorised access.
We do not store nor have access to your seed phrase. We store only hash-function of the seed phrase to confirm its validity in case of your password restoration.
Platform usage data
We collect information about your user experience – your device information, IP- address, geolocation data, and time and duration of use. We use this information (a) to manage your active session (give information about logged in devices) and (b) to conduct our marketing research.
Also, the Platform usage is collected an anonymized and aggregated way to improve the Platform usability and for marketing purposes. Learn more about it in the section “Analytics” of this notice.
A cookie is a small text file that is stored on the user’s computer for record-keeping purposes.
We use both «session cookies» and «persistent cookies» for the Web version of the Platform. Session cookies expire when you close your browser. Persistent cookies remainon the computer to further identify the user make it easier to navigate the Web version. Cookies also enable us to track and target the interests of users to enhance the experience on the Web version.
If you reject cookies, you may still use the Website, but your ability to use some areas of the Website functions may be limited. Also, your web browser allows you to control and limit cookies on your computer.
Legal basis for the processing
Provision of our services
Your telephone number, email address, wallet information, and usage data are being processed to provide you with the services of the Platform. Without this information, we will be unable to provide you with them.
We will not send e-mails with our newsletters, announcements, and other offers to you, nor will we collect marketing cookies unless we obtain the relevant consents from you.
You can withdraw your consent at any time. You can usually do it on the settings page. The withdrawal will not affect the lawfulness of processing based on consent before. You can also opt-out e-mail subscription by clicking the appropriate button in our e-mails to you.
For the marketing purposes, we process the statistics of activity on our Platform, your Platform usage data and country code of your telephone number. These data help us to understand our target groups and conduct marketing research.
We do not intend to collect nor process the children’s (under 18 years old) personal data. Only individuals, who are already 18 years old, may use our Platform and provide information to us.
If we become aware that someone under the age of 18 has provided or attempted to provide us his/her personal information and registered an account, we will use our best efforts to remove the information permanently from our files and delete this account.
Sharing your information
Telephone and E-mail notifications
We are using third parties’ notifications and mailing services for sending our notifications, newsletters, announcements, and other products and service offers from us. This third party may only use information about you to perform services on our behalf. They are not allowed to use it for their own purposes.
We share anonymized and aggregated details of the Platform use, including, but not limited to traffic data, location data, length visit, other communication data, IP address, device information (such as your hardware model, operating system version, unique device identifiers). The information does not allow to identify any certain person, so considered non-personally identifiable information.
Non-Personally Identifiable Information is collected and processed by Google Analytics in an anonymized and aggregated way to improve the Platform usability and for marketing purposes.
Google Analytics is a web analytics service that tracks and reports traffic on the Platform. Google Analytics uses the data collected to track and monitor the use of our Platform. This data may also be shared with other Google services. For more information on the privacy practices of Google, you can check its Policies at https://www.google.com/analytics/policies/.
In addition to the disclosures for the purposes identified before, we may disclose information about you:
- if we are required to do so by law, in connection with any legal proceedings or to establish, exercise or defend our legal rights. For example, we may be obliged to save and store the history of transactions made through the Platform to comply with our legal obligations under the financial laws. If we are asked by the authorised financial regulatory body, we will have to provide share the data with it; and
- in case we sell, license or otherwise assign our Company, corporate rights, the Platform or its separate parts or features to third parties. Except as provided in this privacy notice, we will not sell, share or rent your information to third parties.
Retaining your personal information
We will store your personal information till it is necessary to carry out our obligations to you regarding the Platform.
We will not store your information if you delete your account or we do not use it anymore for the purposes listed in this privacy notice, except if to comply with our legal obligations (for example, if we are required to retain your data to comply with financial regulations), resolve disputes, and enforce our legal agreements and policies.
Regarding your information, you have the right to request us:
- to give access to the information that was collected;
- to update your information;
- to delete any undesirable information about you;
- to restrict processing of your information;
- to stop processing of your information for certain purposes; and
- to send information about you to a third party.
You can complete requests by contacting us at [email protected].
If you believe that our use of your personal information violates your rights, you can lodge a complaint with your national data protection authority.
Security of your personal information
Your personal information is being stored and processed on the servers of the cloud provider inside the European Union. These servers have all technical measures to store the data securely and protected against unauthorised access.
We take necessary and sufficient organizational measures to protect your information from unauthorized or accidental access, destruction, modification, blocking, copying, distribution, as well as from other illegal actions of third parties.
Immediate access to some amount of the data is only allowed to our authorized employees involved in maintaining the Platform. Such employees keep strict confidentiality and prevent unauthorized third-party access to personal information.
Changes to this notice
We may update this privacy notice from time-to-time by posting a new version in our Platform. We advise you to check this page occasionally to ensure you are happy with any changes. However, we will endeavor to provide you with the announcement about any significant changes.
Our Platform may contain links to third-party services and platforms. Although we choose our partners thoroughly and diligently, we cannot be responsible for the content, terms and conditions or privacy policies of third-party services.
We encourage users to be aware when they leave our Platform and to read the privacy statements of the services that collect personally identifiable information.
Third-party websites may contain their own cookies. We are not responsible for their usage of cookies.
Should you have any questions about this privacy notice, please contact us.
You may e-mail us at [email protected].
Our registered office is located at 30-015, Krakow, Swietorkrzyska street, 12/123, Poland.