Privacy Policy

SPOTLESS WALLET

Last Reviewed and Updated: May 17, 2022

SpotlessWallet and its subsidiary, Proper Trust AG (collectively, “SpotlessWallet,” “we,” “our,” and/or “us”), values the privacy of individuals who use our websites (including SpotlessWallet.com (the “Website” or “Site”)), applications, or services, including the blockchain currency management software that is downloadable from the site, and any services that link to this Privacy Policy (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose Personal Data from users of our Software, Site, and Services. For the purposes of this Privacy Policy, “Personal Data” means information that relates to an identified or identifiable natural person.

By using our Site or Services, you agree to the collection, use, and disclosure of your Personal Data as described in this Privacy Policy. Beyond this Privacy Policy, your use of our Site or Services is also subject to our Terms of Service. If you are a California resident, our California Resident Privacy Notice provides more information about your California privacy rights and explains how you can exercise those rights.

As the SpotlessWallet is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your Personal Data to us to use the SpotlessWallet. If you sign up for our newsletter or provide your Personal Data in a customer service ticket, that information will be collected by us. However, certain third-party API providers may require you to provide them with Personal Data, in order to use their services through the SpotlessWallet.

INFORMATION WE COLLECT

We may collect limited Personal Data from or about you or your devices from various sources, as described below.

Information You Provide to Us. When you contact us or sign up for our newsletter, we collect any Personal Data you provide to us, such as your name and email address. If you apply for a job with us, we will collect the Personal Data you provide to us through our Website or via a third-party website in connection with your job application.

Information We Collect Automatically. We may automatically collect information about you and your devices when you use our Site or Services. For example, when you visit our Website, we collect your internet protocol (IP) address, web browser type, web browser language, operating system type, the website you visited before browsing to our website, a pseudonymous User ID that is unique to SpotlessWallet for SpotlessWallet’s internal use in improving its products and services, the pages you view, the length of time you spend on a page, the dates and times of your visits, the hyperlinks you click on, and other information about your use of our Website. When performing an exchange through a third-party API provider, we log information such as the wallet addresses and the transaction IDs involved.

Cookies. We and the third-party API providers may collect information using cookies, pixel tags, or similar technologies. Our third-party partners, such as analytics or advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site.

Our Website uses the following types of cookies for the purposes described below:

- Functional Cookies. We use functional cookies to recognize you when you return to our Site.

- Analytics and Performance Cookies.

We use analytics and performance cookies for website analytics purposes to operate, maintain, and improve the Site and Services. The information gathered by these cookies is aggregated and anonymized and does not identify any specific individual visitor. We use Google Analytics to collect and process certain analytics data on our behalf. Google Analytics uses its own cookies that help us understand how you engage with the Site and Services and may also collect information about your use of other websites, apps, and online resources.

You can block cookies by setting your internet browser to block some or all of the cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our Site and Services. You can change your browser settings to block or notify you when you receive a cookie, delete cookies or browse our Site using your browser’s anonymous usage setting. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings. If you do not agree to our use of cookies or similar technologies which store information on your device, you should change your browser settings accordingly. You should understand that some features of our Site or Services may not function properly if you do not accept cookies or these technologies. Where required by applicable law, you will be asked to consent to certain cookies and similar technologies before we use or install them on your computer or other device.

Information We Receive from Third Parties. We may receive Personal Data about you from third parties such as data or marketing partners and combine it with other Personal Data we have about you

HOW WE USE THE PERSONAL DATA WE COLLECT

We use the Personal Data we collect for the following purposes:

To provide, maintain, debug, improve, and enhance our Site and Services.

● To understand and analyze how you use our Site and Services and develop new products, services, features, and functionality.

● To communicate with you, provide you with updates and other information relating to our Site and Services, provide information that you request, provide you with our newsletter, respond to comments and questions, and otherwise provide customer support.

● For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.

● To personalize your experience on our Site such as identifying you as a repeat visitor.

● To facilitate the connection of third-party services or applications.

● To create de-identified and/or aggregated data to improve for our business purposes, including to improve our

Services.

● To find and prevent fraud, detect security incidents, and respond to trust and safety issues that may arise.

● For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

● To contract with third-party API providers, including providing customer service, processing job applications, verifying customer information, providing advertising or marketing services, providing analytic services or providing similar services on behalf of the business or service provider.

● For other purposes for which we provide specific notice at the time the Personal Data is collected.

SECURITY

We use reasonable organizational, technical, and administrative measures to protect Personal Data within our organization. However, as no electronic transmission or storage of Personal Data can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Data. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us via the “Contact Information” section below.

RETENTION

We will only retain your Personal Data as long as reasonably required for us to provide the requested customer support and inquiry services. In the context of customer support, we retain information sufficient to connect subsequent requests from the same user in order to provide efficient service, unless a longer retention period is required or permitted by law (for example for regulatory purposes).

THIRD-PARTIES

Our Site may contain links or API connections to other websites, products, or services that we do not own or operate. We are not responsible for the privacy and advertising practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party API providers or any Personal Data you disclose to these third parties. We encourage you to read their privacy policies before providing any Personal Data to them.