Policy
Your privacy is of utmost importance to us. It is our policy to respect your privacy and comply with any applicable law and regulation regarding any personal information we may collect about you, including across our website, https://wallet.uniultra.xyz/, and other sites we own and operate as well as mobile applications we offer. Wherever possible, we have designed our website so that you may navigate and use our website without having to provide Personal Data.This Privacy Policy describes how we, as a controller, collect, use and share your personal data. It applies to personal data you voluntarily provide to us, or is automatically collected by us.In this policy, "we", "us" and "our" refers to Unicorn Ultra Foundation a legal entity incorporated in Panama. Any data protection related questions you might have about how we handle your personal dataIn this Policy, “personal data” means any information relating to you as an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an online identifier or to one or more factors specific to your physical, physiological, genetic, mental, economic, cultural or social identity.In this Policy, “processing” means any operation or set of operations which is performed on personal data (as defined in this Privacy Policy) or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1. Glossary
What do some of the capitalized terms mean in this policy?
“Blockchain” means a mathematically secured consensus ledger such as the Ethereum Virtual Machine, an Ethereum Virtual Machine compatible validation mechanism, or other decentralized validation mechanisms.
“Transaction” means a change to the data set through a new entry in the continuous Blockchain.
“Smart Contract” is a piece of source code deployed as an application on the Blockchain which can be executed, including self-execution of Transactions as well as execution triggered by 3rd parties.
“Token” is a digital asset transferred in a Transaction, including ETH, ERC20, ERC721 and ERC1155 tokens.
“Wallet” is a cryptographic storage solution permitting you to store cryptographic assets by correlation of a (i) Public Key and (ii) a Private Key or a Smart Contract to receive, manage and send Tokens.
“Recovery Phrase” is a series of secret words used to generate one or more Private Keys and derived Public Keys.
“Public Key” is a unique sequence of numbers and letters within the Blockchain to distinguish the network participants from each other.
“Private Key” is a unique sequence of numbers and/or letters required to initiate a Blockchain Transaction and should only be known by the legal owner of the Wallet.
“Safe Account” is a modular, self-custodial (i.e. not supervised by us) smart contract-based multi-signature Wallet.
“Safe Account Transaction” is a Transaction of a Safe Account, authorized by a user, typically via their Wallet.
“Profile” means the Public Key and user provided, human readable label stored locally on the user's device.
2. Your information and the Blockchain
Blockchains, also known as distributed ledger technology (or simply ‘DLT’), are made up of digitally recorded data in a chain of packages called ‘blocks’. The manner in which these blocks are linked is chronological, meaning that the data is very difficult to alter once recorded. Since the ledger may be distributed all over the world (across several ‘nodes’ which usually replicate the ledger) this means there is no single person making decisions or otherwise administering the system (such as an operator of a cloud computing system), and that there is no centralized place where it is located either.
Accordingly, by design, records of a Blockchain cannot be changed or deleted and are said to be ‘immutable’. This may affect your ability to exercise your rights such as your right to erasure (‘right to be forgotten’), or your rights to object or restrict processing of your personal data. Data on the Blockchain cannot be erased and cannot be changed. Although smart contracts may be used to revoke certain access rights, and some content may be made invisible to others, it is not deleted.
In certain circumstances, in order to comply with our contractual obligations to you (such as delivery of Tokens) it will be necessary to write certain personal data, such as your Wallet address, onto the Blockchain; this is done through a smart contract and requires you to execute such transactions using your Wallet’s Private Key.
In most cases ultimate decisions to (i) transact on the Blockchain using your Wallet, as well as (ii) share the Public Key relating to your Wallet with anyone (including us) rests with you.
IF YOU WANT TO ENSURE YOUR PRIVACY RIGHTS ARE NOT AFFECTED IN ANY WAY, YOU SHOULD NOT TRANSACT ON BLOCKCHAINS AS CERTAIN RIGHTS MAY NOT BE FULLY AVAILABLE OR EXERCISABLE BY YOU OR US DUE TO THE TECHNOLOGICAL INFRASTRUCTURE OF THE BLOCKCHAIN. IN PARTICULAR THE BLOCKCHAIN IS AVAILABLE TO THE PUBLIC AND ANY PERSONAL DATA SHARED ON THE BLOCKCHAIN WILL BECOME PUBLICLY AVAILABLE
3. How We Use Personal Data
3.1. When visiting our website and using U2U Super App
When visiting our website or using U2U Super App, we may collect and process personal data. The data will be stored in different instances
We connect the Wallet to the web app to identify the user via their public Wallet address. For this purpose we process:
public Wallet address and
WalletConnect connection data
When you create a new Safe Account we process the following data to compose a Transaction based on your entered data to be approved by your Wallet:
your public Wallet address,
account balance,
smart contract address of the Safe Account,
addresses of externally owned accounts and
user activity
The legal base for all these activities is the performance of the contract we have with you (GDPR Art.6.1b).
THE DATA WILL BE STORED ON THE BLOCKCHAIN. GIVEN THE TECHNOLOGICAL DESIGN OF THE BLOCKCHAIN, AS EXPLAINED IN SECTION 2, THIS DATA WILL BECOME PUBLIC AND IT WILL NOT LIKELY BE POSSIBLE TO DELETE OR CHANGE THE DATA AT ANY GIVEN TIME.
3.2. Tracking
3.2.1 We may store the following personal data to analyze your behavior:
IP Address,
session tracking,
user behavior,
wallet type,
device and browser user agent,
user consent,
operating system,
referrers,
user behavior: subpage, duration, and revisit, the date and time of access,
This data may be processed in order to improve the product and user experience.
The lawful basis for this processing is your consent (GDPR Art.6.1a) when agreeing to accept cookies.
3.2.2 We conduct technical monitoring of your activity on the platform in order to ensure availability, integrity and robustness of the service. For this purpose we process your:
IP addresses,
meta and communication data,
website access and
log data
The lawful basis for this processing is our legitimate interest (GDPR Art.6.1f) in ensuring the correctness of the service.
3.3. When Participating in User Experience Research (UXR)
When you participate in our user experience research we may collect and process some personal data. This data may include:
your name
your email
your phone type
your occupation
range of managed funds
In addition, we may take a recording of you while testing U2U Super App for internal and external use. The basis for this collection and processing is our legitimate business interest in monitoring and improving our services.
The lawful basis for this processing is your consent as provided before participating in user experience research.
3.4 Other uses of your Personal Data
We may process any of your Personal Data where it is necessary to establish, exercise, or defend legal claims. The legal basis for this is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
Further, we may process your Personal data where such processing is necessary in order for us to comply with a legal obligation to which we are subject. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights.
4. Use of Third Party Applications
4.1. Blockchain
When using Safe Accounts your smart contract address, Safe Account Transactions, addresses of signer accounts and ETH balances and token balances will be stored on the Blockchain. See section 2 of this Policy
THE INFORMATION WILL BE DISPLAYED PERMANENTLY AND PUBLIC, THIS IS PART OF THE NATURE OF THE BLOCKCHAIN. IF YOU ARE NEW TO THIS FIELD, WE HIGHLY RECOMMEND INFORMING YOURSELF ABOUT THE BLOCKCHAIN TECHNOLOGY BEFORE USING OUR SERVICES.
4.2. Google Firebase
We use the following Google Firebase services:
Firebase Cloud Messaging: Provide updates to the user about changes in the mobile apps via push notifications.
Firebase remote config: Inform users about, recommend or force user to update their mobile app or enabling/disabling certain app features. These settings are global for all users, no personalization is happening.
Firebase crash reporting: Report errors and crashes to improve product and user experience.
4.3. WalletConnect
WalletConnect is used to connect wallets to dapps using end-to-end encryption by scanning a QR code. We do not store any information collected by WalletConnect.
5. Sharing Your Personal Data
We may pass your information to our Business Partners, administration centers, third party service providers, agents, subcontractors and other associated organizations for the purposes of completing tasks and providing our services to you.
In addition, when we use any other third-party service providers, we will disclose only the personal information that is necessary to deliver the service required and we will ensure that they keep your information secure and not use it for their own direct marketing purposes. In addition, we may transfer your personal information to a third party as part of a sale of some, or all, of our business and assets or as part of any business restructuring or reorganization, or if we are under a duty to disclose or share your personal data in order to comply with any legal obligation. However, we will take steps to ensure that your privacy rights continue to be protected.
6. Existence of Automated Decision-making
We do not use automatic decision-making or profiling when processing Personal Data.
7. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8. Acceptance
By accessing and using our website and services , you signify your agreement to this Privacy Policy. We reserve the right to change or amend this Privacy Policy at any time. Please check our page frequently to see any updates or changes to this Privacy Policy.
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