UPDATED ON Dec 31, 2019
Scope and Consent
This policy describes the ways Boolean, Inc. collect, store, use and protect Personal Data. The purpose of this policy is to ensure that Boolwallet complies with applicable United States (US) federal and state regulations, and European Union (hereinafter, “EU”) data protection laws such as the General Data Protection Regulation (hereinafter, “GDPR”). Services of boolwallet include merchant processing services, products, and any other features, technologies or functionalities (hereinafter: “Services”) offered by Boolean, Inc.
There are five types of data subjects whose personal data we may process:
- Visitors of our websites (Boowallet.com);
- Users that sign up for our Services;
- Users that interfaced with Boolwallet through any third parties cooperate with Boolean, Inc.
- Users that have downloaded and installed either the Boolwallet or Copay app on their mobile device;
- Users who indirectly interface with Boolwallet when requesting a cryptocurrency withdrawal via other users that are using Services of Boolwallet.
What is “personally identifiable information?”
“Personally Identifiable Information” (hereinafter: “Personal Data”) is any information that can be directly associated with a specific person and can be used to identify that person. A prime example of identifiable information is a person’s name.
What kind of personal data do we collect?
The Personal Data we collect depends on the type of user:
- Visitors: We may collect the following Personal Data for visitors of our websites (https://www.boolwallet.com):
- IP address
- Email address (e.g. when you subscribe to our blog or signed up with email)
- Phone number (e.g. when you contact our sales team or signed up with phone number)
- Name (e.g. when you submit a support request)
We may collect information about a visitor’s computer or other access devices for fraud prevention purposes.
- Users: For wallet users, Boolwallet collects the following Personal Data:
- Email address
- Phone number
- Mobile device information and state
- Users from any third parties that use Boolwallet’s service:
- Email address
- Phone number
- Mobile device information and state
Sensitive or special categories of personal data
Boolwallet does not process any sensitive personal information, such as religion, race, ethnicity and/or political views.
Why we collect personal information
Our primary purpose for collecting Personal Data is to provide you with a secure, smooth, efficient, and customized experience. We may use your Personal Data to:
- comply with applicable laws and regulations;
- provide the Boolwallet Services and customer support you request;
- process transactions and send notices about your transactions;
- resolve disputes, collect fees, and troubleshoot problems;
- deliver targeted marketing, service update notices, and promotional offers based on your communication preferences;
- compare information for accuracy and verify it with third parties.
How we protect and store personal information
We take security of data very seriously. We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Data only for those employees who require it to fulfill their job responsibilities.
- IT Security Policy: This policy describes how we store and process your Personal Data on our servers in the United States and elsewhere in the world where Boolwallet facilities are located. It also describes how we protect it by maintaining physical, electronic and procedural safeguards in compliance with applicable US federal and state regulations, and EU data protection laws.
- Incident Response Policy: This policy describes our response to an information security incident.
- Data Breach Policy: This policy specifically describes what steps will be taken by us in case of a data breach. This includes notifying the supervisory authorities and the affected data subjects when required.
- Business Continuity and Disaster Recovery Policy: This policy describes how we recover from a disaster and what steps will be taken to continue or resume routine business operations.
We are a regulated Financial Institution in China and per the applicable Bank Secrecy Act provisions, we will retain Personal Data that has been obtained as a part of our Customer Identification Program for a period of 5 years after an account has been closed or became dormant.
How we share personal data with third parties
We may share your Personal Data with:
- Other Boolwallet entities, in order to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about our products, services and communications;
- Service providers under contract who help with our business operations. We will make sure that these third parties have appropriate internal controls in place to protect any Personal Data that might be transferred;
- In cases of suspected fraud or in connection with an ongoing investigation, we may share certain shopper information with our merchants.
Please note that these third parties may be in other countries where the laws on processing Personal Data may be less stringent than in your country. We deploy the following safeguards if we transfer Personal Data originating from the European Union or Switzerland to other countries not deemed adequate under applicable data protection law:
E.U.-U.S. Privacy Shield
Boolean, Inc complies with the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the transfer of personal data from the EEA to the US (“Personal Data”). Boolean, Inc has self-certified to the US Department of Commerce declared its commitment to adhere to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement, and Liability (the “Principles”). For more information about the Privacy Shield Program, please visit: www.privacyshield.gov/welcome.
Boolean, Inc’s self-certification to the Privacy Shield is subject to the investigatory and enforcement authority of the Federal Trade Commission.
Disclosure and Accountability for Onward Transfers
Consistent with the Principles, Boolwallet will only disclose an individual’s nonpublic personal information to third parties under one or more of the following conditions:
- The disclosure is to a third party providing services to Boolean, Inc, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, Boolean, Inc remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Boolean, Inc proves that it is not responsible for the matter giving rise to the damage;
- With the individual’s permission to make the disclosure;
- Where required to the extent necessary to meet a legal obligation to which Boolean, Inc is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.
- Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.
Recourse, Enforcement, Liability
Under certain circumstances detailed in the Privacy Shield, Data Subjects may be able to invoke binding arbitration before the Privacy Shield Panel, when other dispute resolution procedures have been exhausted. For additional information, please visit: www.privacyshield.gov/article?id=How-to-Submit-a-Complaint.
EU Model Clauses
Boolwallet offers EU Model Clauses, also known as Standard Contractual Clauses, to meet the adequacy and security requirements for our merchants or third parties that operate in the European Union. Please contact Boolwallet (email@example.com) if you wish to use this option.
Boolwallet shall be liable for the acts and omissions of any third parties with whom we share Personal Data unless Boolwallet proves that it is not responsible for the event giving rise to the damage.
How data subjects can access or change their personal data
Individuals located in the European Union have statutory rights in relation to their Personal Data. Subject to any exemptions provided by law, you may have the right to request access to Information, as well as to seek to update, delete, correct, or restrict the processing of this Personal Data. If you are located in the European Union and would like to exercise the right of access, you can make a request via our support team by send an email to: firstname.lastname@example.org. If you choose to delete your Boolwallet account, we will mark your account in our database as “Closed”. We will retain the information on the account in line with the data retention principles as outlined in Data retention.
We do not sell your Personal Data to third parties for their marketing purposes without your explicit consent. We may combine your information with information we collect from other companies and use it to improve and personalize the Boolwallet Services, content and experience.
If you have any question or believe we maintain your Personal Data within the scope of the GDPR, or just simply do not comply with your local laws or regulation, you may contact our support team by email: email@example.com.
What are cookies?
A cookie is a small piece of data that a website asks your browser to store on your computer or mobile device. The cookie allows the website to “remember” your actions or preferences over time. Most browsers support cookies, but you can set your browser to decline them and can delete them whenever you like.
What type of cookies do we use?
We send a “session cookie” to your computer when you log in to your account or otherwise use the Boolwallet Services. This type of cookie helps us to recognize you if you visit multiple pages on our site during the same session, so that we do not need to ask you for your password on each page. Once you logout or close your browser, this cookie expires and no longer has any effect.
We also use longer-lasting cookies for other purposes such as to display your email address on our login page, so that you don’t need to retype the email address each time you login to your account.
We encode our cookies so that only we can interpret the information stored in them. You are free to decline our cookies if your browser permits, but doing so may interfere with your use of our website. We may also collect information about your computer or other access device to mitigate risk and for fraud prevention purposes.
You may encounter cookies from third parties when using the Boolwallet Services on websites that we do not control (for example, if you view a web page created by a third party or use an application developed by a third party, there may be a cookie placed by that web page or application.)
Managing your cookie settings
You can manage cookies through the settings of your Internet browser. You can have the browser notify you when you receive a new cookie, delete individual cookies or delete all cookies. Please note that, if you choose to delete Boolwallet cookies, your access to some functionalities and areas of our website may be degraded or restricted.
Permission of personal Mobile Devices
In order to provide better experience and convenient service, while using Boolwallet, some necessary permission of using certain functions on mobile devices is needed. When the first time open Boolwallet, there are several permissions required listed below:
- Mobile Device identity (This is for your account securities)
- Mobile Device status (This is needed for Media function)
- Voice recording (Used for voice message)
- Camera (This is for scanning function and photo taking)
All those permissions are general requirement of using application, we do not collect any personal data from those function. You can also turn all those permissions down based on your preference, if you have already approved those permissions, you can go to mobile settings to turn them off. We do not recommend you to turn those permissions down, this may lead to some features not functioning in the Boolwallet.
Changes to this policy
Questions about privacy? Please contact us.