Privacy policy

The privacy policy describes the rules and principles for the collection and processing of Personal Data of Users by the company HASHER COMPANY OÜ, Code: 16917232, registered at the address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152.

The Privacy Policy (“Policy”) governs the collection, processing, storage and transfer of Personal Data, defines the legal basis for the processing of Personal Data and sets out the rights of Users in accordance with applicable data protection and privacy laws.

References to the words “we”, “our” or “us” or similar words in content mean the company HASHER COMPANY OÜ (“HASHER WALLET”), depending on the context of the Policy.

References to the words “you”, “you” or “your” or similar words in content mean Users of the Platform.

We are committed to protecting the privacy and security of the Personal Information you provide to us, and we will only collect and use your information in the ways described in this Policy.

Your decision to use the HASHER WALLET Application and provide your Personal Information is voluntary. You may choose not to provide the requested information, but this may limit the Services that the Platform provides.

  1. TERMS
    We introduce and denote some terms with capital letters. Their use in the text of the Policy means that they have a special meaning, which is defined in the description of such terms. Section 1 of the Policy contains definitions of certain capitalised terms.
    1. Personal data information that identifies you as a specific person or can be identified to interact with you.
    2. User - an identifiable and non-identifiable person who interacts with the Application
    3. Application - – a mobile application, software modules and code that belong to HASHER WALLET. The content of the Application is protected by copyright, trademark laws, as well as other rights related to intellectual property and unfair competition laws.
    4. EDPB (European Data Protection Board) - European Data Protection Board.
    5. CCPA (California Consumer Privacy Act) - a California statute designed to enhance privacy rights and consumer protection for California and the United States residents.
    6. GDPR General Data Protection Regulation (“GDPR”), an act, which applies to regulate the processing of personal data since May 25, 2018.
  2. TYPES OF PERSONAL DATA WE COLLECT
    1. HASHER WALLET can guarantee Users a high level of confidentiality, as it tries to minimize the amount of Personal Data it collects.We do not collect or process: first names, last names, addresses, telephone numbers, email addresses, payment card or bank account data, geolocation data, or special categories of Users’ Personal data, such as information about race or ethnicity, religious or philosophical beliefs, sexuality and orientation, political opinions, trade union membership, health information, and genetic and biometric data. We also do not collect information about Users' criminal records or offences.
    2. Personal data collected automatically. Some information about Users is automatically collected from the mobile device when they interact with the Application.
      We may collect Personal data such as IP address to understand the country from which you are connecting when using the Application, time zone and language settings, or information about the device you use to access the Application.
    3. Personal data collected voluntarily at the initiative of Users. Data that you provide when contacting the Application support service, namely when communicating using Communication Tools.
      We collect IDs from Users that are used to contact you and/or provide services.
  3. PERSONAL DATA COLLECTION METHODS
    1. We collect identifiable and non-identifiable Users’ Personal data in the following ways:
      1. When the User interacts with the Application.
      2. During analytics and advertising campaigns using advertising and analytics services, such as Google ADS, Google Analytics, Facebook ADS, or Facebook Analytics, the list is not exhaustive.
  4. AGE RESTRICTION FOR APP USERS
    1. The Application is not intended for use by minors under the age of 18. HASHER WALLET does not knowingly collect information from minors under the age of 18 and supposes that children of any age should obtain the consent of their legal guardians before providing any Personal data.
    2. If you suppose we have incorrectly or unintentionally collected the Personal data of minors under 16, please notify us at support@hasherwallet.io so that we can remove that data.
  5. PURPOSES OF USING PERSONAL DATA
    1. We process Users' Personal data for the purposes set out in the Policy:
      1. to provide Application services;
      2. to develop, provide, improve, update, or correct errors in the Application and/or expand services;
      3. to ensure internal quality and security control, protection against fraudulent or illegal activities;
      4. to respond to inquiries and complaints, as well as communications with Users;
      5. to enforce the law, including protecting our rights or the rights of third parties.
  6. EMAILING AND PROMO
    1. HASHER WALLET does not conduct advertising mailings or send commercial or non-commercial offers to Users. We do not send confirmations about the use of the Application services, or notifications about changes to this Policy. You can find the amended version of the Policy in the Application.
  7. PERIOD FOR RETAINING PERSONAL DATA
    1. HASHER WALLET has the right to use Users’ Personal data only for the purposes specified in Section 5 of the Policy.
    2. By providing access to Personal data, you consent to the transfer, storage and processing of Personal data. In turn, we undertake to take all necessary measures to ensure that Personal data is processed in compliance with security rules and in accordance with the provisions of the Policy.
    3. Personal data is stored until the User requests its removal. In this case, Personal data will be deleted within 60 (sixty) days from the date of registration of the request for deletion and/or within 3 (three) years from the date of receipt of such data, if such storage is necessary for recording statistical, financial, corporate and commercial data.
    4. We may retain Personal data for as long as necessary to provide the Services or fulfil obligations, resolve disputes, prevent misuse, and enforce agreements.
    5. The Personal data that we process and store is and remains the property of Users. In case of changes in Personal data that are necessary for the correct provision/reception of Services, Users are responsible for notifying us of such changes.
  8. DATA SECURITY AND DPO
    1. We make every effort to ensure that the storage of Personal data complies, to the extent possible, with the GDPR and CCPA. According to Article 32 of the GDPR, HASHER WALLET takes measures to ensure the security of storing Personal data, such as anonymization and encryption, ensuring confidentiality, integrity, availability and sustainability of processing services, and testing the effectiveness of protective measures.
    2. To improve control over the storage and security of data, HASHER WALLET may engage a Data Protection Officer (hereinafter “DPO”), who is responsible for compliance with the law on the protection of personal data, in accordance with articles 37, 38, 39, GDPR, namely to perform the following tasks:
      1. inform the controller and processor about obligations under the data protection regulation;
      2. monitor compliance with the norms and requirements of the regulations;
      3. represent in Supervisory authority;
      4. advise in any situation affecting the regulation;
      5. accept and consider requests and complaints from Users to protect their rights, in accordance with Section 11 of the Policy.
    3. We implement measures for the secure storage of collected Personal data on servers and hosting. We also provide AES-192-CBC data encryption, md5 hashing and anonymization. Access to the Application is encrypted using standard transport layer security (“TLS”) technology. We also use strict HTTPS transport security.
    4. Notwithstanding data storage security measures were implemented, HASHER WALLET cannot fully guarantee protection against access, disclosure, alteration or deletion of data as a result of events, including, but not limited to, hardware or software failure or unauthorised use. HASHER WALLET is not responsible for the leakage, unauthorised collection and disclosure, resale or misuse of Personal data by third parties.
  9. INTERNATIONAL TRANSFERS OF PERSONAL DATA
    1. HASHER WALLET does not transfer Users’ Personal data to any third parties, but integrates third parties into the Application, with the help of which Users can use the services of the Application. Such third parties may collect, store and use Personal Data of Application Users.
  10. INTEGRATED THIRD-PARTY SERVICES
    1. HASHER WALLET integrates systems and services of third parties into the Application to provide services to Users. In certain situations, such third parties collect and process Personal data of Application Users. All Personal data provided by the User to third parties is provided only with the User’s personal consent to such transfer and processing, and, exclusively, in accordance with the Privacy policies and Terms of Use of such third parties. The list of integrated third parties and links to their services are posted in the Application.
    2. HASHER WALLET does not control third-party services that may be hosted on the Application. Third-party services may place their own cookies or other files on your device, collect data, or solicit personal information from you. Before using third-party services that are hosted in the Application, we recommend that you read the Privacy policy of the third-party services that you use in the Application.
    3. The fact that we integrate third-party services into the Application does not constitute a confirmation of our connection with it, as well a confirmation that their Privacy policies and/or information security policies comply with the HASHER WALLET Policy.
  11. USER RIGHTS
    1. Access right. Privacy Policy lists the Users’ Personal data that we collect and process. The User may contact us by support@hasherwallet.io tto request access to the Personal data we hold, in accordance with Article 15 General Data Protection Regulation.
    2. Right to rectification. The User has the right to update, correct, and supplement his Personal data. You may contact us at support@hasherwallet.io to update, correct and/or change your Personal data, in accordance with Article 16 General Data Protection Regulation.
    3. Right to transfer. The User may request the transfer of Personal data to third parties, in accordance with Article 20 General Data Protection Regulation.
    4. Right to be forgotten. The User has the right to delete Personal data about himself in accordance with Article 17 General Data Protection Regulation. In that case, Personal data will be permanently deleted.
    5. Right to object. The User has the right to object to the processing of Personal data at any time, in accordance with Article 21 General Data Protection Regulation.
    6. Right to withdraw consent to data processing. At any time the User has the right to withdraw their consent to the processing of Personal data that was provided to us. In case of withdrawal of consent to processing, some functions of the Application may not be available.
    7. Right not to be subject to automated decision-making in individual cases, including profiling. The User has the right not to be subject to a decision based solely on automated processing, including profiling, which gives rise to its legal consequences, according to Article 22 General Data Protection Regulation.
    8. HASHER WALLET will use commercially reasonable efforts to comply with Users' deletion requests, but certain information will be retained within the Application. In addition, the rights described above may be limited, for example, if fulfilling your request would result in disclosure of another User's Personal data, or if you ask us to delete information that we are required to keep by law, or if we have a legitimate interest in preservation (for example, for fraud prevention purposes).
    9. Your Personal data may remain in our archives, and information you update or delete may be retained for our administrative purposes to the extent permitted by law. We will not delete information that you have posted publicly using the Application. Please be aware that neither Users nor HASHER WALLET can delete all copies of information that has previously been shared with others.
  12. ADDITIONAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
    1. This Supplementary California Privacy Notice applies only to California residents. It applies to Personal data that we collect on the Application or through other means and resources, such as information collected offline, in person or by phone, on freelance exchanges or social media.
    2. CPRA requires us to disclose information about the categories of Consumers’ Personal data we collect in California, the categories of sources and the business or commercial purposes for which the information was collected, and the categories of parties we share the California residents’ Personal data.
    3. CPRA allows you to require that we:
      1. provide you with the categories of Personal data we have collected or disclosed about you in the past twelve (12) months;
      2. provide you with categories of sources we used to collect your Personal data;
      3. explain the business and/or commercial purpose of collecting or processing your Personal data;
      4. restrict the categories of third parties to whom we may share your data;
      5. provide access to and/or a copy of the information we hold about you;
      6. delete your Personal data we have.
  13. CHANGES TO THIS POLICY
    1. We have the right to periodically make changes, update and supplement the Policy to ensure the safety of Personal data and compliance with the requirements of the GDPR/CCPA legislation. All updated versions of this Policy will be posted in the Application. HASHER WALLET does not notify Users about changes to the Policy by means of newsletters.
    2. If you use the Application after HASHER WALLET makes changes to the Privacy Policy, then you agree to the updated version of the Policy.
    3. Our electronic or otherwise stored copies of the Privacy Policy shall be deemed to be the original, complete, valid and enforceable versions of this Policy in effect at the time of your use of the Application.
  14. GUIDELINES
    1. We collect feedback and guidelines about the Application Services for advertising and marketing promotion of the Application. We use this information to respond to your inquiries, improve the Services and the Application, develop new products and features, and attract new Users.
    2. With the Users’ consent, we may publish guidelines that include your Personal data or a link to that. If you need to update or remove your guidelines, please, contact us at: support@hasherwallet.io.
  15. FEEDBACK
    1. For any questions regarding the collection and processing of the User's Personal data, you can contact us at the email address : support@hasherwallet.io.
    2. You also have the right to receive further information about your rights in relation to your Personal data by sending an email to : support@hasherwallet.io.
    3. If you have an unresolved privacy or data use concern that we have not satisfied, any questions or complaints regarding the Application or this Policy, you may contact us by email : support@hasherwallet.io.
  16. CONTACTS
    HASHER COMPANY OÜ
    Code: 16917232
    Address: Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152
    E-mail:     support@hasherwallet.io
    CEO: Morgulets Kostiantyn Viktorovych