Privacy Policy

Last Updated: October 15, 2019
Introduction
Our registered users ("Members") share their wallet addresses, nicknames, personal profile URLs. Content and data on some of our Services is viewable to non-members ("Visitors").

We use the term "Designated Countries" to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
Services
This Privacy Policy applies to tizer.io, Tizer-branded apps, tizer.io subdomains, and other Tizer-related sites, apps, communications and services ("Services"), including off-site Services, such as our ad services, but excluding sites, apps and services that state that they are offered under a different privacy policy.
Data Controllers and Contracting Parties
If you reside in the "Designated Countries": TizerWallet OÜ will be the controller of your personal data provided to, or collected by or for, or processed in connection with our Services; you are entering into the User Agreement with Tizer Europe.

If you reside outside of the Designated Countries: Tizer will be the controller of your personal data provided to, or collected by or for, or processed in connection with, our Services; you are entering into the User Agreement with Tizer.

As a Visitor or Member of our Services, the collection, use and sharing of your personal data is subject to this Privacy Policy (which includes our Cookie Policy and other documents referenced in this Privacy Policy) and updates.
Change
Tizer ("we" or "us") can modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection, use and sharing of your personal data is subject to the updated Privacy Policy.

1. Data We Collect

1.1. Data You Provide To Us
Registration

To create an account you need to provide data including your email address, mobile number, and a password.

Profile

You have choices about the information on your profile, such as your nickname, bio, photo and others. You don't have to provide additional information on your profile; however, profile information helps you to get more from our Services, including helping Members and Partners communicate you. It's your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add personal data to your profile that you would not want to be publicly available.

Posting and Uploading

We collect personal data from you when you provide, post or upload it to our Services, such as when you fill out a form, (e.g., with demographic data or billing address), respond to a survey, or submit a feedback. If you opt to import your phone book, we receive your contacts.

If you sync your contacts or calendars with our Services, we may collect your address book and calendar meeting information for further suggestions of payment recipients by providing information about them, e.g. times, places, attendees and contacts.

You don't have to post or upload personal data; though if you don't, it may limit your customer experience over our Services.
1.2. Data From Others
Contact and Calendar

Information We may receive personal data (including contact information) about you when others import or sync their contacts or calendar with our Services, associate their contacts with Member profiles.

Related

Companies and Other Services We receive data about you when you use some of the other services provided by us or our affiliates.
1.3. Service Use
We receive data about you when you use some of the other services provided by us or our affiliates.
1.4. Cookies, Web Beacons and Other Similar Technologies
As further described in our Cookie Policy, we use cookies and similar technologies (e.g., web beacons, pixels, ad tags and device identifiers) to recognize you and/or your device(s) on, off and across different Services and devices. We also allow some others to use cookies as described in our Cookie Policy.
1.5. Your Device and Location
When you visit or leave our Services, we get information about your IP address, proxy server, operating system, web browser and add-ons, device identifier and features, and/or ISP or your mobile carrier. If you use our Services from a mobile device or from a mobile app, that device will send us data about applications installed on your device and your location based on your phone settings. We will ask you to opt-in before we use GPS/GLONASS or other tools to identify your precise location.
1.6. User behavior
Because we use third-party services (like Firebase) for user behavior analytics for customer experience improvements, we also collect application screen showings/hidings, screen taps, swipe directions, application openings, app crashes, application logs and so on.
1.7. Other
Our Services are dynamic, and we often introduce new features, which may require the collection of new information. If we collect materially different personal data or materially change how we use your data, we will notify you and may also modify this Privacy Policy.

2. How We Use Your Data

How we use your personal data will depend on which Services you use, how you use those Services and the choices you make in your settings. We use the data that we have about you to provide and personalize, including with the help of automated systems and inferences we make, our Services (including ads) so that they can be more relevant and useful to you and others
2.1. Services
We use your data to authorize access to our Services. Members can create cryptocurrency wallets, close them and do several actions.

Transfer Cryptocurrency

Our Services allow you to send cryptocurrency:

  • to other wallets,
  • to Tizer user (member),
  • to your other wallet
If you synchronize your phonebook using our Services, you can easily send your cryptocurrency to other Tizer users (members) using phone number. Transferring the cryptocurrency you can provide some commentaries to your transactions. If transfer receiver is a valid Tizer member, he will be able to read the sender's comment.

We may use data about your transfers (such as your receivers, amounts, fees, mechanics, actions, creation time, device location and transaction comments) to help us to improve your user experience, suggest the most frequent counterparty on the send screen, find your habits and remember implicit recurrent payments to provide polite notifications.

Request

Cryptocurrency Our Services and applications allow you to request some money in cryptocurrency from your friends/contacts providing wallet address, QR-code, and unique URL. We use the data we have about you money requests (e.g., data you provide, data we collect from your engagement with our Services and inferences we make from the data we have about you), to recommend relevant opportunities and deals on our Services, suggest payment receivers you may wish to make further transfers/requests. So we will use this information (activity and other data, including your nickname and picture) to personalize content and advertisement.

Exchange cryptocurrency

Our Services allow you to exchange one cryptocurrency to another, entering amount of a cryptocurrency you wish to sell or to buy. We may use your currency exchange data to recommend relevant opportunities with the best rate and lowest commissions of currency pairs you interested on our Services.

Telegram messenger listener


Our Services allow you to connect your Telegram messenger account with Tizer providing login and password to your telegram account. Our Services listen to Member's conversations and detect some keywords and/or phrases (for example, "Send me 0.504 BTC to 2CbGSAEYstWetqTFn4Au4n4GJg7xOaNVN8"). Telegram listener works in background mode and checks only read messages and doesn't store Member's messages. We will use your data for sending push-notification to your installed Tizer app for simplify cryptocurrency transfer form application. We will help Member to fill required fields to make a transfer to the interlocutor easier and faster. User can stop listening messenger's conversation at any time on the Settings tab inside the app.
2.2. Premium Services
We may sell premium Services that provide our Members additional functionality and services (including bank cards, enhanced security and flat exchange rate) as part of our solutions. For getting additional services like bank card, our Services may require you to provide additional documents like national/international ID, utility bills, driver license, your photo, and other documents. This list is not final and our employees can ask you to provide additional documents during KYC/AML procedure. Video identification is also applicable for some countries.
2.3. Communications
We may contact you through email, mobile phone, notices posted on our websites or apps, including text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also may send messages about how to use the Services, updates, reminders, offers, security and legal notices and promotional messages from us and our partners.
2.4. Advertising
We target (and measure the performance of) ads to Members on our Services directly or through a variety of partners, using the following data, whether separately or combined:

  • Data from advertising technologies on and off our Services, like web beacons, pixels, ad tags, cookies, and device identifiers;
  • Member-provided information (e.g., profile info, contact information);
  • Data from your use of our Services (e.g., activity, transfers, exchanges, taping, clicking on an ad, etc.);
  • Information from advertising partners and publishers.
We may show you ads called sponsored content which look similar to non-sponsored content, except that they are labeled "ads" or "sponsored." If you take an action (such as tap, hide) on these ads, your action is associated with your name and viewable by the advertiser.
2.5. Marketing
We use data and content about Members for invitations and promoting our Services.
2.6. Developing Services and Research
Service Development

We use data, including public feedback, to conduct research and development for the further development of our Services in order to provide you and others with a better, more intuitive and personalized experience, drive membership growth and engagement on our Services, and help people to use cryptocurrency and digital assets safe and easy.

Surveys

Polls and surveys are conducted by us and others through our Services. You are not obligated to respond to polls or surveys, and you have choices about the information you provide. You may opt-out of survey invitations.
2.7. Customer Support
We use the data (which can include your communications) to investigate, respond to and resolve complaints and Service issues (e.g., bugs).
2.8. Aggregate Insights
We use your data to produce and share aggregated insights that do not identify you. For example we may use your data to generate statistics about our members, their Services usage, to calculate ad impressions served or clicked on, or to publish visitor demographics for a Service or demographic workforce insights.
2.9. Security and Investigations
We use your data (including your communications) if we think it's necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

3. How We Share Information

3.1. Our Services
Profile

Your profile is fully private to all Members and customers of our Services. In some cases part of your profile fields (e.g. nickname, avatar, bio and so on) could be publicity provided by specific URL (members and visitors can view certain fields in your profile).

Request Cryptocurrency

Sharing your wallet address and/or phone number of registered Tizer user you provide this information to a persons you chose. In this case, Tizer disclaims legal liability for the dissemination of this information.

Exchange cryptocurrency

Conducting cryptocurrency exchange, you implicitly provide your source wallet address and destination wallet address with third-party crypto exchange Service (like Changely and other).

Telegram messenger listener

Connecting Member's telegram account with Tizer wallet, the Member actually doesn't share account credentials with our Services, but he provides us access token to api.telegram.org only. We hold it securely and only for the one purpose.
3.2. Others' Services
You may link your account with others' services (e.g. Telegram Messenger) so that they can get your info (e.g. your contacts', your profiles, your activity etc). Excerpts from your profile may also appear on the services of others.

Subject to your settings, our Services may organize an communication through your Tizer account and other services. When you opt to link your account with other services, parts of your personal data may become available to them.
3.3. Related Services
We may share your personal data with our affiliates to provide and develop our Services. We may combine information internally across the different Services covered by this Privacy Policy to help our Services be more relevant and useful to you and others. For example, Our Block Explorer will recommend better content (transactions) to you based on your Tizer profile data, and we can personalize your Ad or token recommendations based on your activity history, because we are able to identify you across different Services using cookies or similar technologies.
3.4. Service Providers
We use others to help us provide our Services (e.g., maintenance, analysis, audit, payments, fraud detection, marketing and development). They will have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes.
3.5. Legal Disclosures
It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Tizer, our Members, personnel, or others. We attempt to notify Members about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
3.6. Change in Control or Sale
We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

4. Your Choices & Obligations

4.1. Data Retention
We retain your personal data while your account is in existence or as needed to provide you Services. This includes data you or others provided to us and data generated or inferred from your use of our Services. Even if you only use our Services when transferring some crypto time to time, we may retain your information and keep your profile open until you decide to close your account. In some cases we choose to retain certain information in a depersonalized or aggregated form.
4.2. Rights to Access and Control Your Personal Data
We provide many choices about the collection, use and sharing of your data, from deleting or correcting data you include in your profile and controlling the visibility of your posts to advertising opt-outs and communication controls. We offer you settings to control and manage the personal data we have about you

For personal data that we have about you:

  • Delete Data: You can ask us to erase or delete all or some of your personal data (e.g., if it is no longer necessary to provide Services to you).
  • Change or Correct Data: You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it's inaccurate.
  • Object to, or Limit or Restrict, Use of Data: You can ask us to 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).
  • Right to Access and/or Take Your Data: You can ask us for a copy of your personal data and can ask for a copy of personal data you provided in machine readable form.
Visitors can learn more about how to make these requests here. You may also contact us using the contact information below, and we will consider your request in accordance with applicable laws.

Please note, that data you have sent to any blockchain networks (all cryptocurrency wallets belong to blockchains) is unchangeable, undeletable and irreversible.
4.3. Account Closure
If you choose to close your Tizer account, your personal data will generally stop being visible to our Services within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our User Agreement, or fulfill your request to "unsubscribe" from further messages from us. We may retain de-personalized information after your account has been closed.

Your profile may continue to be displayed in the services of others (e.g., search engine results, payment feed of other users) until they refresh their cache.

5. Other Important Information

5.1. Security
We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
5.2. Cross-Border Data Transfers
We process data both inside and outside of the United States and rely on legally-provided mechanisms to lawfully transfer data across borders. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.
5.3 Lawful Bases for Processing
We will only collect and process personal data about you where we have lawful bases. Lawful bases include consent (where you have given consent), contract (where processing is necessary for the performance of a contract with you (e.g. to deliver the Tizer Services you have requested)) and "legitimate interests".

Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object. If you have any questions about the lawful bases upon which we collect and use your personal data, please contact us.
5.4 Contact Information
If you want to send us notices or service of process, please contact us by legal@tizer.io.

Although our users typically prefer to submit their inquiries in regards to our Privacy Policy or User Agreement by Email, we offer the option to write to us at this address: TizerWallet OÜ; Harju maakond, Tallinn, Lasnamäe linnaosa, Peterburi tee 47, 11415