If you are a data subject in the United Kingdom (“UK”) or any part of the European Economic Area (“EEA”) and/or in any case Regulation (EU) 2016/679 applies (“GDPR”), please also see paragraph 10 below entitled Additional Disclosures for People in Europe.
1. PRODUCT OVERVIEW
Upon setting-up your Comet wallet, you will be assigned a private key and public digital wallet address. We are not provided with a copy of your private key and we are unable to recover any private key in the event it is lost.
2. THE INFORMATION WE COLLECT ABOUT YOU
We limit what personal data is required to use Comet. While you may voluntarily provide to us certain information that includes personal data like contact information and communications as described below, such personal data is not required to use the Service. However, in order to provide the Service, there is limited information, which may include personal data that must be collected automatically. Please read the below carefully to understand what may be collected and how it is used.
2.1 Information You May Voluntarily Provide
(a) Contact Information, including name or email address when you reach out to us for support or other communications; and
(b) Content, including any content in communications with us that you provide.
2.2 Information We Collect Automatically
When you use Comet as the digital wallet for a given transaction on the Blockchain, we will process limited information automatically including:
(a) Use Data, including data about analytic data use, browser type, operating system, time stamps, and your referring and exiting pages;
(b) Log Files, which are files that record events that occur in connection with your use of the Services; and
(c) Transaction Data, including information related to transactions such as public wallet addresses.
Use Data and Log Files, and to the extent you share them with us, Contact Information and Content are used to maintain, improve and enhance our Service and develop new products, prevent fraud, for analytics, and to generally comply with applicable laws.
Transaction Data are not stored by Safe Haven, and is only used as necessary to forward data to the Blockchain when you engage in a transaction using your Comet wallet.
We also collect non-identifying aggregate information which we may use for the exclusive purpose of improving the security, compatibility or interoperability of the Comet software.
3. HOW WE USE THE INFORMATION WE COLLECT ABOUT YOU
We use the information we collect from and about you for the following business purposes:
(a) To provide, maintain, improve, and enhance our Service;
(b) To understand and analyze how our Service is used and develop new products, services, features, and functionality;
(c) To communicate with you, provide you with updates and other information relating to our Service, provide information that you request, respond to comments and questions, and otherwise provide customer support;
(d) To find and prevent fraud, and respond to trust and safety issues that may arise; and
(e) For compliance purposes, including enforcing our legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
For information on your rights and choices regarding how we use personal data about you, please see the paragraph 5 below entitled Your Rights and Choices.
4. SHARING OF PERSONAL AND NON-PERSONAL DATA
(a) Third Parties Providing Services On Our Behalf. In order to make various features, services and materials available to you through the Service, perform analytics, host the Service, and respond to your requests and inquiries, we may share your information you provide with third parties that perform functions on our behalf;
(b) Blockchain Platform. When you engage in a transaction that is recorded on the Blockchain, certain information that may be considered personal data related to that transaction will be published on the blockchain and may be accessible to third parties not controlled by Safe Haven, and will be recorded on the Blockchain permanently across a wide network of computer systems and be incapable of deletion. Many blockchains are open to forensic analysis which can lead to deanonymization and the unintentional revelation of personal data, especially when blockchain data is combined with other data;
(c) Business Transfers. We share information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition, business combination of all or any portion of our business or assets, change of control, or a transfer of all or a portion of our business or assets to another third party (including in the case of any bankruptcy proceeding); and
If GDPR applies to you, you can also contact us for additional information on subjects for which we share your personal data.
5. YOUR RIGHTS AND CHOICES
5.1 Uninstalling Your Comet Wallet
You may uninstall your Comet wallet browser extension at any time. Please note that any transactions made on the Blockchain while using your Comet wallet are permanently recorded on the Blockchain, and deleting your Comet wallet will have no effect on the Blockchain ledger or any digital assets still associated with your Comet wallet following any uninstallation; and
You can opt-out of receiving promotional emails from us at any time by following the removal instructions in the specific communication that you receive, or emailing us at the email address provided in paragraph 9 below entitled Contact Us with the word UNSUBSCRIBE in the subject field of the email. Note that your opt out is limited to the email address used.
6. DATA SECURITY
Safe Haven uses reasonable security measures designed to prevent unauthorized intrusion to the Service and the alteration, acquisition or misuse of personal data. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of information about you, collected from you, or submitted by you. We will not be responsible for loss, corruption or unauthorized acquisition or misuse of information that you provide or that we collect through the Service that is stored by us or our service providers, or for any damages resulting from such loss, corruption or unauthorized acquisition or misuse.
7. CHILDREN’S PRIVACY
Comet is not directed towards, nor was it designed to attract the attention of any children, and we do not knowingly collect or maintain personal data from any person under the age of thirteen.
9. CONTACT US
10. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN EUROPE
GDPR and data protection laws in Europe distinguish between organizations that process personal data for their own purposes (known as “controllers”) and organizations that process personal data on behalf of other organizations (known as “processors”). Safe Haven acts as a controller with respect to personal data collected as you interact with our Service.
10.2 Lawful Basis for Processing
GDPR and data protection laws in Europe require a “lawful basis” for processing personal data. Our lawful bases include the following:
(b) To pursue our legitimate interests. We rely on legitimate interests pursued by us to process your information, including understanding how our Service is functioning, improving our Service, developing new products and preventing fraud. Information we will use include Use Data and Log Data. Where we solely rely on legitimate interest, we carry out a balancing test to weight our interests against your right to personal data protection, our processing will never override your fundamental rights and freedoms, and you can always exercise your right to object to such processing;
(c) Consent. In certain situations where you provide us with consent, we may process your information; and
(d) To comply with law. In limited circumstances, we may process information in order to comply with legal obligations. To the extent we have received such information from third parties where we have agreed to contractual requirements such as standard contractual clauses, we will use our reasonable efforts to dispute making such disclosures unless legally required to do so.
10.3 Retention of Information
Once the purpose of processing is fulfilled, we retain personal data for no longer than the applicable statutory limitation period. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements. We will delete or anonymize personal data once the applicable retention period has expired.
Note that blockchains are designed by default to permanently record information across a wide network of computer systems; therefore, while we commit not to store immediately identifiable personal data, some pseudonymized information will be stored across the Blockchain and therefore it will not be possible to delete such information.
10.4 Data Transfer
If GDPR applies and your data is transferred outside UK or the EEA to the United States or any other country, we will transfer your personal data subject to appropriate safeguards, such as an adequacy decision by the European Commission on the basis of article 45 the GDPR, or Standard Contractual Clauses as provided from time to time by the European Commission. You can receive additional information on where your data is transferred, and which are the appropriate safeguards by contacting us.
10.5 Your Data Subject Rights
10.5.1 Your Rights to Your Information
If you are a data subject according to the GDPR, subject to certain conditions you have the right to:
- access, rectify, or erase any personal data we process about you;
- data portability, asking us to transfer to any third party at your choice
- restrict or object to our processing of personal data we process about you; and
- where applicable, withdraw your consent at any time for any data processing.
10.5.2 How to Exercise Your Rights
You may exercise your rights by submitting a written request to us at the email address set out in paragraph 9 above entitled Contact Us. We will respond to your request within thirty (30) days. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions.
10.5.3 When Information May Be Retained
Please note that we retain information as necessary to fulfil the purposes for which it was collected, and may continue to retain and use information even after a data subject request for purposes including to perform under the contract, as necessary to comply with our legal obligations, resolve disputes, prevent fraud, and enforce our agreements.
If you have a complaint about our use of your personal data or response to your requests regarding your personal data, you may submit a complaint to the Data Protection Supervisory Authority in your jurisdiction. We would, however, appreciate the opportunity to address your concerns before you approach a data protection regulator, and would welcome you directing an inquiry first to us.