Privacy policy

This Privacy Policy was last updated on 9th of March 2021.

1. General information

1.1. References in this Privacy Policy to “SimpleHold” and “Service”, relate to the browser extension, available at https://chrome.google.com/webstore, operated by SimpleSwap Ltd, Trust Company Complex, Ajeltake Road, Ajeltake Island Majuro, Marshall Islands MH 96960 (“We”, “Us”).

1.2. To the extent we collect any Personal Data, this Privacy Policy describes how SimpleHold collects, uses, and shares personal information of people who use our Services.

1.3. This Policy applies to anyone who accesses the Services. Please read the Policy carefully to understand our practices regarding your Personal Data and how we will treat it. By using our Services, you acknowledge that the collection, use, and sharing of your Personal Data will take place as described in this Policy.

1.4. This Privacy Policy does not apply to anonymised data, as it cannot be used to identify you.

1.5. SimpleHold is the data controller in relation to the Personal Data processed within the framework of this Privacy Policy.

1.6. Eligibility. An individual can only become a Client of SimpleHold and use its features if he/she is aged 18.

1.7. SimpleHold reserves the right to amend this Privacy Policy; therefore it is recommended that you check this Privacy Policy on a regular basis. We will send a notice or an email regarding such changes to you.

All the changes to this Privacy Policy are effective as of the “Last updated” date. The Client who continues to use the Service after the Last updated date is deemed to accept the changes made to it.

1.8. The present Privacy Policy is governed by the laws of England and Wales.

2. Specifics of Blockchain

Due to the inherent transparency of many blockchains, transactions that individuals broadcast via SimpleHold may be publicly accessible. This includes, but is not limited to, your public sending address, the public address of the receiver, the amount sent or received, and any other data a user has chosen to include in a given transaction. Information stored on a blockchain may be public, immutable, and difficult or even impossible to remove or delete. Transactions and addresses may reveal information about the user’s identity and information can potentially be correlated now or in the future by any party who chooses to do so, including law enforcement. Users are encouraged to review how privacy and transparency on the blockchain works.

3. Principles related to the specifics of the Services.

Operation of our Services is based on the following principles, applicable to treatment of your Personal Data:

We don’t require you to register or log in.

We don’t have access to your funds and private keys.

We don’t require your name or email address.

Your private keys will stay on your device.

4. Contact us

Any requests and questions about this Privacy Policy, collection, use and disclosure of Personal Data by SimpleHold should be directed to [email protected].

5. Collected data

We may collect the following types of information:

5.1.1. Personal Data that you provide to us:

We may collect Personal Data that you choose to provide to us. For example, when you contact us for support and give us your e-mail address and any other information that you choose to provide.

SimpleHold does not knowingly collect any sensitive personal data or special categories of personal data.

5.1.2. Personal Data collected through the use of the Service:

When you use the Service, we may collect data regarding the device(s) that you use to access the Service (such as your IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and UID (identifier used by certain analytics providers)), technical (device’s language settings and browser settings, time settings) and statistical data (including data about the Internet connection, and application usage data).

5.2. By providing Personal Data to SimpleHold, you warrant that such data is true, accurate and up to date.

6. How we use your Personal Data

The following legal bases apply to the ways in which we use and share your Personal Data:

We rely on your consent to process Personal Data to provide support and/or carry out Promotions. This consent can be withdrawn at any time.

We also process the Personal Data provided by you in our legitimate interests in ensuring our business is conducted legitimately and to a high standard.

7. Retention

7.1. We will retain Personal Data, that you communicate to us through the use of the Service, as long as you have our browser extension installed on your device. We will retain the information that you provide in order to process your request and/or receive support, for as long as is practically (but no longer than a year since the data in received from you) needed to proceed the relevant request.

7.2. When determining the specific retention period, we take into account various criteria, such as the nature and length of our relationship with you, mandatory retention periods provided by law, and the limitations, provided by law.

7.3. We reserve the right to store your Personal Data for a longer period of time than provided in paragraph 7.1., when it is performed in order to fulfil our legal obligations (including law enforcement requests, dispute resolution) and/or to ensure our compliance with applicable law.

8. Disclosure of Personal Data

8.1. We may share your information in the following circumstances:

We may share your information with service providers who help with parts of our business operations, such as:

- Chrome Web Store (Privacy Policy is available at: https://policies.google.com/privacy?hl=en-GB),

- GetBlock (Privacy Policy is available at: https://getblock.io/privacy-policy),

- Nownodes (Privacy Policy is available at: https://nownodes.io/).

We may share your information with providers of analytics, such as:

Amplitude (Privacy Policy is available at: https://amplitude.com/privacy), Google Analytics.

We may share your information with law enforcement or regulatory agencies, as may be required by law.

8.2. We ensure appropriate contractual control over third parties assisting the Service in processing your Personal Data, securing that your rights are upheld, your Personal Data is secure, appropriate security and privacy arrangements are in place.

8.3. In the event of change in our corporate structure, resulting in transfer of the Client’s Personal Data to a third party, all the Clients of the Service would be notified of such changes via email and through a notice posted on the Service’s website. Respective notice would explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.

9. Your privacy rights

9.1. Every Client of the Service is a data subject and thus has ultimate rights over his/her Personal Data.

9.2. The rights of a data subject over his/her Personal Data are as follows:

Your rightDescription
Information and AccessThe right to know whether your Personal Data is being processed, right to get information regarding processing of personal data, right to request a copy of Personal Data being processed. The right to information about public and private entities with which we have shared data.
Rectification (correction)The right to correct your Personal Data in a situation when such data available to us or disclosed to third parties is inaccurate or incomplete.
ErasureThe right to request deletion of your Personal Data from our database so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law.
Restrict processingThe right to introduce the restriction regime on the processing of your Personal Data, so that in each case the data may be processed only upon your separate consent.
Data portabilityThe right to request for the Personal Data to be given in a machine-readable format so that it could be transferred to another service provider or transfer directly to a third party designated by you.
ObjectThe right to object to processing of your Personal Data in a case when the corresponding processing is not performed on the basis of your consent.
Withdraw consentRight to withdraw consent to processing of your Personal Data by us or third parties to which we have previously disclosed your Personal Data.

9.3. The abovementioned rights are not absolute. In order to exercise some of the rights, you should meet certain conditions and requirements, specified in applicable law.

9.4. For more information regarding your rights in relation to Personal Data, please contact [email protected]. In order to exercise your rights, please submit a request to [email protected].

9.5. In addition to the rights mentioned above, as a resident of EU/EEA you also have a right to complain to a data protection regulator in your jurisdiction.

10. Protection measures

10.1. We work hard to protect our clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although SimpleHold takes steps to secure Clients’ information, we cannot guarantee, that an unauthorized access, hacking, data loss, or other breaches will never occur.

11. Cookies

11.1. In order to guarantee an optimal level of usability and performance and to ensure relevance of promoted services, we use cookies and similar technologies (SDK) in order to track the interaction of clients with our Service. This section explains the different types of cookies that may be set when you use our Service, helping to understand and manage them as you wish.

11.2. A cookie is a small file that is stored locally at your technical device as soon as the Service is being used. Cookies function by saving sets of data, such as, for example, language selection. Cookies do not store personal information like Client’s name or address.

11.3. You can generally activate or later deactivate the use of cookies through a functionality built into your web browser. To learn more about how to control cookie settings through your browser:

Click here to learn more about the “Private Browsing” setting and managing cookie settings in Firefox;

Click here to learn more about “Incognito” and managing cookie settings in Chrome;

Click here to learn more about “InPrivate” and managing cookie settings in Internet Explorer; or

Click here to learn more about “Private Browsing” and managing cookie settings in Safari.

11.4. Below is information about how we use cookies:

NamePurposeIs it a 1st or 3rd party cookie or local storage entry?
Necessary cookiesThese cookies are strictly necessary to provide you with the Services.1st party cookie
Local storageAnalytics1st party cookie
CloudflareError reporting and technical maintenance3rd Party cookie
AmplitudeAnalytics3rd Party cookie
Google AnalyticsAnalytics3rd Party cookie

12. Cross-Border Data Transfer

Please be aware that Personal Data that we collect from you may be transferred outside of EU/EEA area, as some of our service providers have their principal place of business in the United States. Data protection laws in the U.S. may be different from those in your country of residence.

We rely on standard contract clauses approved by the European Commission when transferring data to US.

Privacy Notice for California residents

This Privacy Notice for California Residents (this “Privacy Notice”) supplements the information contained in SimpleHold (“Company”, “us” or “our”, or “we”) Privacy Policy (“Site Privacy Policy”) and applies solely to all visitors, users and others who reside in the State of California (“consumers”, “you” or “your”). We adopt this Privacy Notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Privacy Notice. All capitalized terms not herein defined will have the meaning set forth in Company’s Privacy Policy. In case on any inconsistencies with Company’s Privacy Policy, this Privacy Notice shall prevail.

1. INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).

1.1. In particular, we have collected the following categories of personal information from our consumers within the last twelve (12) months:

A. Identifiers.

Examples: A unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.

C. Internet or other similar network activity.

Examples: Information on a consumer’s interaction with the application.

1.2. Personal information does not include:

(i)

Publicly available information from government records,

(ii)

De-identified or aggregated consumer information,

(iii)

Information excluded from the CCPA's scope, like:

i. health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
ii. personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

1.3. We obtain the categories of personal information listed above from the following categories of sources:

(i)

Directly from our clients or their agents. For example, from information our clients provide to us related to the Services for which they engage us.

(ii)

Directly from you when you provide it to us. For example, if you share your name and contact information to ask a question about our site or app.

(iii)

Indirectly from you. For example, from observing your actions on our Site.

(iv)

From third parties, for example, our service providers.

2. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following purposes:

(i)

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our site, app or product we will use that personal information to respond to your inquiry.

(ii)

To provide, support, personalize and develop our apps and products.

(iii)

To process your requests and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

(iv)

To notify you about changes to our site, app or any products or services we offer or provide through it.

(v)

To notify you about changes to our policies and/or user agreements.

(vi)

To maintain a record of our dealings with you.

(vii)

To understand and analyze the usage trends and preferences of our users, to improve the site, the app and other products and to develop new features, and functionality.

(viii)

To contact you for administrative and information purposes - this may include providing customer service or sending communications, including changes to our terms of use.

(ix)

To engage features of third party social networks.

(x)

For testing, research, analytics and product development.

(xi)

To help maintain the safety, security, and integrity of our site and app, and our databases, other technology assets and business.

(xii)

To diagnose or fix technological problems in relation to our site, app and products.

(xiii)

To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

(xiv)

To respond to law enforcement requests and as required by applicable law, court order or governmental regulations.

(xv)

To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

(xvi)

As described to you when collecting your personal information or as otherwise set forth in the CCPA.

3. SHARING PERSONAL INFORMATION

3.1. We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

3.2. In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: Category A: Identifiers. Category C: Internet or other similar network activity.

3.3. We disclose your personal information for a business purpose to the following categories of third parties:

(i)

Our affiliates.

(ii)

Service providers.

(iii)

Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

(iv)

Law enforcement bodies and courts.

3.4. We share your personal information for the following general purposes:

(i)

Service Providers: We may disclose personal information to third-party service providers that assist us with our operations. For example, analytics, log management, payment processing and data storage and processing services.

(ii)

Protecting our Rights: We may disclose personal information to third parties if we believe that doing so is legally required or is in our interest to protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights or property of others.

(iii)

Corporate Transaction: Personal information may be disclosed as part of a corporate transaction, such as a merger, acquisition, debt financing, sale of company assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal information could be transferred to third parties as one of our business assets.

In the preceding twelve (12) months, we have not sold any personal information.

4. YOUR RIGHTS AND CHOICES

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

4.1. Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will disclose to you:

(ii)

The categories of sources for the personal information we collected about you.

(iii)

Our business or commercial purpose for collecting and selling that personal information.

(iv)

The categories of third parties with whom we share that personal information.

(v)

The specific pieces of personal information we collected about you (also called a data portability request).

(vi)

If we disclosed your personal information for a business purpose, a list with disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

4.2. Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights Section), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

(i)

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you or otherwise perform our contract with you.

(ii)

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

(iii)

Debug products to identify and repair errors that impair existing intended functionality.

(iv)

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

(v)

Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

(vi)

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

(vii)

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

(viii)

Comply with a legal obligation.

(ix)

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

4.3. Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by emailing us at [email protected].

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

(i)

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

(ii)

Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

4.3.1. Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

4.4. Personal Information Sales Opt-Out and Opt-In Rights

If you are a California resident and 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time.

To exercise the right to opt-out, you (or your authorized representative) may submit a variable notice to [email protected].

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales.

5. NON-DISCRIMINATION

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

(i)

Deny you goods or services.

(ii)

Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

(iii)

Provide you a different level or quality of goods or services.

(iv)

Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

6. CHANGES TO OUR PRIVACY NOTICE

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will post the updated Privacy Notice on our Site and update the Privacy Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes.

7. CONTACT INFORMATION

If you have any questions or comments about this Privacy Notice, the ways in which the Company collects and uses your information described here and in our Site Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact our representative responsible for personal information as follows: [email protected].