Privacy Policy

1. General

1.1. This document (as updated, amended and supplemented from time to time, the Privacy Policy) explains the privacy rules applicable to personal data and other information collected or submitted when you access, install or use the Software or Services regardless of the device (e.g. computer, tablet, mobile phone, etc.) you use.

1.2. By accessing, installing or using the Software and/or Services, and by submitting your personal data to us, you and those you legally represent (you) confirm that you have read and agree to be bound by this Privacy Policy. If you do not agree with this Privacy Policy or any of its provisions, please do not use the Software or Services. Any access, installation or use of the Software and/or Services by you is also subject to the Terms of Use. If there is any conflict or inconsistency between clauses in the Terms of Use and this Privacy Policy, this Privacy Policy shall apply.

1.3. You may contact our Data Protection Officer by emailing dpo@web3password.com if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.

1.4. Web3Password created this Privacy Policy to demonstrate our commitment to protecting your privacy and to disclose our privacy practices pertaining to our products.

1.5. Our Software and Services are constantly updated to introduce new features or modify current ones. We may therefore need to amend the Privacy Policy from time to time. Unless stated otherwise by us, each update of the Privacy Policy comes into effect as of the moment when the amended Privacy Policy is published on our website at https://web3password.com/privacy. Please check the Privacy Policy regularly so that you are familiar with the most current wording of the Privacy Policy. You are deemed to have accepted the most current Privacy Policy from time to time by your continued use of the Software and/or Services.

2. Definitions and interpretation

2.1 The following terms shall have the meanings ascribed to them respectively below:

2.2. Any term used in this Privacy Policy which are defined in the Terms of Use shall have the same meaning unless specifically defined otherwise in this Privacy Policy.

3. Information we collect

3.1. We generally do not collect your personal data. We will never solicit or require your personal data in order to provide you with access to and for you to use the Software or the Services. Please do not attempt to send any personal data about yourself to us.

3.2. You understand that we generally cannot send you any email, message or initiate any conventional direct communications with you because we do not solicit your email address, phone number or device ID.

3.3. We may receive personal data provided to us voluntarily by you directly or via a third party who has been authorised by you to disclose your personal data to us. To the extent that such personal data is received or collected by us, you consent to our processing your personal data for the following purposes:

3.3.1. verifying your identity where we are legally required to do so;

3.3.2. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

3.3.3. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

3.3.4. any other purposes for which you have provided the information; and

3.3.5. transmitting to any relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.

3.4. You acknowledge and agree that data stored on blockchains and smart contracts are technically immutable and cannot be amended, and you hereby waive any right to request the deletion, amendment or otherwise of such data.

3.5. Web3Password does not have the technical means to access Your Content in plain text. The System is built based on a zero-knowledge architecture and that means that only you know what is stored in your vault. Web3Password keeps the proof that you have the key to your Web3Password® vault, but not Your Mnemonic Phrase. Web3Password does not store nor have the means to access Your Mnemonic Phrase. Blockchain and smart contract ensures that only you can decrypt Your Content.

3.6. You may request Web3Password to provide you with information about whether we hold, or process on behalf of a third party, any of your personal data. To request this information please contact us at dpo@web3password.com.

3.7. The purposes listed in clause 3.3 above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

3.8. Web3Password would never knowingly collect or solicit personal data from anyone under the age of 18. If you are under the age of 18, please do not attempt to send any personal data about yourself to us. If we acknowledge that we have collected and processed personal data from a child under the age of 18, we will to the extent technically possible delete that data as quickly as possible.

4. Data security

To the extent that we collect any of your personal data, we have implemented appropriate physical, technical and organisational measure to protection information about you against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access and against all other unlawful forms of processing. However, no security measures is completely inviolable. By using the Software and/or the Services, you acknowledge that we cannot guarantee 100% security of your personal data and all information received through our Software and/or Services have been provided at your responsibility.

5. Date retention and deletion

To the extent we collect any of your personal data, we will keep your personal data on for so long as it is necessary, or for as long as we have any other legitimate ground to do so, but not longer than permitted or required by law. When we no longer have a legal ground to keep your personal data, we will either securely dispose of, or de-identify your personal data through appropriate anonymisation means. We will destroy personal data stored in the form of electronic files using method(s) that would prevent recovery of the data.

6. Application, web extension and cookies

6.1. The Software does not collect any personal data, such as name, mailing address, email address, IP address and telephone number.

6.2. The Software does not track or store a user’s App access history.

6.3. Installation of the Web3Password browser extension requires explicit permission to read and write login and password data into a user-designated website form fields for the purpose of securely auto-filling credentials from your Web3Password® vault.

6.4. The Software does not track or store your browsing page history.

6.5. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. Please refer to our Cookie Policy https://web3password.com/privacy for more information.

6.6. As is true of most websites, we gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.

6.7. We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon your web browsing activity also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.

7. Links to third-party websites

When you access and use the Software you may find links to non-Web3Password third party websites. A link to any non-Web3Password website does not imply that Web3Password endorses the privacy policy (if any) of the third party or accepts any responsibility for any privacy policy they may have. Web3Password has no control over how the third party will handle your personal data.

8. Cross-border transfers of personal data

8.1. To facilitate our Software and Services, we may store, access, and transfer personal data from around the world, including in countries where Web3Password has operations. These locations may not guarantee the same level of protection of personal data as the one in which you reside. We assess the circumstances involving all cross-border data transfers and have suitable safeguards in place to require that your personal data will remain protected in accordance with this Privacy Policy. For example, in case your personal data is transferred to countries outside the EEA, we make sure there is an adequacy decision from the European Commission with regards to the recipient country or we use standard contractual clauses approved by the European Commission for such transfer of your personal data.

8.2. For the purposes of the PDPA, you consent to the transfer of your personal data to countries outside of Singapore. If your personal data is transferred out of Singapore, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

9. Testimonials

You hereby consent to our posting your testimonial along with your name. If you wish to withdraw your consent, or if you wish to update or delete your testimonial, please contact us at dpo@web3password.com.

10. Country-specific provisions

10.1. The terms of this Privacy Policy are applicable to all users of the Software and Services regardless of location.

10.2. Nothing in this Privacy Policy is intended to subject or be construed as having the effect of subjecting, Web3Password to the laws of any jurisdiction other than Singapore.

10.3. For users in the EEA. If you are resident in an EEA country, you can exercise your rights as provided in the European Unions' General Data Protection Regulation (GDPR) by contacting us at dpo@web3password.com.

10.4. For users in California. If you are resident in California, you can exercise your rights as provided in the CCPA by contacting us at dpo@web3password.com.

11. Privacy Shield

11.1. Web3Password complies with the EU-U.S., Swiss-U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Information transferred from the European Union, United Kingdom (UK) and Switzerland, as applicable, to the United States in reliance on Privacy Shield. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov.

11.2. Web3Password complies with the PDPA.

11.3. Web3Password complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

12. Limitation of liability

To ensure the security of personal data, Web3Password employs various technical, physical, and organisational security measures. However, it is your responsibility to exercise caution and reason when using the Software and Services. You will be personally liable if your use of the Software and Services violates any third-party privacy or any other rights or any applicable laws. Under no circumstances is Web3Password liable for the consequences of your unlawful, wilful and negligent activities, and any circumstances that may not have been reasonably controlled or foreseen. Please refer to the Terms of Use for more information.

13. Prevailing language

13.1. For all purposes, the English language version of the Privacy Policy shall be the original, governing instrument and understanding between you and us. In the event of any conflict between this English language version of the Privacy Policy and any subsequent translation into any other language, the English language version shall govern and control.

14. Questions

14.1. If you have questions about our Privacy Policy, email us at dpo@web3password.com.