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1 <?xml version="1.0" encoding="utf-8"?> 2 <!DOCTYPE document PUBLIC "+//IDN docutils.sourceforge.net//DTD Docutils Generic//EN//XML" "http://docutils.sourceforge.net/docs/ref/docutils.dtd"> 3 <!-- Generated by Docutils 0.16 --> 4 <document source="/research/anastasis/anastasis/contrib/pp/pp.rst"> 5 <section ids="privacy-policy" names="privacy\ policy"> 6 <title>Privacy Policy</title> 7 <paragraph>Last Updated: 07.09.2021</paragraph> 8 <paragraph>This Privacy Policy describes the policies and procedures of Anastasis 9 SARL (“we,” “our,” or “us”) pertaining to the collection, use, and 10 disclosure of your information on our sites and related mobile 11 applications and products we offer (the “Services”). This Privacy 12 Statement applies to your personal data when you use our Services, and 13 does not apply to online websites or services that we do not own or 14 control.</paragraph> 15 <section ids="overview" names="overview"> 16 <title>Overview</title> 17 <paragraph>Your privacy is important to us. We follow a few fundamental 18 principles: We don’t ask you for personally identifiable information 19 (defined below). That being said, your contact information, such as 20 your phone number, social media handle, or email address (depending on 21 how you contact us), may be collected when you communicate with us, 22 for example to report a bug or other error related to Anastasis. We 23 don’t share your information with third parties except when strictly 24 required to deliver you our Services and products, or to comply with 25 the law. If you have any questions or concerns about this policy, 26 please reach out to us at <reference refuri="mailto:privacy@anastasis.lu">privacy@anastasis.lu</reference>.</paragraph> 27 </section> 28 <section ids="how-you-accept-this-policy" names="how\ you\ accept\ this\ policy"> 29 <title>How you accept this policy</title> 30 <paragraph>By using our Services or visiting our sites, you agree to the use, disclosure, 31 and procedures outlined in this Privacy Policy.</paragraph> 32 </section> 33 <section ids="what-personal-information-do-we-collect-from-our-users" names="what\ personal\ information\ do\ we\ collect\ from\ our\ users?"> 34 <title>What personal information do we collect from our users?</title> 35 <paragraph>The information we collect from you falls into two categories: (i) personally 36 identifiable information (i.e., data that could potentially identify you as an 37 individual) (“Personal Information”), and (ii) non-personally identifiable 38 information (i.e., information that cannot be used to identify who you are) 39 (“Non-Personal Information”). This Privacy Policy covers both categories and 40 will tell you how we might collect and use each type.</paragraph> 41 <paragraph>We do our best to not collect any Personal Information from Anastasis 42 users. The detailed Personal Information Anastasis asks from you during 43 the regular backup and recovery process at the beginning is never shared 44 with us and only used to create a cryptographic account identifier which 45 does not allow us to recover any of your details.</paragraph> 46 <paragraph>That being said, when using our Services to recover key material, we may 47 inherently receive the following information (depending on your choice of 48 authentication method):</paragraph> 49 <block_quote> 50 <bullet_list bullet="*"> 51 <list_item> 52 <paragraph>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.</paragraph> 53 </list_item> 54 <list_item> 55 <paragraph>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.</paragraph> 56 </list_item> 57 <list_item> 58 <paragraph>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.</paragraph> 59 </list_item> 60 <list_item> 61 <paragraph>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.</paragraph> 62 </list_item> 63 <list_item> 64 <paragraph>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.</paragraph> 65 </list_item> 66 </bullet_list> 67 </block_quote> 68 </section> 69 <section ids="how-we-collect-and-process-information" names="how\ we\ collect\ and\ process\ information"> 70 <title>How we collect and process information</title> 71 <paragraph>We may process your information for the following reasons:</paragraph> 72 <block_quote> 73 <bullet_list bullet="*"> 74 <list_item> 75 <paragraph>to authenticate you during secret recovery</paragraph> 76 </list_item> 77 <list_item> 78 <paragraph>to support you using Anastasis when you contact us</paragraph> 79 </list_item> 80 </bullet_list> 81 </block_quote> 82 </section> 83 <section ids="how-we-share-and-use-the-information-we-gather" names="how\ we\ share\ and\ use\ the\ information\ we\ gather"> 84 <title>How we share and use the information we gather</title> 85 <paragraph>We may share your authentication data with other providers that assist 86 us in performing the authentication. We will try to use providers that 87 to the best of our knowledge respect your privacy and have good 88 privacy practices. We reserve the right to change authentication 89 providers at any time to ensure availability of our services.</paragraph> 90 <paragraph>We primarily use the limited information we receive directly from you to 91 enhance Anastasis. Some ways we may use your Personal Information are 92 to: Contact you when necessary to respond to your comments, answer your 93 questions, or obtain additional information on issues related to bugs or 94 errors with the Anastasis application that you reported.</paragraph> 95 </section> 96 <section ids="agents-or-third-party-partners" names="agents\ or\ third\ party\ partners"> 97 <title>Agents or third party partners</title> 98 <paragraph>We may provide your Personal Information to our employees, contractors, 99 agents, service providers, and designees (“Agents”) to enable them to perform 100 certain services for us exclusively, including: improvement and maintenance of 101 our software and Services. By accepting this Privacy Policy, as outlined 102 above, you consent to any such transfer.</paragraph> 103 </section> 104 <section ids="protection-of-us-and-others" names="protection\ of\ us\ and\ others"> 105 <title>Protection of us and others</title> 106 <paragraph>We reserve the right to access, read, preserve, and disclose any information 107 that we reasonably believe is necessary to comply with the law or a court 108 order.</paragraph> 109 </section> 110 <section ids="what-personal-information-can-i-access-or-change" names="what\ personal\ information\ can\ i\ access\ or\ change?"> 111 <title>What personal information can I access or change?</title> 112 <paragraph>You can request access to the information we have collected from 113 you. You can do this by contacting us at <reference refuri="mailto:privacy@anastasis.lu">privacy@anastasis.lu</reference>. We will 114 make sure to provide you with a copy of the data we process about 115 you. To comply with your request, we may ask you to verify your 116 identity. We will fulfill your request by sending your copy 117 electronically. For any subsequent access request, we may charge you 118 with an administrative fee. If you believe that the information we 119 have collected is incorrect, you are welcome to contact us so we can 120 update it and keep your data accurate. Any data that is no longer 121 needed for purposes specified in the “How We Use the Information We 122 Gather” section will be deleted after ninety (90) days.</paragraph> 123 </section> 124 <section ids="data-retention" names="data\ retention"> 125 <title>Data retention</title> 126 <paragraph>Information entered into our bug tracker will be retained indefinitely 127 and is typically made public. We will only use it to triage the 128 problem. Beyond that, we do not retain personally identifiable 129 information about our users for longer than one week.</paragraph> 130 </section> 131 <section ids="data-security" names="data\ security"> 132 <title>Data security</title> 133 <paragraph>We are committed to making sure your information is protected. We employ 134 several physical and electronic safeguards to keep your information safe, 135 including encrypted user passwords, two factor verification and authentication 136 on passwords where possible, and securing connections with industry standard 137 transport layer security. You are also welcome to contact us using GnuPG 138 encrypted e-mail. Even with all these precautions, we cannot fully guarantee 139 against the access, disclosure, alteration, or deletion of data through 140 events, including but not limited to hardware or software failure or 141 unauthorized use. Any information that you provide to us is done so entirely 142 at your own risk.</paragraph> 143 </section> 144 <section ids="changes-and-updates-to-privacy-policy" names="changes\ and\ updates\ to\ privacy\ policy"> 145 <title>Changes and updates to privacy policy</title> 146 <paragraph>We reserve the right to update and revise this privacy policy at any time. We 147 occasionally review this Privacy Policy to make sure it complies with 148 applicable laws and conforms to changes in our business. We may need to update 149 this Privacy Policy, and we reserve the right to do so at any time. If we do 150 revise this Privacy Policy, we will update the “Effective Date” at the top 151 of this page so that you can tell if it has changed since your last visit. As 152 we generally do not collect contact information and also do not track your 153 visits, we will not be able to notify you directly. However, Anastasis clients 154 may inform you about a change in the privacy policy once they detect that the 155 policy has changed. Please review this Privacy Policy regularly to ensure that 156 you are aware of its terms. Any use of our Services after an amendment to our 157 Privacy Policy constitutes your acceptance to the revised or amended 158 agreement.</paragraph> 159 </section> 160 <section ids="international-users-and-visitors" names="international\ users\ and\ visitors"> 161 <title>International users and visitors</title> 162 <paragraph>Our Services are (currently) hosted in Germany. If you are a user 163 accessing the Services from the Switzerland, Asia, US, or any other 164 region with laws or regulations governing personal data collection, 165 use, and disclosure that differ from the laws of Germany, please be 166 advised that through your continued use of the Services, which is 167 governed by the law of the country hosting the service, you are 168 transferring your Personal Information to Germany and you consent to 169 that transfer.</paragraph> 170 </section> 171 <section ids="questions" names="questions"> 172 <title>Questions</title> 173 <paragraph>Please contact us at <reference refuri="mailto:privacy@anastasis.lu">privacy@anastasis.lu</reference> if you have questions about our 174 privacy practices that are not addressed in this Privacy Statement.</paragraph> 175 </section> 176 </section> 177 </document>