Privacy Policy

(Avelot Limited product Privacy Policy)

This document is the Privacy Policy of Avelot Limited (hereinafter the Policy) and is an integral part of all legal documents of the product of AMLSafe (hereinafter – AMLSafe).

The product of AMLSafe belongs to Avelot Limited, a company incorporated in Hong Kong, under the company number 2741105 and registered address Room 747, 7/F, Star House, 3 Salisbury Road, Tsim Sha Tsui, Hong Kong.

This Privacy Policy covers the treatment of the personal information gathered by AMLSafe when you use or access www.amlsafe.io (the Site), related mobile applications and products we offer (the Services). By using our Services, You (hereinafter – referred to as the User and You) accept and agree also with this Policy.

Your privacy is important to us. We don’t ask You for personally identifiable information (i.e., data that could potentially identify You as an individual). At the same time, your contact information, such as your phone number, social media handle, or email address (depending on how You contact us), may be collected when You communicate with us or if You report a bug or other error related to AMLSafe. We don’t share your information with third parties except to deliver You our Services, comply with the law, make AMLSafe better, protect our rights, or effectuate a business transfer. If You have any questions or concerns about this policy, please reach out to us at support@amlsafe.io.

We don’t have access to your funds (private keys). Your private keys will stay on your device. Your camera will only be used for reading QR codes. Our services will never send your camera images to our servers. All of our servers support HTTPS.

HOW YOU ACCEPT THIS POLICY

By using AMLSafe, including downloading one of our mobile applications, visiting our website, You agree to the use, disclosure, and procedures outlined in this Policy.  It’s your own responsibility to read the Privacy Policy carefully before you start to use AMLSafe.

IF You DO NOT AGREE TO THIS POLICY, PLEASE DO NOT USE OUR SERVICES OR SITE.

 

  1. PERSONAL DATA WE COLLECT

AMLSafe may collect personal information about You as described in the Policy when You (i) register for the Site and the Services, through your account, (ii) use the Services, (iii) or interact with a third-party which is a supplier, provider or partner of AMLSafe. AMLSafe collects the following types of information from You, some of which might be considered personal information under applicable law.

1.1. Information that Users provide us during registration and use of the Services. 

This information may include data that the User transmits, filling out forms on the Site during the registration, when making purchase and deals, subscribing to our news. We do collect PUBlIC wallet addresses that You generate through AMLSafe. Further, we may collect some personal information from You when You communicate with us, including your contact information, such as your phone number, social media handle, or email address (depending on how You reach out). Information You create through the Site or mobile applications, including public wallet addresses. 

1.2. Information collected to optimize the experience of the User and to improve the quality of the Services.

Like other online services, we also collect a variety of non-personal information: technical information, including the internet protocol (IP) address used to connect the computer or another device to the internet, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; information about the visit of the Site, including the URL clickstream to, through and from our Site (including date and time); pages You viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call customer support service; information about geolocation of the User; financial data and information on the use of AMLSafe Services; the website address, if any, that linked You to AMLSafe; the website address, if any, You leave the Site and travel to; and other non-personally identifiable traffic data.

1.3 Personal information about children

Our Services are not targeted towards children, and we don’t knowingly collect information from children under the age of 13. If you are a parent or legal guardian of a minor child, we will treat any information that you provide us while using AMLSafe on behalf of your minor child as personal information as otherwise provided in the Policy. If you have questions concerning our information practices with respect to children, or if you learn that a child under the age of 13 has used AMLSafe, created a user account, or provided us with personal information, please email us at support@amlsafe.io. 

  1. HOW WE COLLECT INFORMATION

When You Contact Us. We may collect certain information if You choose to contact us, if You use the Services or if You report a bug or other error with AMLSafe. This may include contact information such as your name, email address, phone number, and public wallet address. We, or companies that provide services on our behalf, may also collect certain non-personal information from You, such as your locally hosted public wallet (a “Wallet”) addresses.

2.1 Information We Automatically Collect

Users who visit our website or use our application may have their device’s IP address logged for the purpose of generating anonymous statistics or troubleshooting the performance of our web servers. Your IP address will not be used to track or identify You, but may be used to determine your geographic location in order to determine which of our services You are presented with. Users of the Site or mobile applications will receive an anonymous unique device id (“UDID”) for the purpose of identifying the device to AMLSafe servers. This UDID will not be tied to users’ identities, but will be used for debugging purposes and to differentiate devices when users access the Services using multiple devices.

2.2 Third-Party Services

Certain features on AMLSafe rely on various third-party products and services (collectively the Third-Parties), such as the Ethereum network, Google Analytics, Apple’s application platform, Kuna.io, Paymir.io. These services may collect certain personal information, such as your public Wallet addresses. 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 the Third-Parties where required to do so by law, or where the 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 the Site, 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-Parties 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.

  1. PURPOSE OF USE OF PERSONAL DATA

We primarily use the limited information we collect to enhance AMLSafe. Except if we sell all or a portion of our business, or as otherwise described below, we do not rent, trade, or sell your personal information. Use of Information to provide AMLSafe to You some ways we may use your personal information are to: contact You when necessary; respond to your comments, questions, or issues related to bugs or errors with AMLSafe; provide You with additional information; send You information and marketing materials about services and products available through AMLSafe, using push notifications or other means; train our team members; or other internal business purposes. Aggregated personal data and non-personal information we may share or disclose them with service providers or with other persons we conduct business with, including but not limited potential third-parties for the purpose of showcasing the performance of the company. These service providers and other persons may also share with us aggregated non-personal information that they have independently developed or acquired. Additionally, we may combine aggregate information from the pixel tags, web beacons, and cookies with similar data we collect from other visitors to help us improve the Services. When doing so, we do our best to ensure that any aggregated information cannot be linked back to You. AMLSafe may use personal information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, prevention of fraudulent, malicious and unlawful activities, or any other purpose disclosed to You at the time You provide personal information or allowed by law.

  1. LEGAL GROUNDS OF PERSONAL DATA PROCESSING

AMLSafe collects and processes personal data of Users only when a legitimate reason for such processing exists. Legal grounds include consent given by the User, a contract between AMLSafe and User, compliance with a legal obligations in cases where AMLSafe is required to request, process and to store personal data of User in order to comply with the requirements of applicable laws, and legitimate interest, compliance with the provisions of applicable laws, the proper level of conduct of our business conclusion and implementation of corporate transactions. In cases where the basis for data processing is the consent of the User, the latter has the right to withdraw it at any time. AMLSafe will ask You for permission before You authorize our collection of this information. AMLSafe will only use that information for the specific reason for which it was provided to us. AMLSafe may also collect information about how You are using the Services to interact with those connected the Third-Parties. Note that the Third-Parties may have the ability to restrict the information that is provided to AMLSafe based on your privacy settings of that account. To enable us to infer the location from the IP addresses of computers or devices that visit the Site or click, AMLSafe receives IP-based location information from the Third-Parties’ provider.

  1. USER RIGHTS AND CONSENT

Users have the following rights in relation to their personal data: the right to delete personal data; the right to change or correct their personal data, in particular when they are incorrectly indicated; the right to challenge or limit the processing of their personal data; the right to access personal data stored by AMLSafe; the right to prohibit the use of personal data for marketing and promotional purposes. User can use the right to prohibit the processing of personal data for promotional purposes by contacting support service any time. AMLSafe will share information about You when You instruct us to do so, such as when You share content with others through the Services or if we notify You that the information You provide will be shared in a particular manner and You provide such information (like sharing/posting it with a third-party service).

You can request access to the personal data by contacting us at support@amlsafe.io. We will make sure to provide you with a copy of the data we process about you. To comply with your request, we may ask you to verify your identity. We will fulfil your request by sending your copy electronically. For any subsequent access request, we may charge you with an administrative fee. If you believe that the information, we have collected is incorrect, you are welcome to contact us so we can update it and keep your data accurate. Any data that is no longer needed for purposes specified in the “How We Use the Information We Gather” section will be deleted after ninety (90) days. Wallet addresses created through the AMLSafe application cannot be deleted from the Ethereum blockchain, therefore we are unable to delete this personal information. If at any point you wish for AMLSafe to delete information about you, you may contact us at support@amlsafe.io.

  1. ACCOUNT INFORMATION SECURITY

User Account information is protected by a password for your privacy and security. You can prevent unauthorized access to your User Account by selecting and protecting your password appropriately, making use of two-factor authentication, and limiting access to your devices by signing off after You have finished accessing your User Account. We are committed to making sure your information is protected and have selected the Third-Parties which use the Ethereum network, that helps keep your personal information safe. Unfortunately, we do not control the Third-Parties and therefore cannot guarantee complete security. We employ several physical and electronic safeguards to keep your information safe, including encrypted user passwords, two-factor verification and authentication on passwords where possible, and securing all connections with industry standard transport layer security. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk. In the event we experience a breach of security, we will promptly notify You if your personal information has been compromised, in accordance with applicable law.

  1. DISCLOSURE OF PERSONAL DATA AND THIRD-PARTY SERVICES

AMLSafe has software integrations with Third-Party services. If you do use third-party services through our Services then they will be clearly marked and there may be other terms or privacy policies that apply.

AMLSafe may share personal data of Users to the Third-Parties in the following cases: if AMLSafe is required to disclose or transfer personal data of the user in accordance with any applicable laws or within the implementation of decisions of the relevant courts, or AMLSafe is compelled to force users to comply with the terms and conditions of the agreements concluded with AMLSafe; in case it is necessary to protect own rights, own property, to guarantee the safety of AMLSafe, our users or others. AMLSafe may share personal data of Users with selected third parties including: business partners, suppliers and sub-contractors for the performance of any contract Service or User enter with; analytics and search engine providers that assist AMLSafe in the improvement and optimization of AMLSafe Services. The Site may contain active links to third-party web-sites, including web-sites of partners, affiliated companies, service providers. If the User follows any of the active links to the third party’s website, he/she must understand that his/her relations with such third parties are governed by other rules and policies of such websites and third parties. AMLSafe will not be liable for the actions of such third parties with respect to users’ personal data. This Privacy Policy does not apply to the practices of other businesses that AMLSafe does not own or control, including other companies’ websites, services and applications (the Third-Parties) that You can access through the AMLSafe Services, or to individuals that AMLSafe does not manage or employ. AMLSafe cannot take responsibility for the content or privacy policies of those Third-Parties. AMLSafe encourages You to review the privacy policies of any third party services You access.

  1. RETENTION

We retain the personal information we receive as described in this Privacy Policy for as long as You use the Services or as necessary to fulfil the purpose(s) for which it was collected, provide the Services, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. If you delete your Wallet or addresses from the AMLSafe Android mobile application, uninstall AMLSafe mobile applications from your device, or request that your information be deleted, we still may retain some information that you have provided to us to maintain AMLSafe or to comply with relevant laws.

  1. DATA PROTECTION SUPERVISORY AUTHORITY

AMLSafe business is regulated by the legislation of Hong Kong and the personal data processing is conducted according to the Personal Data (Privacy) Ordinance (the PDPO). AMLSafe Data Protection Supervisory Authority in terms of data protection is the Privacy Commissioner for Personal Data (PCPD). The Users may contact the authority at address: Room 1303, 13/F, Sunlight Tower, 248 Queen’s Road East, Wanchai, Hong Kong, or via e-mail: enquiry@pcpd.org.hk, if they wish to discuss with them any instance where they feel AMLSafe may not be adhering to the terms within this Policy or to raise a complaint.

  1. CHANGES AND AMENDMENTS OF POLICY

We reserve the right to update and revise this privacy policy at any time. We occasionally review the Policy to make sure it complies with applicable laws and conforms to changes in our business. We may need to update the Policy, and we reserve the right to do so at any time. If we do revise the Policy, we will update the “Effective Date” at the bottom of this page so that You can tell if it has changed since your last visit and will do our best to notify you. Please review the Policy regularly to ensure that You are aware of its terms. Any use of AMLSafe after an amendment to the Policy constitutes your acceptance to the revised or amended agreement. 

  1. CONTACT

If You have any questions regarding the content of this Policy or the procedure for processing Personal Data, please contact us by email at support@amlsafe.io.

Thanks for reading our Privacy Policy!