Privacy Policy

PRIVACY POLICY OF THE MYDAPPWALLET APP

This Privacy Policy (hereinafter: “Policy“) contains information on the processing of your personal data in connection with the use of the MyDappWallet App, operating at the internet address http://wallet.mydappwallet.com/ (hereinafter: “App“).

All capitalized terms that are not otherwise defined in the Policy shall have the meaning given to them in the Terms and Conditions available at this site.

Personal data Controller

The Controller of your personal data is DBRIDGE sp. z o.o. company with its registered office in Warsaw (registered office address: ul. Echa Leśne 21B, 03-286 Warsaw), entered in the  Register of Entrepreneurs of the National Court Register kept by the District Court of Warsaw, XIV Commercial Division of the National Court Register under the KRS number: 0000981309, holder of NIP: 5242945385, REGON number: 522538698, with the share capital of PLN 6.000 (six thousands PLN) paid in full (hereinafter: “Controller“).

Contact with the Controller

In all matters related to the processing of personal data, you can contact the Controller using:

  1. e-mail: contact@dbridge.network;
  2. post address: ul. Echa Leśne 21B, 03-286 Warsaw, Poland.
  3. telephone: +48601360881.

Measures to protect personal data

The Controller uses modern organizational and technical safeguards to
ensure the best possible protection of your personal data and
guarantees that it processes them in accordance with the
provisions of Regulation (EU) 2016/679 of the European Parliament
and of the Council of 27 April 2016 on the protection of
individuals with regard to the processing of personal data and on
the free movement of such data, and repealing Directive 95/46/EC
(General Data Protection Regulation) (hereinafter: "
GDPR"),
the Act of 10 May 2018 on the protection of personal data and
other provisions on the protection of personal data.

Information
about the processed personal data

Using
the App requires the processing of your personal data. Below you
will find detailed information about the purposes and legal bases
of processing, as well as the period of processing and the
obligation or voluntariness to provide them.

Purpose
of processing
Personal
data processed
Legal
basis
Conclusion
and performance of the Agreement for the provision of the Account
Service
  1. e-mail
    address
  2. telephone
    number
Article
6(1)(b) of the GDPR

(processing
is necessary for the performance of the Account Service Agreement
concluded with the data subject or to take steps to conclude it)

Providing
the above-mentioned personal data is a condition for the
conclusion and performance of the contract for the provision of
the Account Service (their provision is voluntary, but the
consequence of not providing them will be the inability to
conclude and perform the above-mentioned contract, including the
creation of an Account).

The
Controller will process the above-mentioned personal data until
the claims arising from the Agreement for the provision of the
Account Service expire.


Purpose
of processing
Personal
data processed
Legal
basis
Conclusion
and performance of the MyDappWallet Service
  1. name
    and surname
  2. e-mail
    address
  3. telephone
    number
  4. address
    of residence/business activity (street, house number, apartment
    number, city, postal code, country)
  5. optionally
    - company and NIP (if the Buyer is an Entrepreneur or
    Entrepreneur with consumer rights)
  6. [...].
Article
6(1)(b) of the GDPR

(processing
is necessary for the performance of the MyDappWallet Service with
the data subject or to take steps to conclude it)

Providing
the above-mentioned personal data is a condition for the
conclusion and performance of the MyDappWallet Service (their
provision is voluntary, but the consequence of not providing them
will be the inability to conclude and perform the MyDappWallet
Service).

The
Controller will process the above-mentioned personal data until
the claims arising from the Agreement for the MyDappWallet Service
expire.


Purpose
of processing
Personal
data processed
Legal
basis
Conclusion
and performance of the Newsletter Agreement
e-mail
address
Article
6(1)(b) of the GDPR

(processing
is necessary for the performance of the Newsletter Subscription
Agreement concluded with the data subject or to take action to
conclude it)

and

Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case informing about new services and
promotions available in the App)

Providing
the above-mentioned personal data is voluntary, but necessary to
receive the Newsletter (the consequence of not providing them will
be the inability to receive the Newsletter.

The
Controller will process the above-mentioned personal data, the
time of effective objection or achievement of the purpose of
processing or until the claims arising from the Newsletter
Subscription Agreement are time-barred (whichever occurs first).


Purpose
of processing
Personal
data processed
Legal
basis
Conducting
a complaint procedure
  1. name
    and surname
  2. e-mail
    address
Article
6(1)(c) of the GDPR

(processing
is necessary to fulfill a legal obligation incumbent on the
Controller, in this case the obligations of:

  • responding
    to a complaint – Article 7a of the Act on consumer rights;
  • exercise
    the Client's rights resulting from the provisions on the
    Controller's liability in the event of non-compliance of the the
    Subject of Digital Services with the Agreement concerning it)
Providing
the above-mentioned personal data is a condition for receiving a
response to the complaint or exercising the Client's rights under
the provisions on the Controller's liability in the event of
non-compliance of the Subject of Digital Services with the
Agreement concerning it (their application is voluntary, but the
consequence of not providing them will be the inability to receive
a response to the complaint and the implementation of the
above-mentioned rights).

The
Controller will process the above-mentioned personal data for the
duration of the complaint procedure, and in the case of the
implementation of the above-mentioned rights of the Client –
until they expire.


 
 
Purpose
of processing
Personal
data processed
Legal
basis
Sending
email notifications
e-mail
address
Article
6(1)(f) of the GDPR

(processing
is necessary in order to implement the legitimate interest of the
Controller, in this case informing Clients about the actions taken
related to the performance of agreements concluded with Clients)

Providing
the above-mentioned personal data voluntary, but necessary to
receive information about activities related to the performance of
agreements concluded with Clients (the consequence of not
providing them will be the inability to receive the
above-mentioned information).

The
Controller will process the above-mentioned personal data until
the objection is effectively raised or the purpose of processing
is achieved (whichever occurs first).


Purpose
of processing
Personal
data processed
Legal
basis
Handling
inquiries submitted by Clients
  1. name
  2. e-mail
    address
  3. other
    data contained in the message to the Controller
Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case to respond to the received inquiry)

Providing
the above-mentioned personal data is voluntary, but necessary to
receive an answer to the inquiry (the consequence of not providing
them will be the inability to receive an answer).

The
Controller will process the above-mentioned personal data until
the objection is effectively raised or the purpose of processing
is achieved
(whichever
occurs first).


Purpose
of processing
Personal
data processed
Legal
basis
Sharing
Reviews on Services
  1. name
  2. optionally
    – other data contained in the Review
Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case providing the Review for information and
promotional purposes)

Providing
the above-mentioned personal data is voluntary, but necessary to
add a Review (the consequence of not providing them will be the
inability to add a Review).

The
Controller will process the above-mentioned personal data until
the objection is effectively raised or the purpose of processing
is achieved
(whichever
occurs first).


Purpose
of processing
Personal
data processed
Legal
basis
Compliance
with tax obligations (m.in issuing a VAT invoice, storing
accounting documentation)
  1. Name
    and surname/company
  2. address
    of residence/registered office
  3. tax
    identification number
Article
6(1)(c) of the GDPR

(processing
is necessary to fulfill the legal obligation incumbent on the
Controller, in this case obligations arising from tax law)

Providing
the above-mentioned personal data is voluntary, but necessary for
the Controller to meet its tax obligations (the consequence of not
providing them will be the Controller's inability to meet the
above-mentioned obligations).

The
Controller will process the above-mentioned personal data for a
period of 5 years from the end of the year in which the tax
payment deadline for the previous year expired.


 
 
Purpose
of processing
Personal
data processed
Legal
basis
Fulfillment
of obligations related to the protection of personal data
  1. Name
    and surname
  2. contact
    details provided by you (e-mail address; correspondence address;
    telephone number)
Article
6(1)(c) of the GDPR

(processing
is necessary to fulfill the legal obligation incumbent on the
Controller, in this case the obligations arising from the
provisions on the protection of personal data)

Providing
the above-mentioned personal data is voluntary, but necessary for
the Controller to properly perform the obligations arising from
the provisions on the protection of personal data, m.in. exercise
the rights granted to you by the GDPR (the consequence of not
providing the above-mentioned data will be the inability to
properly implement the above-mentioned rights).

The
Controller will process the above-mentioned personal data until
the expiry of the limitation periods for claims for violation of
the provisions on the protection of personal data.


 
 
Purpose
of processing
Personal
data processed
Legal
basis
Establishing,
investigating, or defending against claims
  1. Name
    and surname/company
  2. e-mail
    address
  3. address
    of residence/registered office
  4. PESEL
    number
  5. Tax
    identification number
Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case to establish, investigate or defend
against claims that may arise in connection with the performance
of Contracts concluded with the Controller)

Providing
the above-mentioned personal data is voluntary, but necessary to
establish, investigate or defend against claims that may arise in
connection with the performance of the agreements concluded with
the Controller (the consequence of not providing the
above-mentioned data will be the inability of the Controller to
take the above-mentioned actions)

The
Controller will process the above-mentioned personal data until
the expiry of the limitation periods for claims that may arise in
connection with the performance of the agreements concluded with
the Controller.


 
 
Purpose
of processing
Personal
data processed
Legal
basis
Analysis
of your activity in the App
  1. date
    and time of visit
  2. IP
    number of the device
  3. device
    operating system type
  4. approximate
    location
  5. type
    of web browser
  6. time
    spent in the App
  7. visited
    subpages and other activities undertaken as part of the App
Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case obtaining information about your activity
in the App)

Providing the above-mentioned personal data is voluntary, but necessary for the Controller to obtain information about your activity in the
App (the consequence of not providing them will be the Controller's inability to obtain the above-mentioned information).

The Controller will process the above-mentioned personal data until
the effective objection is raised or the purpose of processing is
achieved.


 
 
Purpose
of proceeding
Personal
data processed
Legal
basis
App
administration
  1. IP
    address
  2. server
    date and time
  3. web
    browser information
  4. operating
    system information

The
above data is saved automatically in the so-called server logs,
each time you use the App (administering it without using server
logs and automatic saving would not be possible).

Article
6(1)(f) of the GDPR

(processing
is necessary to implement the legitimate interest of the
Controller, in this case to ensure the proper operation of the
App)

Providing
the above-mentioned personal data is voluntary, but necessary to
ensure the proper operation of the App (the consequence of not
providing them will be the inability to ensure the operation of
the App in a proper manner).

The
Controller will process the above-mentioned personal data until
the effective objection is raised or the purpose of processing is
achieved.

Profiling
To create your profile for marketing purposes and direct marketing tailored to your preferences, the Controller will process your
personal data in an automated manner, including profiling them – however, this will not cause any legal effects for you or similarly
significantly affect your situation.

The scope of profiled personal data corresponds to the scope indicated above in relation to the analysis of your activity in the App and the
data you save on the Account.

The legal basis for the processing of personal data for the above purpose is art. 6 par. 1 lit. f GDPR, according to which the Controller may
process personal data to implement his legitimate interest, in this case to conduct marketing activities tailored to the preferences of
recipients. Providing the above-mentioned personal data is voluntary, but necessary to achieve the above-mentioned purpose (the consequence
of not providing them will be the inability of the Controller to conduct marketing activities tailored to the preferences of
recipients).

The Controller will process personal data for the purpose of profiling until an objection is effectively raised or the purpose of processing
is achieved.

Recipients of personal data
The recipients of personal data will be the following external entities cooperating with the Controller:hosting company; providers of online payment systems; newsletter service provider; companies providing tools for analyzing activity in the App and directing direct marketing to people using it (m.in. Google Analytics);a company, providing accounting services
In addition, personal data may also be transferred to public or private entities, if such an obligation results from generally applicable law, a final court judgment or a final administrative decision.

Transfer of personal data to a third country
In connection with the Controller's use of services provided by Google LLC, your personal data may be transferred to the following third countries: Great Britain, Canada, USA, Chile, Brazil, Israel, Saudi Arabia, Qatar, India, China, South Korea, Japan, Singapore, Taiwan (Republic of China), Indonesia and Australia.
The basis for the transfer of data to the above-mentioned third countries are: in the case of the United Kingdom, Canada, Israel and Japan - decisions of the European Commission stating an adequate level of protection of personal data in each of the above-mentioned third countries; for the USA,
Chile, Brazil, Saudi Arabia, Qatar, India, China, South Korea,
Singapore, Taiwan (Republic of China), Indonesia and Australia, contractual clauses ensuring an adequate level of protection, in accordance with the standard contractual clauses set out in Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries pursuant to a Regulation of the European Parliament and of the Council (EU) 2016/679.

You can obtain from the Controller a copy of the data transferred to a third country.

Your rights
In connection with the processing of personal data, you have the following rights:

  1. the right to information about what personal data concerning you is processed by
    the Controller and to receive a copy of this data (the so-called right of access). Issuing the first copy of the data is free, for
    the next one the Controller may charge a fee;
  2. if the processed data becomes outdated or incomplete (or otherwise incorrect), you have the right to request its rectification;
  3. in certain situations, you can ask the Controller to delete your personal data, e.g. when:
    1. the data will no longer be needed by the Controller for the purposes of which he
      informed;
    2. you have effectively withdrawn your consent to the processing of data - unless the Controller has the right to process data on another
      legal basis;
    3. the processing is unlawful; the need to delete data results from the Controller's legal obligation.
  1. if personal data are processed by the Controller on the basis of consent to processing or for the purpose of performing the Agreement concluded
    with him, you have the right to transfer your data to another Controller;
  2. if personal data is processed by the Controller on the basis of your consent to processing, you have the right to withdraw this consent at any time
    (withdrawal of consent does not affect the lawfulness of processing that was made on the basis of consent before its withdrawal);
  3. if you consider
    that the processed personal data is incorrect, their processing is unlawful, or the Controller no longer needs certain data, you can
    request that for a specific, necessary time (e.g. checking the correctness of data or pursuing claims) the Controller does not
    perform any operations on the data, but only Apps them;
  4. you have the right to object to the processing of personal data whose basis for processing is the legitimate interest of the Controller. In the
    event of an effective objection, the Controller will cease to process personal data for the above-mentioned purpose;
  5. you have the right to lodge a complaint with the President of the Office for Personal Data Protection if you believe that the processing of personal data violates the provisions of the GDPR.
Cookies

  1. The Controller informs that the App uses "cookies" installed on your end device. These are small text files that can be read by the
    Controller's system, as well as by systems belonging to other entities whose services are used by the Controller (e.g. Facebook,
    Google).
  2. The Controller uses cookies for the following purposes:
    1. ensuring the proper operation of the App – thanks to cookies, it is possible to operate efficiently the
      App, use its functions and conveniently move between individual
      subpages;
    2. increasing the comfort of browsing the App – thanks to cookies, it is possible to detect errors on some subpages
      and their constant improvement;
    3. creating statistics – cookies are used to analyze how users use the App. Thanks to this, it is possible to constantly improve the App and adapt its operation to the preferences of users;
    4. conducting
      marketing activities

      – thanks to cookies, the Controller may direct advertisements
      tailored to users' preferences.
  1. Controller can place both permanent and temporary (session) files on your device. Session files are usually deleted when you close the browser, but closing the browser does not delete persistent files.
  2. Information
    about cookies used by the Controller is displayed in the panel located at the bottom of the App's website. Depending on your decision, you can enable or disable cookies of individual categories (except for necessary cookies) and change these settings at any time.
  3. Data collected using cookies do not allow the Controller to identify you.
  4. The Controller
    uses the following cookies or tools using them:
 
TOOL
SUPPLIER
FUNCTIONS
AND SCOPE OF DOWNLOADED DATA
PERIOD
OF OPERATION
Necessary
cookies
Controller
The
operation of these files is necessary for the proper functioning
of the App, so you can not disable them. Thanks to these files
(collecting, m.in. the IP number of your device), it is possible,
m.in. to inform you about cookies operating on the App
most
of the necessary cookies are session cookies, but some remain on
your device for a period of [
...]
months or until they are deleted
Google
Analytics
Google
This
tool allows you to collect statistical data on how users use the
App, m.in. the number of visits, the duration of visits, the
search engine used, location. The collected data helps to improve
the App and make it more friendly to customers.
up
to 2 years or until they are removed (whichever occurs first)
Facebook
Pixel
Facebook
This
tool also allows you to determine that you have visited the App,
to direct ads displayed on Facebook and Instagram social networks
to you and measure their effectiveness.
up
to 3 months or until they are removed (whichever occurs first)
[]
[]
[]
[]

  1. Through most used browsers, you can check whether cookies have been installed on your end device, as well as delete installed cookies and block them from being installed by the App in the future. Disabling or limiting the use of cookies may, however, cause quite serious difficulties in using the App, e.g. in the form of the need to log in to each subpage, a longer loading period of the App’s restrictions on the use of certain functionalities.
Final provisions
To the extent not regulated by the Policy, generally applicable provisions on the protection of personal data shall apply.

This policy is effective from 22/11/2023.

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