Privacy policy – Plutus Crypto Wallet

Plutus AI Wallet Privacy Policy

LAST REVISED: August 13, 2019

We value Your privacy and respect Your interest in learning how information about you is collected and used. Dice Roll Solutions Ltd. (the “Owner”, ‘Plutus”, “We”, “Our”, or “Us”, “Data Controller”), which is the owner of Plutus AI Wallet App., the website http//plutus.ai (referred to as the “App” and the “Site”, respectively, and collectively referred to as the “Software”) has developed a Privacy Policy guaranteeing the protection and confidentiality of the personal data of Users (the “User”, “You”, or “Your”) collected. This document (Policy) describes how We collect, use, disclose, transfer, and safeguard Your information.

This Policy is drafted in strict compliance with data protection laws applicable in relevant jurisdiction and Regulation (EU) 2016/679 (General Data Protection Regulation), hereinafter referred to as the “GDPR”.

1. Acceptance of the Policy terms

1.1. By using the Software, You are indicating Your express consent to the terms and conditions of this Privacy Policy. Plutus reserves the right to amend the Privacy Policy at its sole discretion, the revised version will be published in the App or on the Site. Please check the current version and any amendments to this Privacy Policy as Your continued use of the Software indicates Your express consent to the amended Privacy Policy.

1.2. If you have a complaint or question about this Policy, if you would like to make a request concerning your personal data, withdraw Your consent, you may at any time contact us at info@plutus.ai. We will aim to respond you within maximum 10 business days from receipt of request. Any correspondence received from You is classified as restricted-access information and may not be disclosed without Your prior consent.

2. The list and the purpose of processing Your information

2.1 When You register with the App or create user account on the Site or use the external accounts (as defined below) to sign in we collect the following personal information:

(a) first and last name,

(b) e-mail address,

(c) profile photo,

(d) ID number of the User’s Google account or the account registered with token exchange which may be used for signing in the App or the Site (the “external account”).

If you register in the App or on the Site without use of external account, we collect and process only your e-mail address if other information is not indicated by you.

We process your personal information for the following purposes (i) access and use of the Software, delivery of the Software features as specified in End-User License Agreement (abbr. “EULA”), (ii) communication with the User with respect to access, use of the Software, support requests, settlement of complaints, award of in-app bonuses.

2.2 When You log in the App or the User’s account on the Site and use the Software we collect and process non-identifiable technical information about Your mobile device or computer and some technical identifiers:

(a) Android or iOS version,

(b) type and version of operating system,

(c) system language,

(e) IP address.

We collect and process the technical information and identifiers for the following purposes (i) smooth running and integration of the Software with the User device and delivery of the Software features, (ii) technical and statistical purposes (including, but not limited to, product updates, patches and fixes to assure correct operation of the Software).

2.3 Plutus Software also automatically collects information about Cookies, which are the text information located in a temporary file that We send via the web server to the User’s device in order to save the session on the User device, and to identify You the next time You visit the App or the Site. Cookies do not contain personal User data. These files contain exclusively technical information that is non-specific and necessary for the identification of the User. Some of Our partners may also use cookies: for example, when placing advertisements. Please note that We do not have access to such cookies. Our partners’ cookies are regulated by their own privacy policies.

You are not required to accept cookies. If you want to turn off cookies in your web browser, follow the instructions for your browser:

Mozilla Firefox http://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences?redirectlocale=en-US&redirectslug=?Enabling+and+disabling+cookies

Chrome http://support.google.com/chrome/bin/?answer.py?hl=en-GB&answer=95647

Safari (OS X) http://support.apple.com/kb/HT1677

Additional information on placement, use, and deletion of cookies can be found at http://www.cookiecentral.com/faq and http://www.aboutcookies.org.

2.4 The Software contains some elements developed by third parties (“Third Parties SDK”). To Our best knowledge, such third parties through Third Parties SDK collect and process personal data on a legal basis and with responsible approach to personal data protection. Moreover, in any case they are well known companies with respected reputation and We always negotiate the necessity to process Your personal data. However, We do not make decisions about the information processed by these third parties and purposes of processing. Therefore, We do not include information on exact actions and purposes of personal data collection of mentioned third parties.

In the list below You can find the information about Third Parties SDK and direct links to texts of privacy policies developed by such third parties:

Company Name Third Party software Purpose of third party software Information or link to privacy policy
Google, Inc. Google Analytics Statistics https://policies.google.com/privacy
Yandex Ltd. Yandex.Metrica Statistics https://yandex.com/legal/confidential/

https://metrica.yandex.com/about/info/privacy-policy

Adjust GMBH Adjust SDK Statistics https://www.adjust.com/terms/privacy-policy/

Third parties Google Analytics, Yandex.Metrica and Adjust place a permanent cookie-files (mostly for statistical reasons) to your web browser to identify you as a unique user the next time you visit the App, it helps us to collect statistics about how the Software is used so we can improve it. These cookie-files do not collect person identifiable information. The information collected using the cookies will be transmitted to Google, Inc and Yandex Ltd., Adjust GmbH respectively. Processing of personal data by Google, Inc., Yandex Ltd. and Adjust GmbH is regulated by the privacy policies of these companies indicated in the table above. To comply with GDPR provisions We inform you of possible risks of your data transfer to Yandex Ltd., the owner of Yandex.Metrica, incorporated and existing under the laws of the Russian Federation, which is not recognised by the European Commission as the country providing adequacy measures for personal data protection. At the same time, We would like to underline that We use the information obtained through Google Analytics, Yandex.Metrica and Adjust GmbH only to exercise our obligations under the EULA entered into with the User, improve our App. and deliver in-app service to the User. To ensure security of your information We do not combine the non-identifiable information received through Google Analytics, Yandex.Metrica and Adjust GmbH with person identifiable information We collect.

You can disable Google Analytics and Yandex.Metrica to recognize you when you return to the App by the following means: 1) for disabling Google Analytics - by (i) opting out Google Analytics cookies in your browser, or (ii) you can use Google Analytics Blocker, 2) for disabling Yandex.Metrica – (i) by un-ticking the “Take my interests into account” box on the settings page: https://yandex.com/tune/adv, (ii) by installation of Yandex.Metrica opt out which is the browser add-on via the link https://yandex.com/support/metrica/general/opt-out.html.

2.5. We do not collect or process any of sensitive data unless it is required to be law such as in the event of a court case. Under most circumstances, the types of data listed below will be never be processed:

(a) Race or ethnic origin,

(b) Political opinions,

(c) Religious or philosophical beliefs,

(d) Trade union memberships,

(e) Genetic or biometric data,

(f) Health or mortality,

(d) Sex life or sexual orientation.

3. Legal basis for processing personal data

3.1 We will only collect and process personal information about You where we have legal basis. Legal basis may include your consent to process personal data, contract and “legitimate interests”.

Type of your data Legal basis

Personal information

(a) first and last name,

(b) e-mail address,

(c) profile photo,

(d) ID number of the User external account.

(a) execution of contract entered between You and Plutus (End-User License Agreement, “EULA”),

(b) legitimate interest: establishment, exercise or defense of your legal claims or legal claims of our partners

Non-identifiable information

(a) Android or iOS version,

(b) type and version of operating system,

(c) system language,

(e) IP address,

(d) Cookies

(a) execution of contract entered between You and Plutus (EULA), including, without limitation, assuring your enjoyable use of the Software,

(b) legitimate interest: establishment, exercise or defense of your legal claims or legal claims of our partners, compliance with any laws and regulations applicable to delivery of the Software to You.

4. Children

The Software is not designed for persons under 18 (or the minimum legal age to consent to the collection and processing of personal data if different under applicable law of relevant jurisdiction). While GDPR specifies that different countries may provide by law for a lower age provided that such lower age is not below 13 years, we do not knowingly collect information from children under 13 as well. If we discover that a child under 13 has provided Us with personal information, We will delete such information from Our systems.

5. How long We store your personal information

5.1. We retain personal information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations (no longer than is necessary for the purposes for which your personal data is processed). In accordance with our record keeping obligations, we will retain basic account information and information about performed transactions for at least 10 years after an account is closed.

5.2. If You submit a request to be forgotten, We will anonymize your personal data unless we have a legal obligation to continue to store the personal data, or for the establishment, exercise or defense of a legal claim. For example, if you have redeemed a reward within any of our applications we may store your personal data for as long the statute of limitations for making a claim relating to that redemption. If you have indicated in any way that you believe you have a dispute with us, we may store your personal data at least until that dispute is resolved.

5.3. We may store anonymized data indefinitely. We maintain this type of data to compare performance of our Site, our Applications and our Services over past periods, to analyze current performance, to measure player activity over time, and for other business uses.

6. How We Share Your Information

We may share the information that we receive from You, including personally identifiable information, as follows:

6.1. Our Users. Your username and any information that you post, including, without limitation, reviews, comments, scores, and text will be available to, and searchable by, all other Our Users.

6.2. Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.

7. Disclosure of your information

7.1. We may be required to disclose Your personal information in accordance with the law, a legal process, or court proceedings, and/or on the basis of public inquiries or inquiries by government agencies inside or outside the country in which You are located.

7.2. We may also disclose information about You if We determine that such disclosure is necessary or appropriate for the purposes of national security, law enforcement, or other instances of public importance.

7.3. We may also disclose information about You if We determine that such disclosure is necessary in order to execute Our regulations and conditions, or for the purposes of protecting Our activity and Our users. Additionally, in the event of the reorganization, merger, or sale of the company, We may transfer any or all of the personal information We have collected to the relevant third party.

7.4. We do not sell or in any way provide personal information of Our users to third parties. This does not include trusted third parties which are providing Us with services concerned with the operation of the Website / App or management of Our business, as well as any other services. Information about You may be processed by Us and other members of Our corporate group and Our partners. Such parties are required to rigorously monitor and accept the regulations of this Privacy Policy. Information about You may be processed both within and outside the jurisdictions of the Cyprus and the EEC.

7.5. In addition to the disclosure of information in accordance with Clauses 7.1–7.4 of this Privacy Policy, We may also disclose information about You to Our employees and the employees of other companies in Our corporate group. All parties receiving information about You are required to comply with current data protection legislation and ensure the confidentiality of Your information to the same extent to which We are bound by those obligations.

8. Security and access to your information

8.1. We strive to maintain maximum accuracy of the information about You that We have at Our disposal. You can contact Our technical support service at any time at info@plutus.ai in order to review, change, or receive a copy of the information about You, or for the purpose of making necessary amendments to that information. The following options regarding Your right in details are listed below:

(a) Delete data: You can request deletion of your personal data that we have about you. We will delete the data and since some of the data is necessary to provide services to you, you will not be able to use services after the deletion;

(b) Change or correct data: You have the right to request change of incorrect personal data that we have about you;

(c) Object to or limit or restrict use of data: You can request that we stop using all or some of your personal data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held);

(d) Right to access and/or take your personal data: You have the right to ask us for a copy of your personal data and can ask for a copy of personal data;

(e) You also have the right to lodge a complaint at a supervisory authority.

8.2. In certain circumstances, We may charge a minimal fee to cover administrative expenses connected with any request made by You in that regard.

8.3. Please read Chapter 3 “Rights of the data subject”  (here) of the Regulation (EU) 2016/679 (General Data Protection Regulation) to learn more what your rights are.

9. Where We Hold Your Information

Personal information We collect may be stored and processed for the purposes set out in this document in any country in which We operate and your personal information may be transferred, stored and processed by recipients in various countries around the world where other users or our partners are located. We do our best to make sure all recipients or your personal data understand the necessity to process personal data only on a legal basis taking into account any and all applicable legislation.

Aiming the appropriate security and protection of data collected we located our servers with personal data of our users in Germany, the member state of EU, recognized by the European Commission as the country providing adequate measures on protection of personal data information in accordance with GDPR.

10. Changing and deletion of the account in the App or on the Site

10.1. Users may change your personal data in the App or on the Site in your account area, or delete information in the User Account record by sending a message to the support service at info@plutus.ai. Your account will be deleted and your personal data will be de-personalized within 30 days of receiving your request.

10.2. We retain your personal data even after You have closed Your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or enforce our EULA. We will retain de-personalized data after Your account has been deleted.

11. Protection of personal information

11.1. We make significant efforts, including taking every administrative, technical, and physical precautionary measure within its power, to protect Your personal information from loss, theft, and dishonest use, as well as from unauthorized access, disclosure, amendment, and deletion. Even so, no security measure is 100% perfect. Therefore, while We strive to employ reasonable protections for your information that are appropriate to its sensitivity, We cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to Your information under Our control.

11.2. Pseudonymous information (in such a way that the individual is not or no longer identifiable), which We are not in position to relate to You, does not qualify as “Personal Information”. All collected information is pseudonymised. Neither We nor any third party may identify You. If any personal data which could let Us identify You is collected, it is always automatically pseudonymised.

11.3. The personal information You post on social networks, on forums, or in chat rooms is visible to other users and may be read, collected, or used by them. You are responsible for the personal information that You prefer to provide in such cases.

11.4. You should take steps to protect against unauthorized access to Your password, and mobile device or computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change Your external account’s password, you must go to the relevant third party site and follow its procedures for changing your password.

12. AMENDMENTS TO THE PRIVACY POLICY

12.1. We reserve the right to amend this Privacy Policy at any time. Amendments to the Privacy Policy shall come into force immediately after the revised version is published in the App or on the Website.

13. APPLICABLE LAW

When processing Your personal data, We rigorously try to comply with the regulations of English Common Law, including the Data Protection Act 1998 and Regulation (EU) 2016/679 (General Data Protection Regulation).

14. ABOUT US

Dice Roll Solutions Ltd.

Registration number: HE 341088

Address: Arch. Makariou III, 155 PROTEAS HOUSE, 5th floor 3026, Limassol, Cyprus

Most recent update to the Privacy Policy: August 13, 2019