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+Privacy Policy
+**************
+
+Last Updated: 07.09.2021
+
+This Privacy Policy describes the policies and procedures of Anastasis
+SARL (“we,” “our,” or “us”) pertaining to the collection, use, and
+disclosure of your information on our sites and related mobile
+applications and products we offer (the “Services”). This Privacy
+Statement applies to your personal data when you use our Services, and
+does not apply to online websites or services that we do not own or
+control.
+
+
+Overview
+========
+
+Your privacy is important to us. We follow a few fundamental
+principles: We don’t ask you for personally identifiable information
+(defined below). That being said, 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,
+for example to report a bug or other error related to Anastasis. We
+don’t share your information with third parties except when strictly
+required to deliver you our Services and products, or to comply with
+the law. If you have any questions or concerns about this policy,
+please reach out to us at privacy@anastasis.lu.
+
+
+How you accept this policy
+==========================
+
+By using our Services or visiting our sites, you agree to the use,
+disclosure, and procedures outlined in this Privacy Policy.
+
+
+What personal information do we collect from our users?
+=======================================================
+
+The information we collect from you falls into two categories: (i)
+personally identifiable information (i.e., data that could potentially
+identify you as an individual) (“Personal Information”), and (ii) non-
+personally identifiable information (i.e., information that cannot be
+used to identify who you are) (“Non-Personal Information”). This
+Privacy Policy covers both categories and will tell you how we might
+collect and use each type.
+
+We do our best to not collect any Personal Information from Anastasis
+users. The detailed Personal Information Anastasis asks from you
+during the regular backup and recovery process at the beginning is
+never shared with us and only used to create a cryptographic account
+identifier which does not allow us to recover any of your details.
+
+That being said, when using our Services to recover key material, we
+may inherently receive the following information (depending on your
+choice of authentication method):
+
+ * Bank account details necessary when receiving funds from you to
+ authenticate via a SEPA transfer. We will store these as part of
+ our business records for accounting, and our bank will also be
+ legally obliged to store the details for many years.
+
+ * Your phone number when using SMS authentication. We rely on third
+ party providers (such as your mobile network operator) to deliver
+ the SMS to you. These third parties will see the SMS message sent
+ to you and could thus learn that you are using Anastasis. SMS is
+ inherently insecure, and you should expect many governments and
+ private parties to be able to observe these messages. However,
+ we do not store your SMS number on our systems, except maybe in
+ short-term logs to diagnose errors.
+
+ * Your e-mail address when using E-mail authentication. We rely on
+ the Internet and your E-mail provider to deliver the E-mail to
+ you. Internet service providers will see the E-mail message sent
+ to you and could thus learn that you are using Anastasis. E-mail
+ is inherently insecure, and you should expect many governments
+ and private parties to be able to observe these messages.
+ However, we do not store your E-mail address on our systems,
+ except maybe in short-term logs to diagnose errors.
+
+ * Your physical address when using postal mail authentication. We
+ rely on external providers for printing and sending the letter to
+ you. These providers will need to learn your address and could
+ learn that you are using Anastasis. Physical mail has strict
+ privacy protections by law, but governments are known to break
+ postal secrecy. We do not store your physical address on our
+ systems, except maybe in short-term logs to diagnose errors.
+
+ * When you contact us. We may collect certain information if you
+ choose to contact us, for example to report a bug or other error
+ with the Taler Wallet. This may include contact information such
+ as your name, email address or phone number depending on the
+ method you choose to contact us.
+
+
+How we collect and process information
+======================================
+
+We may process your information for the following reasons:
+
+ * to authenticate you during secret recovery
+
+ * to support you using Anastasis when you contact us
+
+
+How we share and use the information we gather
+==============================================
+
+We may share your authentication data with other providers that assist
+us in performing the authentication. We will try to use providers that
+to the best of our knowledge respect your privacy and have good
+privacy practices. We reserve the right to change authentication
+providers at any time to ensure availability of our services.
+
+We primarily use the limited information we receive directly from you
+to enhance Anastasis. Some ways we may use your Personal Information
+are to: Contact you when necessary to respond to your comments, answer
+your questions, or obtain additional information on issues related to
+bugs or errors with the Anastasis application that you reported.
+
+
+Agents or third party partners
+==============================
+
+We may provide your Personal Information to our employees,
+contractors, agents, service providers, and designees (“Agents”) to
+enable them to perform certain services for us exclusively, including:
+improvement and maintenance of our software and Services. By accepting
+this Privacy Policy, as outlined above, you consent to any such
+transfer.
+
+
+Protection of us and others
+===========================
+
+We reserve the right to access, read, preserve, and disclose any
+information that we reasonably believe is necessary to comply with the
+law or a court order.
+
+
+What personal information can I access or change?
+=================================================
+
+You can request access to the information we have collected from you.
+You can do this by contacting us at privacy@anastasis.lu. 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 fulfill 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.
+
+
+Data retention
+==============
+
+Information entered into our bug tracker will be retained indefinitely
+and is typically made public. We will only use it to triage the
+problem. Beyond that, we do not retain personally identifiable
+information about our users for longer than one week.
+
+
+Data security
+=============
+
+We are committed to making sure your information is protected. 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 connections with industry standard transport layer security.
+You are also welcome to contact us using GnuPG encrypted e-mail. 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.
+
+
+Changes and updates to privacy policy
+=====================================
+
+We reserve the right to update and revise this privacy policy at any
+time. We occasionally review this Privacy Policy to make sure it
+complies with applicable laws and conforms to changes in our business.
+We may need to update this Privacy Policy, and we reserve the right to
+do so at any time. If we do revise this Privacy Policy, we will update
+the “Effective Date” at the top of this page so that you can tell if
+it has changed since your last visit. As we generally do not collect
+contact information and also do not track your visits, we will not be
+able to notify you directly. However, Anastasis clients may inform you
+about a change in the privacy policy once they detect that the policy
+has changed. Please review this Privacy Policy regularly to ensure
+that you are aware of its terms. Any use of our Services after an
+amendment to our Privacy Policy constitutes your acceptance to the
+revised or amended agreement.
+
+
+International users and visitors
+================================
+
+Our Services are (currently) hosted in Germany. If you are a user
+accessing the Services from the Switzerland, Asia, US, or any other
+region with laws or regulations governing personal data collection,
+use, and disclosure that differ from the laws of Germany, please be
+advised that through your continued use of the Services, which is
+governed by the law of the country hosting the service, you are
+transferring your Personal Information to Germany and you consent to
+that transfer.
+
+
+Questions
+=========
+
+Please contact us at privacy@anastasis.lu if you have questions about
+our privacy practices that are not addressed in this Privacy
+Statement.