Privacy Policy

Effective date: 21/11/2023

1. Introduction

Welcome to Wigwam.

Wigwam (“we”, “us” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website at https://wigwam.app (the “Site”) and the services available through our Site, including any mobile applications, web applications and browser extensions (collectively, the “Services”), and how we use and disclose that information.

By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site or Services, and any dispute over privacy, is subject to this Policy (including any applicable changes) and an applicable Terms of Use, including its applicable limitations on damages and provisions for the resolution of disputes.

2. Definitions

SERVICES

https://wigwam.app (the “Site”) and the services available through this site, including any mobile applications, web applications and browser extensions.

PERSONAL DATA means data about a living individual who can be identified from that data (or from those and other information either in our possession or likely to come into our possession).

USAGE DATA is data collected automatically either generated by the use of Services or from Services infrastructure itself (for example, the duration of a page visit).

COOKIES are small files stored on your device (computer or mobile device).

DATA CONTROLLER means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal data are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your data.

DATA PROCESSORS (OR SERVICE PROVIDERS) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.

DATA SUBJECT is any living individual who is the subject of Personal Data.

THE USER is the individual using our Services. The User corresponds to the Data Subject, who is the subject of Personal Data.

3. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

4. Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

  • Email address
  • Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or by emailing at [email protected].

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access Service by or through a mobile device (“Usage Data”).

This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

To know more information about Cookies read our Cookies Policy.

In Wigwam application

In the Wigwam application we may track only these types of anonymous data: anonymized clicks and pageview events. More information you may find in the 13.2.1 point of this agreement.

5. Use of Data

Wigwam uses the collected data for various purposes:

  • to provide and maintain our Services;
  • to notify you about changes to our Services;
  • to allow you to participate in interactive features of our Services when you choose to do so;
  • to provide customer support;
  • to gather analysis or valuable information so that we can improve our Services;
  • to monitor the usage of our Services;
  • to detect, prevent and address technical issues;
  • to fulfill any other purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to provide you with notices about your account and/or subscription, including expiration and renewal notices, email-instructions, etc.;
  • to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information;
  • in any other way we may describe when you provide the information;
  • for any other purpose with your consent.

6. Retention of Data

We will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to - and maintained on - computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Wigwam will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organisation or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

We may disclose personal information that we collect, or you provide:

  • Business Transaction.
  • If we or our subsidiaries are involved in a merger, acquisition or asset sale, your Personal Data may be transferred.
  • Other cases. We may disclose your information also:
  • to our subsidiaries and affiliates;

9. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

10. Your Data Protection Rights Under General Data Protection Regulation (GDPR)

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. - See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please email us at [email protected]. In certain circumstances, you have the following data protection rights:

  • the right to access, update or to delete the information we have on you;
  • the right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete;
  • the right to object. You have the right to object to our processing of your Personal Data;
  • the right of restriction. You have the right to request that we restrict the processing of your personal information;
  • the right to data portability. You have the right to be provided with a copy of your Personal Data in a structured, machine-readable and commonly used format;
  • the right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information;

Please note that we may ask you to verify your identity before responding to such requests.

Please note, we may not be able to provide Services without some necessary data.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

11. Your Data Protection Rights under the California Privacy Protection Act (CalOPPA)

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law's reach stretches well beyond California to require a person or company in the United States (and conceivable the world) that operates websites collecting personally identifiable information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. - See more at: https://consumercal.org/about-cfc/cfc-education-foundation/california-online-privacy-protection-act-caloppa-3/.

According to CalOPPA we agree to the following:

  • users can visit our site anonymously;
  • our Privacy Policy link includes the word “Privacy”, and can easily be found on the page specified above on the home page of our website;
  • users will be notified of any privacy policy changes on our Privacy Policy Page;
  • users are able to change their personal information by emailing us at [email protected].

Our Policy on “Do Not Track” Signals:

We honor Do Not Track signals and do not track, plant cookies, or use advertising when a Do Not Track browser mechanism is in place. Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

12. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide Service on our behalf, perform Service-related services or assist us in analysing how our Services are used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

13. Analytics

We may use third-party Service Providers to monitor and analyze the use of our website and our applications.

13.1 Google Analytics on the website wigwam.app

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service.

This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

We also encourage you to review Google's policy for safeguarding your data: https://support.google.com/analytics/answer/6004245.

13.2.1 Amplitude in the Wigwam application

Amplitude is a product analytics platform that helps businesses to track visitors with the help of collaborative analytics. The platform uses event generated reports to understand users' interactions with products and provides insights to accelerate work on a real-time basis. Amplitude privacy notice may be found here: https://amplitude.com/privacy.

13.2.2. What events we are tracking with Amplitude:

We are improving the Wigwam application constantly and to better understand which section of the wallet should be updated, we gather anonymous usage data. This data will be used only for improving the usability of the Wigwam application.

What we track:

  1. Anonymized click
  2. Pageview events

We NEVER track:

  1. Keys
  2. Addresses
  3. Transactions
  4. Balances
  5. Hashes
  6. IP
  7. Any personal information

You may always turn off the analytics tracking feature in your wallet settings.

14. CI/CD tools

We may use third-party Service Providers to automate the development process of our Services.

  1. GitHub
  2. GitHub is provided by GitHub, Inc.
  3. GitHub is a development platform to host and review code, manage projects, and build software.

For more information on what data GitHub collects for what purpose and how the protection of the data is ensured, please visit GitHub Privacy Policy page: https://help.github.com/en/articles/github-privacy-statement.

15. Behavioral Remarketing

Wigwam website uses remarketing services to advertise on third party websites to you after you visited our website. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our website.

Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads.

Google also recommends installing the Google Analytics Opt-out Browser Add-on -https://tools.google.com/dlpage/gaoptout - for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt-out from Twitter's interest-based ads by following their instructions: https://support.twitter.com/articles/20170405.

You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy.

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950.

To opt-out from Facebook's interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217.

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook's Data Policy: https://www.facebook.com/privacy/explanation.

16. Links to Other Sites

Our Services may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

17. Children's Privacy

Our Services are not intended for use by children under the age of 13 (“Children”). We do not knowingly collect personally identifiable information from Children under 13. If you become aware that a Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers.

18. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Services, prior to the change becoming effective and update “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

19. Contact Us

If you have any questions about this Privacy Policy, please contact us by email: [email protected].