Who are we?

What’s this notice about?

This notice explains how we process your data in relation to:

• the SafeMoon Wallet mobile application (the “App”);

• the websites owned or operated by us, including without limitation www.safemoon.com, swap.safemoon.com, safemoon.education, and merch.safemoon.com (collectively, the “Properties”); and

• our other products and services,

(together, the “SafeMoon Products and Services”).

We may update this notice from time to time, so please check back in on a regular basis. Your continued use of SafeMoon Products and Services indicates your acceptance of the modified Privacy and Cookie Notice.

To the extent data is associated with an identified or identifiable natural person and is protected as personal data or similar designation under applicable data protection or privacy law, it is referred to in this notice as "personal data" and/or “personal information”.

Please note that the SafeMoon Products and Services may link to or mention websites, applications or services that are not operated by us, and you should refer to the privacy policies on those third-party websites, applications or services to understand how your personal data is being used.

What are your rights?

You have the following rights, although these rights may be limited in some circumstances, to:

• Ask us to send a copy of your personal data to you or someone else

• Ask us to restrict, stop processing, or delete your personal data

• Object to our processing of your personal data

• Object to use of your personal data for direct marketing purposes

• Ask us to correct inaccuracies in your personal data

If we rely on consent to process data, or send direct marketing, you can withdraw consent by email to the address below.

How do you contact us?

If you wish to exercise your rights under this policy, please contact us at: care@safemoon.com

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: legal@safemoon.ltd

If we can’t resolve your issue, you can also get in touch with the local data protection or consumer protection authority in your country (as applicable for your jurisdiction). For instance, if you live in the UK, you can get in touch with the Information Commissioner’s Office: https://ico.org.uk/concerns.
If you live in a country or jurisdiction other than the UK, you can submit a complaint to the supervisory authority or (if applicable) consumer protection authority in your country or jurisdiction.

Services and Products Data

Information that we collect about you to provide SafeMoon Products and Services to you, including:

• Name and/or username, Mnemonic phrase, unique device password, and any additional information (such as a profile picture or avatar) you provide when using SafeMoon Products and Services (e.g. when creating a wallet on the App)

• Information provided when making transactions via SafeMoon Products and Services (including without limitation, if relevant, the fiat and SafeMoon account balances)

• Information relating to previous transactions made via SafeMoon Products and Services (including without limitation information relating to transactions via the App such as "transactionHash", "blockHash", "blockNumber", "status", "type", "nonce", "transactionIndex", "from", "to", "amount", "tokenSymbol", "createdAt" and "gasUsed")

• If required for your use of any SafeMoon Products and Services, information for the purpose of verifying your identity in order to effectuate transactions and to prevent fraud or misuse, such as photo ID, date of birth, name, email, address and/or phone number, and other information as may be required by our Know Your Customer (KYC), Know Your Business (KYB), Anti Money Laundering (AML) and related service providers

• Firebase Cloud Messaging (FCM) tokens

• Information relating to your device, such as user agent string, timestamp, IP address, device identifier

• Any other personal data you provide to us in order for us to provide SafeMoon Products and Services to you (including information you send us as part of your enquiries)

• Information that we collect about you to fulfil your purchase of products or merchandise we may sell to you from time to time, such as: name, email address, telephone number, b, delivery address, information relating to your orders (e.g. products purchased), payment information, and any order- related correspondence between us and you.

We process this information: (a) to respond to your enquiries; (b) to provide SafeMoon Products and Services to you; (c) to manage risk, prevent fraud, misuse and/or unlawful acts in relation to use of the SafeMoon Products and Services, and (d) to understand how you use the SafeMoon Products and Services to improve them.

Legal basis for this processing

• (a) and (b): Entering or performing contracts with you, fulfilling your orders, and complying with legal obligations.

• (c) Our legitimate interests of managing risk and protecting the SafeMoon Products and Services from fraud, misuse, or unlawful acts.

• (d): Our legitimate interests of improving the SafeMoon Products and Services.

More information

You may be required to provide us with certain information for us to provide certain SafeMoon Products and Services to you.

Sources

We collect this personal data from you.

Recipients

We use a variety of service providers to assist us in providing SafeMoon Products and Services. A representative, non-exhaustive list of such service providers is as follows:

We use Zendesk, Inc. and its affiliated entities (“Zendesk”) for the provision of customer support (e.g. logging tickets when enquiries are made or bugs are reported). You can view Zendesk's privacy notice here: Privacy Policy (zendesk.co.uk).

We use Moon Pay PTE Limited and its affiliated entities (“MoonPay”) to process transactions made via various SafeMoon Products and Services. You can view MoonPay’s privacy notice here: https://www.moonpay.com/legal/privacy_policy.

We use Sum and Substance Ltd. (“SumSub”) to perform KYC and KYB services, and we use Chainalysis for transaction monitoring to detect and prevent fraud, misuse and/or unlawful acts in relation to use of the SafeMoon Products and Services. You can view SumSub’s privacy notice here: https://sumsub.com/privacy-notice/, and Chainalysis’s privacy notice here: https://www.chainalysis.com/privacy-policy/.

We use Shopify as our e-commerce platform for merchandise we sell. You can view Shopify's privacy notice here: https://www.shopify.com/legal/privacy

We may also use other service providers from time to time to assist us with the provision of SafeMoon Products and Services, which may include providing marketing and advertising services, order fulfilment, providing mailing or email services, tax and accounting services, fraud prevention, web hosting, or other services.

Marketing Data

Information that we collect to make suggestions and recommendations to you about: (i) news and updates relating to us, our partners or the SafeMoon Products and Services; (ii) content, and products and services that may interest you; and (iii) other promotional activity and events we think may be of interest, including:

• Email address

• Other information collected and clearly identifiable to you at the point of your signing up to our marketing communications

Legal basis for this processing

If required by law, we rely upon your consent for us to undertake this data processing activity. You can revoke your consent at any time by letting us know, including by emailing us.

In some instances (such as with some of our existing customers) the law may permit us to process your personal data to send marketing communications on the basis of our legitimate interests, being our legitimate business interests in marketing our activities and promoting the success of our business and the SafeMoon Products and Services. If the information is not of interest for you, you can opt-out at any time by letting us know, including by emailing us.

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with marketing and communication relating to the SafeMoon Products and Services, which may include providing promotional and advertising services, providing mailing or email services, and similar services.

Waiting List Data

Information that we collect about you when you sign-up to being notified of when a new service or product is available, or to joining a waiting list for a new product or service:

• Full name

• Email address

• Country of residence

• Any personal data you provide to us in response to questions that we ask you in relation to the new product or service, the sign-up process, or SafeMoon

We process this information: (a) to enable you to register your interest in the new product or service and receive updates on the new product or service; and (b) to collect your feedback on the new product or service, and SafeMoon Products and Services in general.

Legal basis for this processing

• (a): Your consent

• (b): Our legitimate interest of improving our services and products

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with marketing and communication relating to new products and services you have asked to be notified about, which may include providing promotional and advertising services, providing mailing or email services, and similar services.

Survey Data

Information that we collect about you when you respond to our surveys:

• Full name

• Email address

• Any personal data you provide to us in response to questions in our surveys

We process this information to understand your thoughts on SafeMoon Products and Services.

Legal basis for this processing

Our legitimate interests of improving our products and services.

Sources

We collect this personal data from you.

Recipients

We may use service providers from time to time to assist us with providing surveys and analysing and understanding survey results.

Technical Data

Information that we collect about the device on which you are using the SafeMoon Products and Services to tailor the delivery of the relevant SafeMoon Products and Services, including:

• Device type

• Geolocation data

We process this information: (a) to improve the delivery of the SafeMoon Products and Services and to customize your experience to your preferences (e.g., if you have selected “dark mode”); (b) to understand how you use the SafeMoon Products and Services to improve them; and (c) to distinguish between bot and human traffic.

Legal basis for this processing

• (a) and (b): Our legitimate interests of understanding website usage and improving the SafeMoon Products and Services.

Sources

We use Google’s services to collect this personal data from you when you use the SafeMoon Products and Services.

Recipients

Google in the USA collects and processes this information on our behalf.

Enquiry Data

Information that we collect to enable us to collect, record and properly respond to your submissions, enquiries and support requests in relation to the SafeMoon Products and Services and our marketing materials:

• Name

• Email address

• Any personal data you provide to us in your submissions, enquiries and support requests

We process this information: (a) to support our efforts to provide you with the best experience when using the SafeMoon Products and Services; (b) to improve the quality of the SafeMoon Products and Services, and provide a better experience to you; and (c) to identify and correct any bugs in the SafeMoon Products and Services.

Legal basis for this processing

Our legitimate interests of improving the SafeMoon Products and Services.

Sources

We collect this personal data from you.

Recipients

N/A

Cookie/data

Duration

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Up to 8 hours

To collect information about how visitors interact with the SafeMoon Products and Services and generate reports to identify problems, understand how visitors use the SafeMoon Products and Services, and improve them.

We use Google Analytics to set these cookies.

You can find out more about how Google uses data by clicking here.

You can opt-out here by installing the Google Analytics Opt-out Browser Add-on: Google Analytics.

Data retention

We hold personal data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain information to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the personal data, the potential risk of unauthorised access, and legal requirements.

Disclosure

Other than as set out above, we may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, service providers, investigators, or credit reference agencies).

• With members of our corporate group, suppliers and subcontractors, as necessary for the purposes set out in this notice.

• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

Data controller

Where we decide the means or purpose of processing your personal data, we are the “data controller."

Storage & Transfers

Where we use data processors outside the UK and EEA, and/or transfer personal data to a country which does not provide an adequate level of protection, we use contracts which give personal data the same protection it has in Europe and the UK. For more information drop us a line using the contact details at the “How do you contact us” section under the “Introduction” heading above.

Data Subject Access Requests

Please see the section entitled “What are your rights?” under the “Introduction” heading above.

Contacting Us

Please see the section entitled “How do you contact us?” under the “Introduction” heading above.

Right to Know

You may have the right, depending on your jurisdiction, to request the following about the personal information we have collected about you during the past 12 months:

• The categories and specific pieces of personal information we have collected about you;

• The categories of sources from which we collected the personal information;

• The business or commercial purpose for which we collected the personal information;

• The categories of third parties with whom we shared the personal information;

• The categories of personal information about you that we disclosed for a business purpose, and the categories of third parties to whom we disclosed that information for a business purpose;

• The right to receive requested information in a readily-usable format if provided electronically; and

• The right to update or correct any personal information which is out of date or incorrect.

To make a request, see the “How do you contact us” section under the “Introduction” heading above.

You may also have the right to ask if we disclose your personal information to third parties for their direct marketing purposes (we do not). It also gives you the right to ask if we sell your personal information to third parties (we do not, and have not done so in the past), and if we did (which we don’t), you would have the right to opt out of such sales.

Additional information about the categories of information we collect and its usage and sharing are located under the sections entitled “Your Data and How We Use It”, “Cookies, Analytics and Similar Technologies”, and “Data Retention and Disclosure”, above.

Right of Deletion

You have the right to ask us to delete the personal information we have collected from you, subject to exceptions the law provides. Please note that you may no longer be able to use the SafeMoon Products and Services if you delete your personal information.

Right of Non-Discrimination

You have the right to not be discriminated against if you exercise these privacy rights. We will not discriminate against you, deny, charge different prices for, or provide a different quality of goods or services if you choose to exercise these rights.

How to Exercise Your Rights

If you live in a relevant jurisdiction and would like to send us a request to exercise one of your above rights, you may do so by contacting us as indicated in the “How do you contact us” section under the “Introduction” heading above.

To help protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with your request.

You may designate an authorized agent to make a request on your behalf as permitted under law, though before we process that request, we will require that you provide the authorized agent written permission to do so and verify your identity directly with us.

To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Exceptions to These Rights

The law provides for certain exceptions to the rights described above. We reserve the right to avail ourselves of these exceptions where applicable.