Privacy Policy

PRIVACY AND COOKIE NOTICE
(Last updated April 2022) 

1.    INTRODUCTION

Who are we?

We are SafeMoon LLC, of 2100 Pleasant Grove Blvd, Pleasant Grove, UT 84062, United States. Together with our affiliated entities, SafeMoon US LLC, Safemoom Aproovals LLC and SafeMoon Media Group Limited, we are referred to in this notice as “SafeMoon”, “we” or “us”.

What’s this notice about?

This notice explains how we process your data in relation to:

●       the SafeMoon Wallet mobile application (the “App”);

●       our website, which can be accessed here: www.safemoon.com (the “Website”);

●       our online shop, which can be accessed here: https://capsule.safemoon.com (the “Online Shop”); and

●       our other products and services,

(together, the “SafeMoon Products and Services”).

We update this notice from time to time, so please check back in on a regular basis.

To the extent data is associated with an identified or identifiable natural person and is protected as personal data or similar designation under applicable data protection or privacy law, it is referred to in this notice as "personal data" and/or “personal information”.

Please note that the SafeMoon Products and Services may link to or mention websites or services that are not operated by us, and you should refer to the privacy policies on those third party websites or services to understand how your personal data is being used.

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: GDPRAdministrator@safemoon.ltd

If we can’t resolve your issue, you can also get in touch with the local data protection or consumer protection authority in your country (as applicable for your jurisdiction). If you live in the UK, you can get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns

(or if you live in a European country other than the UK, you can submit a complaint to the supervisory authority in your country).

 

 

2.    YOUR DATA AND HOW WE USE IT

What data we collect from or about you

How we use it, and legal bases for processing under applicable law

Sources and recipients

Services and Products Data

Information that we collect about you in order to provide certain services and products via the App, including:

We process this information: (a) to respond to your enquiries; (b) to provide our services and products via the App; and (c) to understand how you use the App in order to improve it.

Sources

We collect this personal data from you.

Recipients

 

●      Mnemonic phrase, unique device password, username and any additional optional information (such as a profile picture or avatar) you provide when creating a wallet on the App

●      Information provided when making transactions via the App (including without limitation the fiat and Safe Moon account balances)

●      Information relating to previous transactions made via the App (including without limitation "transactionHash", "blockHash", "blockNumber", "status", "type”, "nonce", "transactionIndex", "from", "to", "amount", "tokenSymbol", "createdAt" and "gasUsed")

●      FCM tokens

●      Information relating to your device

●      Any personal data you provide to us in order for us to provide our services and products to you (including information you send us as part of your

enquiries)

Legal basis for this processing

●       (a) and (c): Our legitimate interests of improving the services and products provided via the App.

●       (b): Entering or performing contracts with you.

More information

You may be required to provide us with certain information in order for us to provide certain services and products via the App to you.

We use Zendesk, Inc. (“Zendesk”) for logging tickets when bugs are reported. You can view Zendesk's privacy notice here: Privacy Policy (zendesk.co.uk).

We use Wyre Payments, Inc. (“Wyre”) to process any transactions made via the App. You can view Wyre’s privacy notice here: https://www.sendwyre.com/privacy

-policy/

SafeMoon Shop Data

Information that we collect about you in relation to the Online Shop:

●      Name

●      Contact information (including email address and telephone number)

●      Billing address and delivery address

●      Information relating to your orders (e.g. products purchased)

●      Payment information

●      Any correspondence exchanged between you and SafeMoon in relation to your orders

We process this information: (a) to process and fulfil orders that you make on the Online Shop; (b) for our own internal administrative purposes (e.g. accounting and record-keeping); and (c) to improve the services that we provide via the Online Shop.

Legal basis for this processing

●       (a): Entering or performing contracts with you (including our Online Shop’s Terms and Conditions, which can be accessed here: https://capsule.safemoon.com/ pages/terms-of-service).

●       (b): Our legitimate interests of promoting the success of our business and our legal obligations.

●       (c): Our legitimate interests of improving the Online Shop.

Sources

We collect this personal data from you and Shopify, Inc. (“Shopify”).

Recipients

We use Shopify as our

e-commerce platform. You can view Shopify's privacy notice here: Shopify Privacy Policy.

Marketing Data

Information that we collect in order to make suggestions and recommendations to you about: (i) news and updates relating to us, our partners or the SafeMoon Products and Services; (ii) content,

Legal basis for this processing

If required by law, we rely upon your consent in order for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us.

Sources

We collect this personal data from you.

Recipients N/A

 

and products and services that may interest you; and (iii) other promotional activity and events we think may be of interest, including:

●      Email address

●           Other    information    collected and  clearly  identifiable  to  you at the point of your signing up to our marketing communications

In some instances (such as with some of our existing customers) the law may permit us to process your personal data in order to send marketing communications on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the SafeMoon Products and Services. If the information is not of interest for you, you can opt-out at any time by letting us know, including by emailing us.

 

Waiting List Data

Information that we collect about you when you sign-up to being notified of when a new service or product is available, or to joining a waiting list for a new service or product:

●      Full name

●      Email address

●      Country of residence

●      Any personal data you provide to us in response to questions that we ask you in relation to the new service or product, the sign-up process or SafeMoon

We process this information: (a) to enable you to register your interest in the new service or product and receive updates on the new service or product; and (b) to collect your feedback on the new product or service, and SafeMoon.

Legal basis for this processing

●       (a): Your consent

●       (b): Our legitimate interests of improving our services and products

Sources

We collect this personal data from you.

Recipients N/A

Survey Data

Information that we collect about you when you respond to our surveys:

●      Full name

●      Email address

●      Any personal data you provide to us in response to questions in our surveys

We process this information to understand your thoughts on our services and products.

Legal basis for this processing Our legitimate interests of

improving our services or products.

Sources

We collect this personal data from you.

Recipients N/A

Technical Data

Information that we collect about the device on which you are using the SafeMoon Products and Services in order to tailor the delivery of the relevant SafeMoon Products and Services, including:

●      Device type

●      Geolocation data

We process this information: (a) to improve the delivery of the SafeMoon Products and Services; and (b) to understand how you use the SafeMoon Products and Services in order to improve them.

Legal basis for this processing

●       (a) and (b): Our legitimate interests of improving the SafeMoon Products and Services.

Sources

We use Google’s services to collect this personal data from you when you use the SafeMoon Products and Services.

Recipients

Google in the USA collects and processes this information on our behalf.

 

 

 

 

Enquiry Data

Information that we collect to enable us to collect, record and properly respond to your submissions, enquiries and support requests in relation to the SafeMoon Products and Services and our marketing materials:

●      Name

●      Email address

●      Any personal data you provide to us in your submissions, enquiries and support requests

We process this information: (a) to ensure that the Website functions properly to support our efforts to provide you with the best experience when using the SafeMoon Products and Services;

(b) to improve the quality of the SafeMoon Products and Services, and provide a better experience to you; and (c) to identify and correct any bugs in the SafeMoon Products and Services.

Legal basis for this processing

Our legitimate interests of improving the SafeMoon Products and Services.

Sources

We collect this personal data from you.

Recipients N/A

 

 

3.    COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Cookies, pixels and other technologies store and access data on your device to help websites and apps work. This table explains their purpose, how long they last, and who else can access their data. We get your consent to use them unless they’re essential for the SafeMoon Products and Services.

Most browsers allow control over cookies, for more information: Google Chrome | Microsoft Edge | Mozilla Firefox | Microsoft Internet Explorer | Opera | Apple Safari.

Cookie/data

Duration

Purpose

Access

_ga

_gat

_gid

Up to 8 hours

To collect information about how visitors interact with the SafeMoon Products and Services and generate reports to identify problems, understand how visitors use the SafeMoon Products and Services, and improve them.

We use Google Analytics to set these cookies.

You can find out more about how Google uses data by clicking here.

You can opt-out here: Google Analytics.

 

 

4.    DATA RETENTION AND DISCLOSURE

Data retention

We hold personal data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of unauthorised access, and legal requirements.

 

 

Disclosure

Other than as set out above, we may disclose your personal data:

●      Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for

 

 

example, we may share personal data with our professional advisors, investigators, or credit reference agencies).

●      With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this notice.

●      If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

 

 

5.    EUROPEAN ECONOMIC AREA AND UNITED KINGDOM PRIVACY RIGHTS

 

Individuals located in certain countries, including the European Economic Area (EEA) and the United Kingdom, have certain statutory rights under the General Data Protection Regulation (GDPR) in relation to their personal data.

 

Data controller

Where we decide the means or purpose of processing your personal data, we are the “data controller."

 

Storage & Transfers

Where we use data processors outside the UK and European Economic Area, and transfer personal data to a country which does not provide an adequate level of protection, we use contracts which give personal data the same protection it has in Europe and the UK. For more information drop us a line using the contact details at the “How do you contact us” section under the “Introduction” heading above.

 

Data Subject Rights

You have the following rights, although these rights may be limited in some circumstances:

●      Ask us to send a copy of your personal data to you or someone else

●      Ask us to restrict, stop processing, or delete your personal data

●      Object to our processing of your personal data

●      Object to use of your personal data for direct marketing purposes

●      Ask us to correct inaccuracies in your personal data

If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address below.

 

Contacting Us

Please see the section entitled “How do you contact us?” under the “Introduction” heading above.

 

 

 

 

 

Right to Know

You may have the right to request, up to twice in a 12-month period, to see the following information about the personal information we have collected about you during the past 12 months:

•                 The categories and specific pieces of personal information we have collected about you;

•                 The categories of sources from which we collected the personal information;

 

•                 The business or commercial purpose for which we collected the personal information;

•                 The categories of third parties with whom we shared the personal information; and

 

•                 The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose.

To request the specific pieces of personal information we have collected about you, see the “How do you contact us” section under the “Introduction” heading above.

California law also gives you the right to ask if we disclose your personal information to third parties for their direct marketing purposes (we do not). It also gives you the right to ask if we sell your personal information to third parties (we do not, and have not done so in the past), and if we did (which we don’t), you’d have the right to opt out of such sales.

Additional information about the categories of information we collect and its usage and sharing are located under the sections entitled “Your Data and How We Use It”, “Cookies, Analytics and Similar Technologies”, and “Data Retention and Disclosure”, above.

Right of Deletion

You have the right to ask us to delete the personal information we have collected from you, subject to exceptions the law provides. Please note that you may no longer be able to use the SafeMoon Products and Services if you delete your personal information.

Right of

Non-Discriminat ion

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

How to Exercise Your Rights

If you live in California and would like to send us a request to exercise one of your above rights, you may do so by contacting us as indicated in the “How do you contact us” section under the “Introduction” heading above.

To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Exceptions to These Rights

California law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable.