KEPLR

Privacy Policy

Effective Date: July 5, 2024

 

 

This Privacy Policy describes how Peklr Inc. (“Keplr”, “we”, “our”, or “us”) collects, uses, shares, and stores the personal information of users of its products (Keplr Browser Extension (the “Extension”), Keplr Web App available at https://wallet.keplr.app (the “Web App”), and Keplr Mobile Application (the “Mobile App”), and its websites (https://keplr.app, https://help.keplr.app) (the “Sites”). This Policy applies to the Sites, applications, products, and services (collectively, “Services”) on or in which it is posted, linked, or referenced.

 

Keplr is committed to protecting the privacy, confidentiality and security of the personal information held by us and complying with personal data protection laws. By downloading and/or using the Services provided by us, you agree to all relevant terms and conditions outlined in this Policy. You also agree to our collection, use, disclosure, and retention of your information as outlined in this Policy.

 

IF YOU DO NOT AGREE WITH THIS POLICY OR OUR TERMS OF USE, YOU MAY NOT USE ANY OF THE SERVICES.

 

Questions or concerns? If you still have any questions or concerns, please contact us at contact@keplr.app.

 

WHAT WE COLLECT

 

Personal Information You Disclose to Us. We gather personal information that you willingly provide to us, either to express your interest in acquiring details about our company or products and Services, to engage with our Services, or when contacting us through different channels.

 

The personal information we collect may include the following:

• Public key(s) on a specified blockchain, and data that is openly available and associated with your public key on chain.

• Offline messages signed by your public key(s).

• Technical data, including your Internet Protocol address, information on the blockchain network used, referring web application(s), and transaction data.

• When Keplr Infra is used as the default RPC/LCD provider in Keplr wallet, your IP address. (IP addresses collection is triggered only when we identify potential DDoS attacks or malicious behavior from monitoring)

• Information we get upon your registration using SSO (Single Sign-On) services, such as Google login or Apple ID login. This may include information such as your name, mobile phone number, gender, date of birth, age, address. Please note that the registration for and the use of SSO services are subject to the corresponding service provider’s privacy policy and terms of use, which are beyond our control.
  • Google's privacy policy regarding its single sign-on service: https://policies.google.com/privacy?hl=en. 
  • Apple’s privacy policy regarding its Sign in with Apple service: https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/.
  • Web3Auth’s privacy policy: https://web3auth.io/docs/legal/privacy-policy

• Non-personal data that does not directly or indirectly reveal your identity or directly relate to an identified individual, such as demographic information, statistics, or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific Website feature.
• Other personal information you provide to us via feedback or customer support, bug report, or otherwise correspond with us.

 

Mobile Application Data. If you use our mobile application(s), we also may collect the following information:

• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's camera (for QR code scanning), Bluetooth (for Ledger connection), storage, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

• Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, Browser type and version, and Internet Protocol (IP) address. This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

 

HOW WE PROCESS AND USE YOUR PERSONAL INFORMATION

We process and use your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. To specify:

• To provide our Services. We may process and use your information to:
  • register you as a new user for our Services pursuant to your request;
  • enable you to access and use our Services;
  • process and complete transactions, and send you related information, including purchase confirmations and invoices;
  • send information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
  • to verify your identity for the purposes of and/or in connection with the provision of our Services to you;
  • perform obligations in the course of or in connection with our provision of the Services requested by you and/or enforce obligations owed to us.
• For analytics and operational purposes. We may process and use information about how you use our Services to better understand how they are being used so we can improve them. We may also process and use your information to manage our business operations and comply with our internal policies and procedures. We may also provide information about how you use our Services to certain clients, as part of the measurement, analytics and business services provided to them.

• To protect our Services. We may process and use your information as part of our efforts to keep our Services safe and secure. These actions can include, but not limited to, restriction from accessing our Services, rate limiting, and permanent blocklisting.

• To respond to user inquiries and request feedback. We may process and use your information to respond to your inquiries, solve any potential issues you may have, or request feedback. We may contact you about your use of our Services.
• For marketing purposes. We may process and use your information to send you marketing and communication information about the Services, promotions, upcoming events, and other news about Services offered by us and our selected partners.

• To comply with appropriate law enforcement. We may use your personal information as deemed necessary or fitting to adhere to relevant laws, lawful requests, and legal procedures, including responding to subpoenas or government authority inquiries.
• Others. We may also process and use your information for any purposes set out in the applicable Terms and Conditions and any other business purposes related to or in connection with the above.

 

We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

 

SHARING OF PERSONAL INFORMATION

We do not share the personal information that you provide us with other organizations without your express consent, except as described in this Privacy Policy. We may disclose personal information to third parties under the following circumstances:

• Provision of Services. We may share or transfer your information where such disclosure is required for the purposes of or in connection with the provision of our Services to you.
• Business Transfers. We may share or transfer your information in connection with or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• Staff, Affiliates and Service Providers. We may share your information with our employees, officers, affiliates, employees and officers of our affiliates, third-party service providers, agents, professional advisors and sub-contractors, insofar as is reasonably necessary to achieve the purposes stated in this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Legal Obligations. We may share your information to comply with legal obligations or otherwise enforce our rights.
• Compliance with Applicable Laws. We may share your information to comply with applicable laws, regulations, codes of practice, guidelines, rules, lawful requests or legal process.

 

THIRD-PARTY LINKS AND WEBSITES

The Services may link to or embed third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications.

 

Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link to a third-party website, service, or application does not imply an endorsement by us. Any data collected by third parties is not covered by this privacy notice. You should review the policies of such third parties and contact them directly to respond to your questions.

 

HOW INFORMATION IS SECURED

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). 

 

When we have no ongoing legitimate business need to process your personal information, we will immediately delete such information.

 

We take reasonable measures to protect your personal information from unauthorized access, use, or disclosure. However, no method of transmission over the internet or electronic storage is 100% secure.

 

DATA PROTECTION OFFICER

We have appointed a data protection officer who is responsible for any questions regarding this Privacy Policy. If you have any questions regarding this Policy, including any inquiries regarding your legal rights, please contact the data privacy manager at contact@keplr.app.

 

YOUR RIGHTS

Withdrawing your consent:  Your consent for the collection, use, processing and/or disclosure of your personal information by us will remain valid unless it is otherwise withdrawn by you. You may withdraw your consent and request us to stop using, processing and/or disclosing your personal information for all or any of the purposes listed above.

 

You may make the above request in writing or via email to our Data Protection Officer (contact details above). We may require reasonable time (depending on the scope of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of consequences of the completion of your request. We shall generally seek to process your request within 30 days of receiving it. Depending on the nature or scope of your withdrawal, please note that we may no longer be able to provide the Services to you – if so, we will notify you before completing the processing of your request.

 

For the avoidance of doubt, the above does not impact our collection, usage, processing and/or disclosure of personal information where the foregoing without consent is permitted or required under applicable laws.

 

Accuracy of your personal information: We generally rely on personal information provided by you (or your authorised representative). To ensure that your personal information is current, complete and accurate, please update us if there are changes to your personal information in the manner below.

 

Reviewing, correcting, deleting, updating and transferring your information: Subject to a reasonable fee, you may request (a) for access to a copy of the personal information which we hold or process about you or information about the ways in which we use, process or disclose your personal information; (b) to correct or update any of your personal information as held or processed by us; or (c) to transfer your personal information to another organization or directly to you.

 

You may make the above requests in writing or via email to our Data Protection Officer (contact details above). We will respond to your request as soon as reasonably possible and generally within 30 days after receipt of your request. Should we be unable to do so, we will inform you within 30 days after receipt of your request of the time by which we will be able to respond to your request. If we are unable to provide you with any personal information or make a correction requested by you, we will inform you of the reasons if we are required to do so.    

 

Addressing questions or comments about your privacy rights: you may email us at contact@keplr.app.

 

INTERNATIONAL TRANSFER

We may transfer, store, process and/or deal with your personal information outside origin of where your personal information is collected. In particular, we may share your personal information with affiliates of Keplr located in the Republic of Korea, the United States, the European Union, Singapore and other countries, and/or to other external third party service providers, as the case maybe.

• While using the Web App, your data may be stored in servers located in the Republic of Korea, the United States, the European Union, and Singapore, owned and operated by Amazon Web Services, Inc., a United States corporation.

• Your data also may be transmitted to servers directly owned and operated by Keplr or affiliates of Keplr.

• Companies in contract with Keplr and/or its affiliates to develop, operate and manage the Services on behalf of Keplr and/or its affiliates may be able to access your information for the purpose of developing and operating the Services.

 

You hereby consent to such international transfers of your personal information. With respect to such transfers, we will comply with applicable data protection and privacy laws.

 

NOTICE FOR EU DATA SUBJECTS

• Data transfers to legal entities in countries outside the European Union (known as third countries) take place as long as:

(i) it is necessary for the purpose of carrying out your orders (e.g., payment and securities orders);

(ii) it is required by law (e.g., reporting obligations under financial regulation);

(iii) or you have granted us your consent.

• The Company has offices outside of the EU and has affiliates and service providers in other countries. Your personal information may be transferred to or from the Republic of Korea, the United States, the European Union, Singapore or other locations outside of your state, province, country, or other governmental jurisdiction where privacy laws may not be as protective as those in your jurisdiction.

 

JURISDICTION-SPECIFIC MATTERS

 

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time by contacting us.

• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.

• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms.

• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.

 

In addition to the rights specified above, you have a right to complain to a supervisory authority.  

 

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time by contacting us.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way

• For investigations and fraud detection and prevention

• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province

• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records

• If the information is publicly available and is specified by the regulations

 

If you are a resident of California, this section applies to you.

If you are a resident of California, you are granted specific rights regarding access to your personal information.

 

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us to contact@keplr.app.

 

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request the removal of unwanted data that you publicly post on the Services. Verification of your identity and request is necessary before any action can be taken. This may entail providing government identification as part of the process. As per California law, you can appoint an authorized agent for requests, requiring a valid power of attorney along with government-issued IDs for both the requester and the agent.

 

CCPA Privacy Notice

California residents can exercise their CCPA rights by reaching out to us at contact@keplr.app.

 

The California Code of Regulations defines a "resident" as:

(1) every individual who is in the State of California for other than a temporary or transitory purpose and

(2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

 

All other individuals are defined as "non-residents."

 

If this definition of "resident" applies to you, we must adhere to certain rights and obligations regarding your personal information.

 

If you are a resident of Virginia, this section applies to you.

If you are a resident of Virginia, you may be granted specific rights regarding access to and use of your personal information.

 

Virginia CDPA Privacy Notice

Under the Virginia Consumer Data Protection Act (CDPA):

 

"Consumer" means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

"Personal data" means any information that is linked or reasonably linkable to an identified or identifiable natural person. "Personal data" does not include de-identified/anonymized data or publicly available information.

 

"Sale of personal data" means the exchange of personal data for monetary consideration.

 

If this definition of "consumer" applies to you, we must adhere to certain rights and obligations regarding your personal data. You can exercise your CDPA rights by reaching out to us at contact@keplr.app. We may request that you provide additional information reasonably necessary to verify your request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request, and may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

 

CHANGES TO THIS PRIVACY POLICY

We may update this Policy at any time. The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

 

GOVERNING LAW

This Privacy Policy shall be governed in all respects by the laws of Singapore.

 

CONTACT US

We welcome any inquiries or comments regarding this Privacy Policy, and you may contact us by emailing us to contact@keplr.app.