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Privacy Notice

Last Update: February 18, 2022

The Privacy Notice (hereinafter - Notice) is a core part of the Keeper Wallet (hereinafter – the Service) Terms of Use. This document describes how we collect, use, share, and delete the data we receive from you because you are using our web browser extension “Keeper Wallet”. Any changes will be made available at the website https://s3.eu-central- 1.amazonaws.com/waves.tech/Privacy_Policy_Waves_Keeper_fin_DL_Tech_9ce50e1fe0.pdf

DLTech Ltd (reg. number 216295) (hereinafter referred to as “We”) understands that your privacy is important and that you care about how your personal data is used. Accordingly, we respect and value the privacy of all our users and will only collect and use personal data in ways that are described here and in a way that is consistent with our obligations and your rights under this Privacy Notice.

1. What is the data we may collect about you or your usage?

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

We do not collect your personal information like name, passport number, tax identification number, etc. Instead, all your personal information, including your seed phrase and wallet, is kept on your device (laptop, smartphone or whatever, where you installed the Keeper Wallet).

We collect only the following metrics about all users anonymously:

Event (data) collectedMeaning
installKeeperThe point of installation
openKeeperOpen UI
idleKeeperThe extension is not used
initVaultThe point of an encrypted storage creation, the password was set
addWalletThe point of creation/import of a new account
allowOrigina website access is granted
disableOrigina website access is denied
approveThe point of User’s confirmation of a transaction or the point of User’s authorization

Depending upon your use of Keeper Wallet, we may collect and hold these pieces of information. It is impossible to personify you by using this information. We do not collect any other data that is directly or indirectly associated with you or your usage of the Keeper Wallet.

We do not collect any ‘special category’ or ‘sensitive’ personal data and/or personal data relating to children, etc. However, we may also collect the information that you provide to us, i.e. your e-mail, in the case of your communication with us by e-mail.

2. How do we use the mentioned data?

We must always have a lawful basis for using any data. The data on the events mentioned earlier are used for statistical monitoring and analysis of the extension performance. The information you provide to us is used to fulfil your request.

We will only use your data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your data for that purpose.

If we need to use your data for a purpose that is unrelated to or incompatiblewith the purpose(s)for which it was originally collected, we will inform you and will explain the legal basis which allows us to do so.

3. How long will we keep the mentioned data?

We will not keep your data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of DataHow Long We Keep It
EventsFor the period of analysis such information only
Information that you provide to usAs long as we need them to fulfil your request or if there are any legal obligations for the length, we are prescribed to store them.

4. How may the user access the data?

We collect the data that is depersonified. So, we cannot divide what kind of data relates to you.

5. How and where do we store or transfer the data?

We do not share any data with anyone that do not have any legal basis for collecting such data. The security of all information we have is essential to us, and to protect it, we take technical measures.

If we sell, transfer, or merge parts of our business or assets (Keeper Wallet), the data may be transferred to a third party. Any new owner of our business or assets (Keeper Wallet) may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Notice.

6. How can the user contact us?

To contact us about anything to do with data and data protection, please use the following details: [email protected].

7. Changes to this Privacy Notice

We may change this Privacy Notice from time to time. This may be necessary, for example, if the lawchanges or if we change our business in away that affects personal data protection.