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Privacy Policy

LAST UPDATED – 21ST OF APRIL, 2020

This Privacy Policy (“Policy”) describes how Khasanshin Rinat Ildarovich, IP, registered under no. 01.02.2021, 661220158399, Duns: 506873901, (“Bearby” or the “controller”) collects, uses, shares, and retain the personal data/information (“data”) of users of our website https://bearby.io/ (the “WebSite”) and our mobile application (“App”). This Policy applies to the WebSite, App, and other products/ services offered to you (the „User”/ “You”) by Bearby (the “Services”)..

This Policy supplements out Terms of Services with regard to any details/aspects regarding the processing of personal data in connection with Bearby.

Please note that by downloading our mobile App or running the WebSite you agree to the terms outlined in this Policy.

This Policy does not apply to any personal data/ information collected through third-party websites or services that you may access through the Services or that you submit to us through any electronic message/text/ e-mail.

ELIGIBILITY

The Services are not designed for / directed towards children, as we are sensitive about children's information. Please note that Bearby is not intended for use by anyone under the age of 18. We do not consciously or intentionally collect any information about children who are under the age of 13.

WHAT INFORMATION WE COLLECT

We will never collect. We do not, in any circumstance, collect or retain your secret phrase or private key associated with your account. The security of your wallet account credentials is your own and personal responsibility and it is highly important to keep both, the secret phrase and the private key, safe and secure.

As a non-custodial solution, Bearby does not store any information/ data on its servers. The information/data are stored in the memory/storage asset of the User's devices.

This Policy does not apply to any personal data/ information collected through third-party websites or services that you may access through the Services or that you submit to us through any electronic message/text/ e-mail.

HOW AND WHY WE USE YOUR INFORMATION/DATA

We use your information/data for the following purposes/ by the following means:

Providing our Services
We will use your personal information/data:
to allow you access and use the Services;
to send information, including confirmations, technical notices, updates on our Services/policies, security alerts, reports, and any support/technical and administrative messages/notifications;
to inform us of any errors/bugs that you may encounter when using our Services.

To improve our Services. Customer support
We may use your personal information/data to operate, maintain, and improve our Services. We may also use your information/data to answer your comments and questions regarding the Services, and to provide you with general customer support.

Communicate with you
We use your personal information/data to communicate with you about upcoming events, our news, any technical/support or administrative messages, the Services' features/tools offered by us and our selected partners.

Compliance with the law. Defence our rights
We use your personal information/ data which may be necessary to comply with the applicable laws, lawful requests and legal processes (e.g. answers/providing information to/during official requests/investigations from government authorities). We may use some personal information/ data to defence our rights when you complain against us.

Compliance with fraud prevention and safety requirements
We may use your personal information/ data to protect, investigate, and deter against fraudulent, unauthorized, or any illegal activity you may be subject/ encounter.

SHARING PERSONAL INFORMATION/ DATA

We do not share, rent, trade, or sell your personal information/ data that you provide us with other third parties/ organizations without your express and specific consent, except as described in this Policy. We may disclose personal information/ data to the following third parties:

Affiliates. We may disclose your data to our affiliated companies for purposes consistent with this Policy.
Buyers/ successors of our business/assets. We may share personal information/ data when our shareholders/management will decide to carry out a sale or transfer of all or a part of our business or assets (including any merger, spin-off, financing, acquisition, or bankruptcy transaction or proceeding).
Government authorities. We may share personal information/data to comply with the legal requirements (including, protection and safety of health/ human being; financial systems and transactions etc). Likewise, we may share information/data to respond to lawful requests and legal processes.
Our advisors and service providers. We may share information/ data with our advisors and service providers, e.g. which may include third party companies and individuals to administer and provide the Service on our behalf (such as customer support, hosting, email delivery and database management services), as well as lawyers, bankers, insurers, auditors etc.
Other Third Parties. You may allow us to share your data with other entities or persons of your choice. Third Parties will process the data according to their privacy policies.

CROSS-BORDER DATA TRANSFER

Please be aware that your personal data may be transferred to, processed, and stored in third countries outside EEA (e.g. the United States). Data protection laws in these third countries outside the EU may be different from those in your country of residence. You consent to the transfer your information, including personal information/ data, to each of these countries as set forth in this Policy by visiting our WebSite or using App/our Services.

Whenever we transfer your personal information/data out of the EEA to the other third countries outside the EEA not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on data transfer mechanisms regulated under EU Regulation no. 679/2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data – “EU Regulation 679/2016”), and recognized by the European Commission as providing adequate protection for personal data.

Please contact us if you want further information on the specific mechanisms used by us when transferring your personal information out of the EEA.

HOW LONG WE KEEP YOUR INFORMATION/ DATA

We will hold your personal information/data on our systems for as long as required to make you available Services. We reserve the right to retain your data for a longer period in case of a complaint or if we reasonably believe there is a likelihood of litigation in respect to our relationship with you.

There may be some circumstances when you can ask us to delete your information/ data, so please consider the fact that we also may retain some non-personally identifiable information for statistical purposes in which case we may use this information indefinitely without further notice to you.

HOW YOUR DATA IS SECURED

We take the protection of Users' information/ data very seriously. We employ industry standard security measures to reduce the risks of unauthorised access to Bearby wallet on use of the Services and to deal with any data breaches. We will notify you of any personal data breach where we are legally required to do so.

However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of information/ data. Users of our Services are responsible for maintaining the security of any password, user ID or other type of authentication. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security has occurred.

You acknowledge that the procedures/mechanisms employed by us do not provide absolute security and you cannot expect that the Service will be immune from any risks associated with the common risks from the use of blockchain networks. Any information that you choose to provide to us is made at your own risk.

CHOICES REGARDING YOUR PERSONAL DATA

As data subject, you can exercise the following rights regulated by the data protection legislation (including, EU Regulation 679/2016):

Right of access. We will provide you with a copy of any data we hold about you;
Right to modify. We will modify your data if any of them are incorrect or inaccurate;
Right of erasure. Delete your personal information/data – if erasure is not technically possible or we consider that we have a reasonable legal ground to retain your data that you ask us to erase we will inform you accordingly;
Portability right. We may transfer your data to another service provider; this applies only while processing the User's data on their consent, and only by automatic means.
Right to object. You may object to processing of your data. We will comply with your request except when we have a legitimate interest for processing or we need to continue processing your data to exercise or defend a legal claim.
Complain. You can contact/complaint to the Romanian supervision authority which data are available at www.dataprotection.ro

You can exercise any of your rights at any time by reaching out to us using the information from the Contact section set out here. When you write to us making a request to exercise your above rights we are entitled to identify you first, and ask you to provide identification details to help us to verify your identity. It will help us in the process of giving you a fast and accurate answer to your request if you clearly point out which right you wish to exercise and the reason for exercising it. We reserve the right to delay auctioning on your request if you do not provide us with enough information/details. Only when you have provided us with the exact information we can proceed to process your request.

Contact details:
If you have any inquiries, questions or concerns about this Policy, you may reach us at support@bearby.io or via https://t.me/bearbychat.