IPPAN

Effective date: November 01, 2021.

Date of last modification: March 17, 2024.

The privacy and security of your personal data is and always will be of fundamental importance to us. Therefore, we want to explain to you in a transparent manner how and why we collect, store, share and use your personal data. Please read the following Privacy Policy carefully.

1. ABOUT THE PRIVACY POLICY

This Privacy Policy contains essential information concerning the personal data of users (hereinafter the User or You) and their relationship with the data controller IPPAN LTD (hereinafter IPPAN or We).

The purpose of this Privacy Policy is:

Ensure that the User understands what personal data We collect about them, the reasons why We collect and use it, and with whom We share that data;
Explain how we use the personal information you provide to us so that you can enjoy the experience when using the service; and
Explain your rights and choices regarding the personal data we collect about you and process, as well as how we will protect your privacy.

2. DATA CONTROLLER

Data controller contact details: IPPAN LTD with CRN 11757949 and address at Office 4 219 Kensington High Street, Kensington, London, England, W8 6BD.

Data Protection contact details: you can contact us at the above postal address and/or via email: [email protected]

3. USER'S CONSENT

It shall be understood that the User has read, understands, understands and accepts the conditions established from the moment he/she uses the ippan.com website and/or downloads and installs the IPPAN software application (hereinafter the application or the platform), which consists of a platform that allows managing the portfolio, private messaging, viewing and/or sharing content on the social network, property of IPPAN. The registration of the registration form(s) of IPPAN both on its website and in its application implies the unequivocal consent, by the User, to the automated processing of personal data in accordance with the privacy conditions of IPPAN. The data collected are adequate, relevant and not excessive in relation to the scope and purposes determined. Notwithstanding the foregoing, such consent may be revoked at any time by the User, by unsubscribing by any of the means made available to the User.

4. PERSONAL DATA WE COLLECT

Below, we indicate the categories of personal data (User Data, Usage Data) that we collect and use on behalf of the User, as well as how we collect them:

4.1. User Data. This is the personal data that the User has provided to us or that we collect in order for the User to access and/or subscribe to and use IPPAN.

4.1.1. From time to time, users may register to one or more waiting lists through the registration forms available on the ippan.com website in order to qualify for access to the private beta version of the application. The personal data we collect is as follows:

Valid e-mail address
Country of Origin
IP address
Web browser
Device
Operating System

IPPAN collects and processes such personal information from the User for the purpose of giving him/her access, at the discretion of IPPAN Private Beta, to the platform by means of an invitation link sent to the User through the valid e-mail address provided by such User in the corresponding form on the web page.

4.1.2. Once the application has been downloaded and installed, the User shall create an IPPAN user account in order to access said platform and use its services, for which the following personal data shall be required:

ID account

4.1.3. Upon successful registration of the account, a wallet linked to the User's account is created. When the wallet is created a cryptographic key pair is automatically generated, the public key is stored on IPPAN servers, the private key on the User's device and it is the User's responsibility to keep it in a secure place.

4.1.4. The account access password is created and stored on the User's device, where a pair of cryptographic keys is generated and it is the User's responsibility to keep it in a safe place.

4.1.5. The two-step verification system is used by default for both registration and access, through the validation of a security code sent by email and a security code sent by text message to the phone number provided.

4.1.6. The PIN code is a 5-digit security mechanism created by the user used within the application for approval of sending and requesting payments; and opening for unlocking the application, the latter being modifiable in the configuration options within the app to be omitted.

4.1.7. Users shall be responsible in all cases for the safekeeping of the private keys of their wallets, the PIN code, so they shall be solely responsible for any damages that may arise from improper use of the same, as well as its loss or any other circumstance that could pose a risk of access or use of the same by unauthorized third parties.

4.2. Use data. Below, we indicate the personal data we collect when the user uses the IPPAN application:

We collect related information about the interaction with the application, such as the duration time of sessions, screens accessed, as well as, automatic collection about unexpected errors causing closure within the application and information about the type of device.

Technical data, such as:

Information about the model, operating system, universal unique device identifier (UUID), application version, storage capacity and ram memory of the device on which the User accesses.
Default language of the system.

5. INTEGRATION OF THIRD PARTY SERVICES

5.1. Statistics

We use the Firebase Analytics service to provide analytics and attribution information, allowing us to monitor and analyze the Application to track User behavior. Firebase Analytics collects Application updates; Application opens; number of sessions; number of Users; number of times the Application is opened; Usage Data; session duration; device information; geographic region; operating systems.

Google Analytics for Firebase

Google Analytics for Firebase or Firebase Analytics is a statistical service provided by Google LLC or Google Ireland Limited, depending on where you access this Application from.

To learn more about how Google uses the Data, please refer to Google's Partner Policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. Users may review this privacy policy for a detailed explanation of the other tools employed by the Registrant.

This Application uses mobile device identifiers and cookie-like technologies to operate the Firebase Analytics service.

Place of processing: USA - Privacy Policy; Ireland – Privacy Policy.

5.2. Infrastructure monitoring

We use the Firebase Crashlytics service to alert us when a failure occurs in your mobile application. Therefore, instance IDs and crash reports are transferred to Firebase. These types of services allow this Application to monitor the usage and behavior of the components of this Application, to enable improvement of its performance and functionality, maintenance or troubleshooting.

The Personal Data processed will depend on the characteristics and implementation modalities of these services, which by their very nature filter the activity of this Application.

Crashlytics

Crashlytics is an application monitoring service provided by Google LLC or Google Ireland Limited, depending on where you access this Application from.

Personal Data processed: error data; Universally Unique Identifier (UUID); device information.

Place of processing: USA - Privacy Policy; Ireland – Privacy Policy.

5.3. BETA Testing

This type of service allows to manage the access of Users to this Application, or parts of it, in order to test some of the functions or the entire Application.

The service provider may automatically collect data relating to system failures and statistics relating to the User's use of this Application in a personally identifiable manner.

Google Play Beta Testing (Google LLC)

Google Play Beta Testing is a beta testing service provided by Google LLC.

Personal Data processed: different kinds of Data, as specified in the Privacy Policy of the service.

Place of processing: USA - Privacy Policy; Ireland – Privacy Policy.

We use your cell phone number to send you a verification code by SMS, for sending SMS we use Twilio, a service of Twilio Inc, 375 Beale Street, Suite 300, San Francisco, CA 94105 (our worldwide headquarters).

Twilio provider information on data protection is available at: https://www.twilio.com/legal/privacy

6. PURPOSES OF DATA PROCESSING

6.1. Purpose of processing users' personal data

For the correct operation of the platform;
For statistical purposes of the operation of the platform and IPPAN's business;
For business planning, information, projection and estimation purposes;
Infrastructure monitoring;
To understand, diagnose, resolve and solve problems, errors and/or bugs of the application;
To evaluate, test and develop new functions, technologies, changes and service improvements;
To comply with legal obligations and requirements of the competent authorities;
To detect any malicious or fraudulent activity.

6.2. Data Retention

The period of conservation of personal data is maintained for as long as it is necessary for the proper functioning of the platform. Please note that, in certain cases, legal or regulatory obligations require us to retain specific records for a longer period of time.

7. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES

We transfer your Personal Data to countries outside the United Kingdom and the European Economic Area (EEA), including but not limited to the United States, where necessary for the provision of the Services, you may transfer and store Personal Data to locations within or outside the European Economic Area (EEA).

8. MINORS

The contents of the Website and the App are not directed at children under the age of 13. In any case, IPPAN will take all possible measures to verify the age of users, but will not be liable for any failure to do so.

9. CONFIDENTIALITY

The personal data that may be collected will be treated with absolute confidentiality, committing ourselves to keep them secret and guaranteeing the duty to keep them by adopting all necessary measures to prevent their alteration, loss and unauthorized access or treatment, in accordance with the provisions of the applicable legislation.

10. RESPONSIBILITY

The User shall be solely responsible for the completion of the forms on the website and / or application with false, inaccurate, incomplete or outdated data.

11. MODIFICATION OF THE PRIVACY POLICY

IPPAN reserves the right to modify its Privacy Policy, according to its own criteria, or especially motivated by legislative, jurisprudential or doctrinal changes in the matter.

Any modification of this Privacy Policy will be published before its effective application and the User will be notified by sending an e-mail. The use of the website and/or the application after such changes will imply full acceptance of these changes. Therefore, the User must ensure that he/she carefully reads such notices.

12. LEGAL INFORMATION

This privacy policy has been drafted based on the provisions of multiple legislations, including Arts. 13 and14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This Privacy Policy relates only to this Platform, unless otherwise stated herein.