Privacy Policy

Last Updated: January 5, 2019

NOTICE

PLEASE READ THESE TERMS OF USE CAREFULLY. YOU AGREE TO BE BOUND BY THESE TERMS OF USE AND ALL TERMS INCORPORATED BY REFERENCE.

By visiting, accessing, or using Tromerce, you consent to the policies and practices of our privacy policy (the “Privacy Policy”) so please read them carefully. If any policies or practices described in this Privacy Policy are unacceptable to you, please do not visit, access, or use Tromerce.

Tromerce Wallet, ("Tromerce Wallet", “Tromerce”,"we", "us" and "our") respects and protects the privacy of visitors to our websites and our customers who use our services. To ensure transparency this Privacy Policy describes our information handling practices when you access our website located at tromerce.com, or any other websites, pages, features, or content we own or operate (collectively, the "Site(s)") and/or when you use the Tromerce wallet mobile app, any Tromerce Wallet or third-party applications relying on such an API, and related services (referred to collectively hereinafter as "Services").

Please take a moment to read this Privacy Policy carefully. If you have any questions about this Privacy Notice, please contact us at hello@tromerce.com

PRIVACY POLICY

At Tromerce, your trust is one of our most important assets. We continually work to protect the privacy of our users and continually review our privacy policy. We will always provide the most current privacy statement. If we decide to change our privacy practices, we will post those changes to this privacy statement and other places we deem appropriate, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, disclose it. We reserve the right to modify this privacy statement at any time, so please review our policy frequently. If we change how we use your Personal Information (as defined below), we will notify you here, by email, or by means of a notice on our home page with information you have provided.

PERSONAL INFORMATION

As used herein, “Personal Information” means any information relating to an identified or identifiable natural person (each, a “Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number, location data, or an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of that natural person.

Third Party Services

Tromerce Wallet uses Fabric, a web analytics service provided by Google, Inc. (“Google”). Google uses cookies to help the website analyze how users use our website. The information generated by the cookie about your use of our website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. You may choose to accept the cookies by selecting the appropriate settings on your browser if you do this you may not be able to use the full functionality of our website. By using our website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please note that your use of these Third Party Services is governed by their respective Terms of Service and Privacy Policies. We use and disclose any collected information in accordance with our own Privacy Policy.

HOW WE USE THE PERSONAL INFORMATION WE COLLECT

The Personal Information we collect and the practices described above are done in an effort to provide you with the best experience possible, protect you from risks related to improper use and fraud, and help us maintain and improve the Tromerce platform. We may share Personal Information with third-party service providers (including those that may be located globally or within your country), who help us operate our platform and systems, and detect fraud and security threats during the normal course of our business. Such third-party service providers are subject to strict confidentiality obligations. In addition, we may be compelled to share Personal Information with law enforcement, government officials, and regulators.

For example, we may use your Personal Information to:

Provide you with our services, including user support for Tromerce;

If we decide to modify the purpose for which your Personal Information is collected and used, we will amend this Privacy Policy.

If we propose to sell or buy any business or assets, we may disclose your Personal Information in an anonymized form to the prospective buyer or seller of such business or assets. In the event of a merger, acquisition, or asset sale of Tromerce, we will give you notice if, and before, your Personal Information is transferred in a non-anonymized form or becomes subject to a different privacy policy.

We do not sell user Personal Information to third parties for the purpose of marketing.

Be aware that Bitcoin, Litecoin, Ethereum and other cryptocurrencies are not necessarily truly anonymous. Generally, anyone can see the balance and transaction history of any public cryptocurrency address. We, and any others who can match your public cryptocurrency address to other Personal Information about you, may be able to identify you from a blockchain transaction. This is because, in some circumstances, Personal Information published on a blockchain (such as your cryptocurrency address and IP address) can be correlated with Personal Information that we and others may have. This may be the case even if we, or they, were not involved in the blockchain transaction. Furthermore, by using data analysis techniques on a given blockchain, it may be possible to identify other Personal Information about you. As part of our security, anti-fraud and/or identity verification and authentication checks, we may conduct such analysis to collect and process such Personal Information about you. You agree to allow us to perform such operations and understand that we may do so.

DATA SECURITY

If Tromerce stores or processes Personal Information, Tromerce protects data by using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards Tromerce uses are firewalls and data encryption, physical access controls to data centers, and information access authorization controls. Tromerce’s employees, contractors and agents are subject to strict contractual confidentiality obligations and may access your Personal Information only on a need-to-know basis.

ACCURACY AND RETENTION OF PERSONAL INFORMATION

We take reasonable and practicable steps to ensure that your Personal Information held by us (i) is accurate with regard to the purposes for which it is to be used, and (ii) is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used, which is when your business relationship with us ends, unless the further retention of your Personal Information is otherwise permitted or required by applicable laws and regulations.

ACCESS, CORRECTION, AND DELETION OF PERSONAL INFORMATION

You have the right to ascertain whether we hold your accurate and current Personal Information, to obtain a copy of the Personal Information that you submitted as permitted by law, and to correct any of your data that is inaccurate. You may also request that we inform you of the type of Personal Information we hold with regard to you, subject to restrictions on our providing copies of certain data pursuant to our obligations under the Bank Secrecy Act (“BSA”) and Anti-Money Laundering (“AML”) regulations and/or data provided to our legal counsel in defense of a claim against us. You may also request that we delete your Personal Information, subject to restrictions under applicable laws and regulations, such as those related to the BSA and AML. For data access, correction, or deletion requests, please contact hello@tromerce.com.
When handling a data access, correction, or deletion request, we check the identity of the requesting party to ensure that he or she is the person legally entitled to make such request. While we maintain a policy to respond to these requests free of charge, should your request be repetitive or unduly onerous, we reserve the right to charge you a reasonable fee for compliance with your request.

CONTACT US

If you have questions or concerns, please feel free to contact us at hello@tromerce.com. Please note that whenever you send us a message, you will be providing us with Personal Information about yourself, including your email address, your name, if you choose to do so, and any information you choose to include in the text of your message. In some cases, other Personal Information may be required in order for us to be helpful and address your question or concern. Such provided Personal Information will be deemed Personal Information provided under this Privacy Policy and handled pursuant to the provisions hereof.
This Privacy Policy only pertains to our policies and practices with regard to your Personal Information. Websites linked to and/or from our website are not covered by this Privacy Policy.

PRIVACY STATEMENT FOR DATA SUBJECTS RESIDING IN THE EUROPEAN UNION

While users who are located in the EU are users of our US entity, we recognize and, to the extent applicable to us, adhere to relevant EU data protection regulations.

LAWFUL GROUNDS TO COLLECT AND PROCESS DATA

We process the Personal Information of Data Subjects who are located in the EU for one or more several lawful purposes, including:

INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

As a global entity, Tromerce may store, transfer, and otherwise process your personal information in countries outside of the country of your residence.

NON-DISCLOSURE OF PERSONAL INFORMATION

Our employees are prohibited, either during or after their employment, from disclosing Personal Information to any person or entity outside of our company, including family members, except under the circumstances described above. An employee is only permitted to disclose the Personal Information of a user to such other employees who needs access to such information in order to deliver our services to that user.

Tromerce
Malaysia