June 30, 2022

Privacy Policy

TonSafe is a software service accessible via a mobile device application and a browser service for The Open Network (the "Network") that enables users to (i) self custody digital assets; (ii) access a digital asset browser and link to decentralized applications and decentralized exchanges; (iii) view addresses and information that are part of digital asset networks and broadcast transactions; and (iv) additional functionality as TonSafe may add to the app from time to time (collectively, the "App" or "TonSafe" or "TonSafe Wallet").

This Privacy Policy describes the policies and procedures on how TonSafe (“we,” “our,” or “us”) collects and processes your information in our AppStore or Google Play application “TonSafe“ (the “Application” or the "App") we offer. Please also read TonSafe Wallet's Terms of Service (the "Terms"), which describe the terms under which you use the Services.

Privacy and information protection are core principles on which we base our Application. This Privacy Policy sets out our current policies and commitment to information protection and privacy. According to this, we aim to collect and process only information strictly necessary for our relationship with customers, partners, users of our Application, in order to provide our services.

We make our Privacy Policy available in our Application in its most recent version. Please review it carefully. By accessing and / or using the Application, you acknowledge and confirm that you have read, understood, and agree to this Privacy Policy.

Information We Collect

As the Application is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your personal data to us to use the Application. We will never ask you to share your private keys, "24 Secret Words" or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed or "24 Secret Words". It is important to note that your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. We may collect limited information about you from your devices or from various sources, as described below.

Information You Give Us

We may gain access to some personal information from you when you communicate with us, including your contact information, email address or phone number or social media account (depending on how you contact us). We do not keep records of any such personal data in providing our services. Any services we provide may only require your Wallet address. Some services may require a Telegram account. We do not store or keep any records matching Telegram accounts with Wallet addresses or identities.

Information Automatically Collected

We may automatically collect information about you and your devices when you use the Application, including: (i) information you create through the Application, such as public wallet addresses; (ii) the IP address of the device you use to access the Application; (iii) the type of browser software you are using; (iv) the operating system you are using; (v) the date and time you access or use the Application; and (vi) other non-personally identifiable information.

How We Use The Information

We use the information we collect for the following purposes:

  • To enable you to access and use the Application, and to process and complete transactions, and send you related information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
  • To understand and analyze how you use our Application and develop new products, services, features, and functionality.
  • To communicate with you about promotions, upcoming events, and other news about products and services offered by us.
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
  • To personalize your experience of the Application such as identifying you as a repeat visitor.
  • To facilitate the connection of third-party services or applications.
  • In order to optimize your user experience, we may use your information to operate, maintain, and improve our Application.
  • For compliance purposes, including enforcing our terms of use or other legal rights, or as may be required by applicable laws and regulations.
  • To contract with third-party API providers, including providing customer service, providing advertising or marketing services, providing analytic services.

Information Visible to Others

All transactions you make with TonSafe on The Open Network are permanent, cannot be edited nor deleted, and are visible to anyone using a TON blockchain explorer. Such information includes your wallet address, current balance, transaction times and amounts, destination or originating wallet address of any payment sent or received, and any message (also called comment or memo) that you may choose to post with such transactions. This can be considered an advantage compared to bank accounts which could be forged or modified by bad actors or system failures, however, you should consider privacy implications should you choose to publish your account wallet address along with your identity, or make your identity known to others.

TonSafe PRO Membership

Those joining TonSafe PRO membership will make a membership fee payment in the form of a subscription in TON via Telegram TonRocketBot, from which your public Telegram profile, such as any displayed image, name, username, phone number if made public, will be visible to those managing the TonSafe PRO private members channel. TonSafe does not keep any records of this information, nor your wallet address should you reveal it, outside of the required functionality of the bot and channel. We require Telegram username or ID to apply discounts and special privileges. To protect your privacy, we do not collect any other identifying information tying you to your wallet address, nor any information such as IP addresses or device data. Only the wallet address is saved without knowing who owns any of the addresses, unless, and only for, the purpose of TonSafe Support.

TonSafe Support

During any interactions with TonSafe Support or via Telegram you may disclose additional information such as your Telegram username and public profile. There are no copies made of these interactions nor any data disclosed therein, outside of the Telegram support application. TonSafe does not share any such information without your prior consent, if required for support. This service is provided by Telegram which may have additional information about your account for the provision of the service.

Legal basis for processing your personal information

We only process your personal data when we have a valid “legal basis”, including when:

  • Performance of a contract: This is when processing of personal data is needed in order to perform our obligations under a contract (to provide services) concluded with you.
  • Legal obligation or for public interest: This is when we are required to process your personal data to comply with a legal obligation.
  • Legitimate interests: Where necessary, we may process personal data where there is a legitimate interest for us in pursuing commercial and business interests (for example, for product development and internal analytics purposes), except where such interests are overridden by your interests, fundamental rights and freedoms.

These legal bases are unlikely to arise for most or all users of TonSafe, as we do not require nor retain personal data in relation to provision of our Services.

Sharing of Information

While we generally do not hold any data about users of TonSafe, we do not share the information that you provide us with other entities without your express consent, except as described in this Privacy Policy. We may disclose general non-personally identifiable information to third parties under the following circumstances:

  • Affiliates. We may disclose aggregate information to our subsidiaries and corporate affiliates (i.e. our family of companies that are related by common ownership or control) for purposes consistent with this Privacy Policy.
  • Business Transfers. We may share the information when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • Analytics Partners. We may optionally use analytics services from time to time to collect and process certain analytics data. These services also may collect information about your use of other websites and online resources, therefore we will choose any such partners carefully, if we make use of such services.
  • Compliance with Laws. As we do not have access to any information other than specified in this Privacy Policy, we are generally unable to share information for legal, protection, and safety purposes.

Cross Border Information Transfer

Please be aware that your information may be transferred to, processed, and stored out of your jurisdiction. You consent to the transfer of any information which you may provide, including personal information, out of any particular jurisdiction as set forth in this Privacy Policy by using the Application. Whenever we transfer your personal information to jurisdictions not deemed by other jurisdictions to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized as providing adequate protection for personal information.

Your Rights

We do not generally store any personal information about users of TonSafe. If you access Third Party Services or Materials, the Privacy policies of those Third Parties apply. Your rights to Privacy are guaranteed under applicable laws. We take great care to ensure your rights to privacy, and no personally identifiable information is required to use TonHub. Nothing in this Privacy policy should be deemed to limit your Rights.