1. General information
1.3. An individual can only become a Client of RebootWallet and use its features if they are aged 18 or over or the age of majority in the country in which they resides if that happens to be greater than 18. RebootWallet does not knowingly collect any information (including Personal Data) or market its services to minors or users under the age of majority.
2. Contact us
2.1. By registering with the Service, the Client consents to the processing of their Personal Data by the Service in accordance with the provisions set below.
2.2. By registering with the Service, the Client gives consent to RebootWallet to anonymize their Personal Data for the purposes of further use in anonymized form in order to improve the performance of the Service.
3. Collected data
3.1. When using the Services, the Client agrees to the processing of the following Personal Data:
3.1.1. Personal Data that the Client provides to the Service:
o When creating an address, the Client obliges to provide the Service with basic details necessary for the Service to work as it might be requested, such as the Client’s name, gender, date of birth and location.
o RebootWallet reserves the right to monitor or record interactions between the Client and the Support Service for training purposes and to ensure high quality of service.
o When participating in Client verification procedures: Client’s Personal Data, as requested by the Service for the Client identification purposes.
o When participating in surveys or focus groups: insights and evaluation of RebootWallet’s services, responses to the questions from the Service.
o When proceeding with transactions: information required under AML/KYC applicable standards in order to ensure the security of transactions.
o While ordering merchant Product through RebootWallet’s website: Client’s Personal Data, as required for the Product’s delivery, such as Client’s full name, postal address, phone number.
3.1.2. Personal Data collected through the use of the Service:
o When the Client is using RebootWallet’s App, the Service may collect data regarding the device(s) the Client uses to access the Service (such as their IP address, device identifier (including unique advertising device identifiers, for example Google Advertiser ID and IDFA), technical and statistical data (including data about the Internet connection, cellular service provider and application usage data) and location data (upon a separate consent from the Client).
3.2. By providing Personal Data to RebootWallet, the Client warrants that such data is true, accurate and up to date.
3.3. In case the Client is entitled to create a Client’s account instead of Client’s address, the present Privacy Policies shall be applicable accordingly.
4. Use of User’s/Client’s personal data
4.1. RebootWallet collects, process and uses Personal Data of Clients of the Service based on the following grounds:
o when such processing is performed in order to fulfil the contract between the Service and the Client;
o based on legitimate interest of the Service;
o upon explicit prior consent from the Client.
4.2. RebootWallet collects and processes Personal Data of the Service’s Clients in order to maintain the functionality of the Service, Product delivery and to ensure compliance with legal and business-related requirements. The User’s/Client’s Personal Data is processed for the following purposes:
4.2.1. When processing of personal data is related to fulfilment of the contract between the Service and the Client:
o to set up, operate and manage the Client’s address and, if necessary, to contact the respective Client through the means provided by the Client upon registration, in connection with the operation and management of the Client’s address;
o to analyze the Client’s profile, activity on the Service, preferences and current location in order to improve the Services;
o to proceed and respond to the requests and enquiries received from the Client;
4.2.2. Under legitimate interests of the Service:
o for Client verification purposes, conducted in relation to an ongoing or alleged misbehavior, performed by the Client of the Service, in order to block addresses as part of the Services anti-spam procedures, to investigate possible fraud;
o to evaluate the effectiveness of marketing and to perform market research and training.
4.2.3. Under an explicit consent from the Client:
o to facilitate networking opportunities of the Client with the Service by way of allowing them to add additional information to the Client’s address;
o to serve the Client with targeted Website advertisements;
o for remarketing purposes, allowing the Service to identify the Client who has previously visited the Website and optimize advertising information according to the Client’s preferences. This feature is used by the Service through third-party services such as Google Advertising;
o to prepare statistics regarding the use of the Services by the Client;
o to identify possible technical malfunctions in the work of the Service, to assist internal research and development and to make improvements to the Website.
4.2.4. When processing delivery of the Products ordered by the Client:
o to facilitate the delivery of the Products ordered by the Client.
5. Duration of the Client’s data retention
5.2. To protect the safety and security of the Clients of the Service, RebootWallet may implement a safety retention window of 30 days following a Client’s address deletion.
5.3. RebootWallet reserves the right to store the Client’s Personal Data for a longer period of time than provided in paragraph 5.1., when it is performed in order to fulfill the legal obligations of the Service (including law enforcement requests, dispute resolution), ensure compliance with applicable law or when the relevant Personal Data is stored on the basis of the Service’s legitimate interests (including security reasons, prevention of fraud).
6. Disclosure of Personal Data
6.1. RebootWallet may share the Client’s Personal Data with third parties in the following cases:
o Other Clients of RebootWallet: The Client shares information with other Clients of RebootWallet by way of voluntarily disclosing information on the Service (including but not limited to information in their Client’s profile). It is in the Client’s discretion to choose the information to be disclosed with the Service and RebootWallet rescinds from responsibility for the other Clients of the Service regarding the way they might use such information, disclosed by the Client.
o Facilitation of Product’s delivery. RebootWallet may share Client’s Personal Data with courier service providers in order to fulfill RebootWallet’s obligations in relation to the Product’s delivery.
o Third-party advertising services. RebootWallet uses the following services but not limited to (list of services is provided alongside with privacy policies of the relevant services):
o Google Analytics
o Third-party analytics services. RebootWallet uses the following services (list of services is provided alongside with privacy policies of the relevant services):
o Google Analytics
o Cloud services providers:
o Client support services
o Providing Client’s data by law: RebootWallet may disclose Client’s Personal Data when such disclosure is required by law and is reasonably necessary:
o in order to establish, exercise, defend or enforce legal rights of the Service;
o to comply with a legal process such as a court order, subpoena or search warrant, government / law enforcement investigation or other legal requirements;
o to assist in the prevention or detection of crime (subject in each case to applicable law);
o to protect the safety or vital interests of an individual.
6.2. In the event of change in the corporate structure of the Service, resulting in transfer of the Client’s Personal Data to a third party, Clients of the Service may be notified of such changes via email and through a notice posted on the Service’s website. Respective notice may explain the identity of the new data controller and the Client’s options regarding disposal of their Personal Data.
7. Client’s rights
7.1. Every Client of the Service is a data subject and thus has ultimate rights over their Personal Data.
7.2. The rights of data subject over their Personal Data are as follows:
Client’s rights and Descriptions:
§ A right to know whether Personal Data concerning the Client is being processed by the Service, right to get information regarding processing of Personal data, right to request a copy of Personal
Data being processed.
§ A right to ask the Service to correct Client’s Personal Data in a situation when such data available to the Service or disclosed to third parties is inaccurate or incomplete.
§ A right to request ‘to be forgotten’, meaning deletion of the Client’s Personal Data from the database of the Service so that the Service is not able to continue processing and storing of such data, with exceptions, provided by applicable law.
o Restrict processing
§ Right to introduce the restriction regime on the processing of the Client’s Personal Data, so that in each case the data may be processed only upon separate consent from the Client.
o Data portability
§ Right to request for the Personal Data provided to the Service 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 the Client.
§ Right to object to processing their Personal Data in a case when the corresponding processing is not performed on the basis of the Client’s consent.
o Withdraw consent
§ Right to withdraw consent to processing of their Personal Data by RebootWallet and/or third party processors of Personal Data. The Client should note that withdrawal of consent to the processing of their will result in the deletion of their profile with the Service and the termination of their use of the Service.
7.3. The abovementioned rights are not absolute. In order to exercise some of the rights, the Client should meet certain conditions and requirements, specified by the law.
7.4. For more information regarding their rights over Personal Data, the Client/User of the Service should contact Admin@RebootWallet.io. In order to exercise their rights, the Client should submit a request to Admin@RebootWallet.io.
7.5. The Client/User of the Service should also be acknowledged of their right to complain to a data protection regulator in their jurisdiction.
8. Protection measures
8.1. When using the Website, Client’s personal data is transferred by the Service to the domain RebootWallet.io.
8.2. RebootWallet works hard to protect its Clients from unauthorized access to or alteration, disclosure or destruction of their Personal Data. Yet, as any other technology companies, although RebootWallet takes steps to secure Clients’ information, it could not be promised or guaranteed, that unauthorized access, hacking, data loss, or other breaches will never occur.
RebootWallet reserves the right to suspend the Client’s address without notice if there is a reasonable suspicion of breach of security. If you believe that your address or information is no longer secure, please notify RebootWallet immediately by sending a message to Admin@RebootWallet.io.
8.3. The Client should take reasonable steps in order to keep their Personal Data safe.
9.2. A cookie is a small file that is stored locally at the Client’s technical device as soon as the Website is being visited. Cookies function by saving particular sets of data, such as, for example, the Client’s language selection. Should the Client open the Website again later, a cookie will transmit this data back to the Website. The Website’s cookies don't store personal information like the Client’s name or address.
9.3. Types of Cookies
RebootWallet’s Website uses different types of cookies:
o Session cookies only last only while the Client is visiting the Website and help RebootWallet to learn more about Client’s use of the Website during a single session and to help the Client to use the Website more efficiently.
o Persistent cookies have a longer lifespan and aren't automatically deleted when the Client closes the Website. These cookies are primarily used to help the Client to sign-in into the Website again quickly, for security and analytical purposes. RebootWallet does not use any information whilst the Client is logged off the Website.
o RebootWallet may use first-party cookies that is when the cookies are placed on the Client’s device directly by the Service. For example, first-party cookies are used to adapt the Website to the language preferences and analyze user experience of the Client.
o Third-party cookies are placed on the Client’s device by RebootWallet’s partners and service providers.
9.4. The Client can at any time reset device identifiers by activating the appropriate setting on their desktop or mobile device. The procedure for managing device identifiers is slightly different for each device and is solely the Clients responsibility.
9.5. Below is information about how RebootWallet uses Clients’ cookies in the Website:
These cookies may be necessary to provide the Client RebootWallet’s services.
o Authentication cookies
§ These persistent cookies help the Service to identify the Clients so that the Client could log into the Website automatically.
o Analytics cookies
§ These cookies help the Service to understand how the Website is being used, and help us customize and improve the Service.
o Google Analytics
o Advertising cookies
§ These cookies are used to make advertising messages more relevant to the Client. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, selecting advertisements that are based on the Client’s interests and measuring the number of ads displayed and their performance, such as how many people clicked on a given ad.
o Social networking cookies
§ These cookies are used to enable the Client to connect the Client’s address to third party social networks.
9.6. Below is information about how RebootWallet uses Clients’ cookies on the RebootWallet.io website:
o Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
10. Cross-border data transfer
10.1. Disclosure of RebootWallet’s Clients’ Personal Data, as provided in section 6 of these Terms of Service sometimes involves cross-border data transfers. RebootWallet uses standard contract clauses approved by The United States or other suitable safeguard to permit data transfers from the USA to other countries. Standard contractual clauses are commitments between companies transferring personal data, binding them to protect the privacy and security of Client’s Personal Data.