Date: June 24, 2020

LAST UPDATED: March 19, 2024

WE RESPECT YOUR PRIVACY AND ENCOURAGE YOU TO READ THE PRIVACY POLICY CAREFULLY AND USE IT TO MAKE INFORMED DECISIONS.

CASPIAN TECHNOLOGIES PTE LTD (Singapore) (hereinafter in the text – the Company, We, Our) has prepared this Privacy Policy to outline its practices with respect to collecting, using and disclosing Your personal information (personal data) when in process of using the Spatium mobile application (“App” or “Application”). The Company is a data controller in respect of personal information that we process in connection with the services we provide through the App.

personal data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations.

It is crucial that You understand the ways how We collect and use Your personal information. You should attentively read this page in full, but below We provide the key highlights:

  1. This Privacy Policy is applicable only in relation to the use of the App and does not apply to data that comes from companies or other organizations.
  2. Our goal is to simplify Your crypto experience. If You do not wish for Your personal information (a) to be collected, used, or (b) disclosed as described in this Privacy Policy, or (c) You are under 18 years of age, You should stop accessing Our App.
  3. The App’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.
  4. We seek to protect Your personal information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of personal information and how We are processing that data.;
  5. We collect and use Your information in order to provide and improve Our App, services We provide and Your experience, protect the security and integrity of Our App, and meet Our legal obligations.
  6. We share Your information with other companies, as well as trusted third parties and service providers,  regulatory bodies in order to offer services information about which contained in the App and fulfill legal requirements.
  7. We offer privacy tools for You to request access to or deletion of information We hold about You. Depending on where You live, You may also have other privacy rights under law.
  8. We do not store files with the Your part of the private key on Our side. Please keep this in mind that if You delete a QR-code generated by the App (if You have chosen the QR code backup option) or a file in Your Apple iCloud or Google Drive (if You have chosen Cloud backup option) with the name "DO NOT DELETE SPATIUM BACKUP", you risk losing access to your account (wallet) and, accordingly, the digital assets on it.

YOU ACKNOWLEDGE THAT WE ARE NOT RESPONSIBLE FOR THE PRODUCTS, SERVICES, OR DESCRIPTIONS OF PRODUCTS OR SERVICES THAT YOU RECEIVE FROM THIRD-PARTY SITES OR TO THE CONTENT OR PRIVACY PRACTICES OF THOSE SITES AND THAT THIS PRIVACY POLICY DOES NOT APPLY TO ANY SUCH THIRD-PARTY PRODUCTS AND SERVICES. YOU ARE KNOWINGLY AND VOLUNTARILY ASSUMING ALL RISKS OF USING THIRD-PARTY SITES TO PURCHASE PRODUCTS AND SERVICES. YOU AGREE THAT WE SHALL HAVE NO LIABILITY WHATSOEVER WITH RESPECT TO SUCH THIRD-PARTY SITES AND YOUR USAGE OF THEM.

CONTACT INFORMATION

Name: CASPIAN TECHNOLOGIES PTE LTD (Singapore)

Reg. No: 201727936

Address: 20A Tanjong Pagar Road (088443), Singapore

If You have:

  • any  questions or concerns regarding this Privacy Policy
  • information that Your child is using the Site
  • complaint

please contact us at info@spatium.net.

Our specialists will consider your request and you will certainly receive feedback from Us. 

We endeavor to protect the privacy of your personal information we hold in our records, however, we cannot guarantee complete security. Unauthorized entry or use and other factors may compromise the security of Your information. If at any time, there is an identified concern for the security of the App or confidentiality of Your personal information, please contact info@spatium.net for a prompt investigation.

CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We collect your information from three groups of sources. For your convenience we provide information on each source in the form of a tables:

  • information provided by the User

    Basic information about the User

    Email Address

    Additional information submitted by You

    Survey responses, information provided for supported purposes, including chats with Our specialists and other means of communications, including information contained therein.

  • information that we learn through Our relationship with you and the way You operate Your account (wallet) and/or services

    Wallet information

    Wallet address (public) and information related to it, including Our part of Your private key (except for Your part of a private key. We also don’t store QR-code and (or) text file containing Your part of a private key for the backup procedure or any other purposes).

    Information about transaction

    Information about the transactions made using Our App, such as the public address of the sender, the public address of the recipient, the amount, balance, currency preferences, payment method, date, and/or timestamp.

    Data received from Google

    Email address, Google ID for authorization procedure and backup purposes.

  • information collected automatically

    App, browser, and device information

    • Information about the device, operating system, and browser You’re using;
    • Other device characteristics or identifiers (e.g. plugins, the network you connect to);
    • IP address.

    Application usage information

    • Information about what You view or click on while visiting Our App and how You use Our services;
    • Information about how Our App and services contained therein are performing when You use the App.
  • information received from third parties

    Blockchain Data

    We may analyze public blockchain data, transaction amounts, and wallet addresses

    Information from analytics providers

    We receive information about your Application usage, interactions, age group, and survey responses

We recognize the importance of keeping our Your personal information secure. We have employees who are responsible for ensuring the security of Your information. We use reasonable security measures, including physical, administrative and technical security measures. These measures may include access controls or other physical security measures, information security technology and policies, and procedures to help ensure that information is properly deleted.

PURPOSES OF USING YOUR PERSONAL INFORMATION

Purpose of using personal information

Information categories used

To create and maintain Your wallet account, including authorization procedure

We need to use some Your personal information to conclude and perform Our User Agreement with you.

  • Basic information about the User;
  • Data received from Google (your Google ID for an authorization purposes).

To provide You services contained in the App

In order to provide you with the functionality of the App (allow You to set up a wallet and perform actions with digital assets).

  • Basic information about the User;
  • Wallet information
  • Transaction information;
  • Blockchain data;
  • Application usage information;
  • App, browser and device information.

To provide You backup services

For the purpose of restoring access to Your account (wallet) if You change device or reinstall the App after deleting it. We provide two ways (at Your discretion) to perform a backup using:

  • QR code; or
  • Apple iCloud/Google drive.

With these tools, You receive Your part of a private key.

IMPORTANT: We do not store the QR-code or text file containing Your part of a private key to Your account (wallet). If You lose them, We will not be able to restore Your access to Your account (wallet).

  • Basic information about the User;
  • Google ID;
  • Wallet information.

To provide You support services

To address your request for support in the App or by email and to respond to customer care and other inquiries.

  • Basic information about the User;
  • Transaction information;
  • Application usage information;
  • Additional information submitted by You.

To communicate with You

To send you administrative or account-related communications about our Services, which can include security updates or transaction-related information, through email, or push notifications. You may not opt-out of receiving critical service communications, such as emails or notifications sent for legal or security purposes.

  • Basic information about the User;
  • Transaction information;
  • Application usage information;
  • Additional information submitted by You.

To promote safety, security and integrity of the App

To verify accounts and related activity, find and address violations of our User Agreement, investigate suspicious activity, detect, prevent and combat harmful or unlawful behavior, detect fraudulent behavior, including account takeover prevention and support.

  • Basic information about the User;
  • Transaction information;
  • Application usage information;
  • Google ID;
  • Additional information submitted by You.

To comply with Our legal obligations

For legal compliance (fulfilling our legal obligations under applicable law, regulation, court order, or other legal processes, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities: protecting the rights; enforcing any agreements with you; resolving disputes).

  • Basic information about the User;
  • Transaction information;
  • Blockchain data;
  • Wallet information;
  • Data received from Google;
  • Application usage information;

To customize Your experience with the App and improve it, including conducting researches

In order to perform core metrics, customize Your experience with the App and to generally improve it, We collect information about Your activity. Also We may carry out surveys of Your experience using the App and to conduct and support research and innovation on topics related to Our App.

  • Basic information about the User;
  • Transaction information;
  • Application usage information;
  • Additional information submitted by You;
  • App, browser and device information;
  • Information from analytics providers.

To provide you with marketing information, promotions

We use Your information to send You targeted marketing communications, promotion materials through email, in-App and push notifications.

  • Basic information about the User;
  • Transaction information;
  • Application usage information;
  • Information from analytics providers.

To enable device-based settings

Collecting information that You allow Us to receive through the device-based settings You enable which we use to provide the features or services described when you enable the setting.

  • App, browser and device information.

We will not collect additional categories of personal data or use the personal data We collected for materially different, unrelated, or incompatible purposes without providing You notice.

TRANSFER OF YOUR INFORMATION

We cooperate with third parties to help Us provide our App with all features (functionality), and as a result We need to share certain information with these third parties.

The App’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Third parties can be divided into the following groups:

Authorities and regulatory bodies

We may share your information regulators, tax authorities, government agencies, to respond pursuant to applicable law or regulations, court orders, legal process or government requests; detect, investigate, prevent, illegal activity or security; and protect the rights, property, and safety of our partners, clients, affiliates.

Affiliates

The information We process and collect may be transferred between companies and employees associated with Us as a normal part of doing business and providing the App and services to You.

Third parties’ services 

We work with third-party service providers to help Us provide all the functionality of the App. We are not responsible for any actions related to the processing of information by Third parties, and We cannot guarantee the protection of Your personal data by such parties. By using Our App, you acknowledge and agree that We shall not be held liable for any damages or losses resulting from the actions of third parties.

INTERNATIONAL TRANSFERS

We may transfer your information to or Your information may be collected directly by organisations in other countries on the basis that anyone to whom We pass that information or who collects it directly protects it in the same way We would and in accordance with applicable laws. In the event that We transfer information to countries outside of the European Economic Area, We will only do so where:

  • the European Commission has decided that the country or the organisation we are sharing your information with will protect your information adequately;
  • he transfer has been authorised by the relevant data protection authority; and/or
  • we have entered into a contract (deed of adherence) with the organisation with which we are sharing your information (based on the model clauses proposed by the European Commission) to ensure your information is adequately protected.

HOW LONG WE KEEP YOUR INFORMATION

We retain the information We collect for as long as needed (including aspects of risk management) and to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements and etc. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time.

We may rectify, replenish, or remove incomplete or inaccurate information at any time and at our own discretion.

CHILD PRIVACY

Our App is intended for a general audience and is not intended for children.

We recognize the importance of protecting the online privacy of children. The Company fully recognizes the importance of respecting the privacy of children, especially in an electronic communication environment. Our App is not intended for people under the age of 18. It is our policy never to knowingly collect or maintain information from anyone under the age of 18.

Please contact us if you believe we may have collected information from your child by email: info@spatium.net and we will remove it.

YOUR PRIVACY RIGHTS (EU)

If You are an European Union resident, You have the following rights according to the article 8 of GDPR:

The right to be informed. This right provides the data subject with the ability to ask a company for information about what personal data (about him or her) is being processed and the rationale for such processing.

The Right to be Forgotten / Right of Erasure. Article 17 of the GDPR details that You can request to have their personal data removed from a controller and processor’s system.

You have the Right of Erasure without delay if they meet one of the following criteria:

  • the controller no longer needs the data;
  • You exercise Your right to object to the data processing;
  • You withdraw consent to processing;
  • the data must be erased for legal reasons;
  • You were a child at the time of data collection;
  • the controller or processor is processing the data unlawfully.

The right of access. This right provides You with the ability to get access to Your personal data that is being processed. This request provides the right for You to see or view Your own personal data, as well as to request copies of the personal data.

The right to rectification. This right provides You with the ability to ask for modifications to your personal data in case You believe that this personal data is not up to date or accurate.

The right to withdraw consent. This right provides You with the ability to withdraw a previously given consent for processing of Your personal data for a purpose. The request would then require the company to stop the processing of the personal data that was based on the consent provided earlier.

The right to object. This right provides You with the ability to object to the processing of Your personal data. Normally, this would be the same as the right to withdraw consent, if consent was appropriately requested and no processing other than legitimate purposes is being conducted. However, a specific scenario would be when You ask that Your personal data should not be processed for certain purposes while a legal dispute is ongoing in court.

The right to data portability. This right allows You to obtain a copy of Your personal data safely and in a machine-readable format free of charge, so it can be copied or securely transferred to another controller. It is important to note that this right is subject to several conditions:

  • only data provided by and concerning the individual is eligible;
  • processing must be performed using automated procedures; and
  • it must not infringe upon the rights and/or freedoms of others.

Rights related to automated decision making and profiling. This right provides You with the ability to object to a decision based on automated processing. Using this right, You may ask for Your request to be reviewed manually, because You believe that automated processing may not consider the unique situation of You.

Depending on where You live, you may be able to exercise certain privacy rights related to Your personal information. If any of the rights listed below are not provided under law for Your operating entity or jurisdiction, we have absolute discretion in providing You with these rights.

MARKETING

Your information, such as Your name, email address and etc., may be used by Us to provide you with promotional materials, concerning our services mentioned on the App.

Out of respect to your right to privacy, within such marketing materials, We provide You with means to decline receiving further marketing offers from Us. If You opt out in receiving email communications, including marketing communications from Us and, You may request to opt out of receiving marketing communications. Please address Your inquiry to info@spatium.net. Please note that even if you unsubscribe from our marketing mailing list, we may continue to send you updates and notifications if they are important.

CHANGES TO THIS PRIVACY POLICY

We’re constantly trying to improve Our App, so We may need to change this Privacy Policy from time to time as well. We post any changes we make to our Privacy Policy on this page and, where appropriate, We will provide You with reasonable notice of any material changes before they take effect or as otherwise required by law. The date the Privacy Policy was last updated is identified at the top of this page.