PRIVACY POLICY

Hi there,

Here at Kepler Technologies GmbH (“EOSPortfolio”, “we”) we are committed to protecting and respecting your privacy. We take your privacy seriously and will use your personal information (or data) to provide the services you sign up for only after obtaining your consent to the collection and processing of your personal data on the terms specified below.

This Privacy Policy explains when, where, how and why we collect and further process personal information about users that we may receive while they visit EOSPortfolio.io website (the “Website”) or use the EOS Portfolio Manager Application (the “Application” or EOSPortfolio).

EOSPortfolio may change this Privacy Policy from time to time if doing so will be deemed necessary in order to comply with the applicable laws and actual circumstances of the functioning of the Website or Application, so please periodically check this page to ensure that you’re satisfied with any changes. Additional notifications on any amendments will be sent to your email or will pop-up when using the Application after the amendments were made. If within one week after such notification was made you did not unsubscribe or withdraw your consent as specified in this Privacy Policy, you will be considered as having accepted all the amendments, unless there is an obligation imposed on EOSPortfolio by an applicable law to obtain your explicit consent to the amendments. This can be a case when, for example, the nature of your data processing and purposes for processing change.

Any questions regarding this Policy and our services should be sent to privacy@kepler.finance .

1. What is EOSPortfolio?

This Privacy Policy governs the way your data is processed when you use the Website, EOSPortfolio Application as well as other EOSPortfolio products and services. EOSPortfolio Application is an application that allows its user to synchronize and keep track of the user’s EOS blockchain assets and display them on user’s device. The Application as well as this Website are products of Kepler Technologies GmbH, registration No. CHE-395.347.099, a company registered at Sumpfstrasse 26, 6312 Steinhausen. Thus, Kepler Technologies GmbH is a person that may process your data obtained from this Website, Application or other EOSPortfolio products.

2. What is personal information and what is processing of personal information?

Personal information (or data) is any information about you and that alone or in combination with other pieces of information gives the opportunity to identify you as a person. It can be your first and last name, your email, your location data, the IP address of your device etc. Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means and so on.

3. What type of information is collected from you via the Website?

EOSPortfolio may collect personal information via the Website when you sign up to receive our marketing information and when you browse our Website. Such information may include your email address or online identifiers and cookie identifiers that give the opportunity for EOSPortfolio to obtain and analyze the technical information such as frequency of visits to the Website, IP address, site pages most frequently accessed, browser type etc. Online and cookies identifiers alone are non-personally identifiable user information, however such information can be combined with the personal information received from you sign up to receive our marketing information and that is why you need to be aware of the fact that such information is collected and processed. Please see our Cookies Policy for more details on such processing here

4. What type of information is collected from you when installing and using the Application?

The installing and use of Application does not require any registration. EOSPortfolio does not collect such personal data as names, email addresses, contact details. Instead, in order to serve as an effective portfolio manager, the Application uses such information as the EOS Public Keys, EOS accounts or your txid's. EOS Public Keys, EOS accounts or your txid's are stored exclusively on your device while using the Application and are not transferred to any servers or third parties including directly to EOSPortfolio  or its contractors. EOSPortfolio does not store, copy or otherwise use such information.

Please note that we do not collect the information on the amount of your crypto assets or tokens involved, statistics generated and displayed on your device or any other information regarding your crypto assets. The information from the third-party sources containing the information described in this section is directly transmitted to your device. EOSPortfolio does not use, store, copy or otherwise process such information.

When You use the Application, we will record only the online identifiers that enable us to analyze the statistics of your activity when using Application (exclusively the actions performed, without any content specifications), statics of screen configuration of your device, defined by a combination of the screen size and density, your device technical characteristics and the version of your operating system.

5. Why does EOSPortfolio collects information from you?

EOSPortfolio collects the information while you are using the Website or Application for the following purposes:

If EOSPortfolio decides to change the purposes of processing specified above, we will inform you on such changes prior to the use of your personal information for the newly set purposes. The notification on such changes will be sent to your email or will pop-up when using the Application after the amendments were made and you will have to provide your consent to the amended purposes unless the new purpose of processing is compatible with those listed above.

6. Who will get access to your personal information?

In order to ensure the Website and the Application works fine and provide high-quality services to its users EOSPortfolio hires people, enters into the agreements with independent contractors as well as cooperates with other services providers, companies and organizations. For these reasons some of the information EOSPortfolio collects from you can be passed to the persons mentioned.

For example, for Website marketing analytics and advertising purposes, EOSPortfolio uses the services provided by Google (Google LLC), such as Google Analytics and AdWords. For the same purposes EOSPortfolio  uses Facebook Pixel provided by Facebook Inc. We also use Mailchimp services (The Rocket Science Group LLC d/b/a MailChimp) for email delivery automation and MouseFlow (Mouseflow, ApS) for the analyses of the behavior of the Website users. When it comes to Application, EOSPortfolio uses the services for mobile apps developers such as Firebase provided by Google LLC, App Store provided by Apple Inc. and Google Play service provided by Google LLC.

These well-known software providers ensure your data is processed in accordance with the strictest data protections standards.

Although Kepler Technologies GmbH is registered in Switzerland it has contractors and subsidiaries in other countries. As mentioned above, your data may be transferred to the companies in the USA. Your data also may be accessed by the non-EU based providers EOSPortfolio engages.

If you are from the EU, it will be important for you to know that the transfer of your data to the recipients in these countries is secured either by the participation of the contractors from the USA in Privacy Shield Program or on the bases of standard contractual clauses adopted by the European Commission and compliant with the EU data protection laws.

By providing your personal information on the Website or when installing the Application, you agree with this Privacy Policy and to the transfer of data to the recipients and countries specified above within the purposes set in Section 5 of this Privacy Policy.

In all cases when we pass the information to other persons, we ensure that your information is being protected and used only for the purposes specified in Section 5 of this Privacy Policy. This is achieved by using only certified services and products, signing agreements on protection of personal data with contractors as well as taking technical measures to ensure the information is protected when stored, used and while being transferred.

You also have to be aware of the fact that EOSPortfolio may disclose your personal information to enforce and comply with the applicable laws. In other words, EOSPortfolio may disclose information necessary for the investigation or legal process on official request from the official bodies acting within their powers.

7. How long will the personal information be processed and stored by EOSPortfolio ?

Your personal information will be stored by EOSPortfolio up to the moment you uninstall the Application from your device or enforce your right to withdraw your consent to the processing of your personal data within the purposes set in Section 5 of this Privacy Policy. This may be done for example by unsubscribing from the email communication sent to you by EOSPortfolio. EOSPortfolio shall terminate the processing of your personal information when you uninstall the Application, unsubscribe from our services or mailing lists unless the special retention period for the storage of such data is set by the applicable legislation.

8. Your rights regarding your personal information EOSPortfolio collects and processes

8.1. You have the right to know what personal information EOSPortfolio processes and get details of such processing

That means that you have the right to ask EOSPortfolio to provide you with the confirmation as to whether or not your personal data is being processed by EOSPortfolio, as well as obtain the full information on the terms of such processing, i.e. purposes of collecting and processing, period of processing, third parties that have access to information. You also have the right to obtain your personal data in a structured, commonly used and machine-readable format in order to be able to transmit it to the other controller of data.

Please kindly note that due to the fact that the use of Application does not require any registration and the information Application uses for its functioning is stored exclusively on the user’s device the right for obtaining some categories of information used by the Application itself may not depend on EOSPortfolio  but on the technical characteristics of your device or the third parties you obtain your information from (e.g. API Keys or your crypto-wallet addresses).

8.2. You have the right to request EOSPortfolio to rectify your personal information

This means you have the right to ask that all the inaccuracies in your personal information be corrected. You can also complete the personal information if you feel there is a need to do so.

Please kindly note that due to the fact that the use of Application does not require any registration and the information Application uses for its functioning is stored exclusively on the user’s device the right to request to rectify some categories of information used by the Application itself may not depend on EOSPortfolio but on the technical characteristics of your device or the third parties you obtain your information from (e.g. EOS Public Keys, EOS accounts or your txid's).

8.3. You have the right to request EOSPortfolio to erase personal information

You have the right to request EOSPortfolio to erase such data if its processing is no longer necessary in relation to the purposes for which it was collected as well as if there are no legal grounds for the processing. In most cases start of EOSPortfolio will erase it unless otherwise will be required by the applicable legislation.

Please kindly note that due to the fact that the use of Application does not require any registration and the information Application uses for its functioning is stored exclusively on the user’s device the right to erasure of some categories of information used by the Application itself may not depend on EOSPortfolio  but on the technical characteristics of your device or the third parties you obtain your information from (e.g. API Keys or your crypto-wallet addresses). In this case you also have to be informed that the request to erase some categories of information used by the Application itself may be subject to uninstalling of the Application by the user.

8.4. You have the right to request EOSPortfolio to restrict the processing of your personal information

You have the right to request the restriction of processing of your personal data in cases provided by the applicable law. For instance, if you want to verify whether the data processed by EOSPortfolio  is accurate, the processing of your data may be restricted for the period of time EOSPortfolio will require to verify your personal data at your request.

Please kindly note that due to the fact that the use of Application does not require any registration and the information Application uses for its functioning is stored exclusively on the user’s device the right to restrict the processing of some categories of information used by the Application itself may not depend on EOSPortfolio but on the technical characteristics of your device or the third parties you obtain your information from (e.g. API Keys or your crypto-wallet addresses).

8.5. You have the right to withdraw consent

You can withdraw your consent to the collection and processing of your personal information by EOSPortfolio  at any time, without affecting the lawfulness of processing based on consent before its withdrawal. After we at EOSPortfolio  receive such withdrawal request from you, we will process it in a timely manner and no longer process your personal information unless the obligation to proceed with processing is set by the applicable law. The phrase “in timely manner” is deciphered below.

Please kindly note that due to the fact that the use of Application does not require any registration and the information Application uses for its functioning is stored exclusively on the user’s device the right to withdraw consent may not depend on EOSPortfolio but on the technical characteristics of your device or the third parties you obtain your information from (e.g. EOS Public Keys, EOS accounts or your txid's). In this case you also have to be informed that the withdrawal of your consent may be subject to uninstalling of the Application by the user.

If you will face any issues regarding the processing of your personal data or have questions on the same matter, please inform EOSPortfolio and we will take all reasonable efforts to resolve the issue. If you have any such issues, please drop us a line at privacy@kepler.finance . You can also address any of your complaints to the data protection controlling bodies.

9. Time for reply and reaction

EOSPortfolio will make all reasonable efforts to timely address your requests pertaining to the rights described above, however you should expect our response not later than one month from the date of filing such request. Our time for response may be extended by two further months if EOSPortfolio is overwhelmed with the number of requests from users. EOSPortfolio will inform you of such extension within one month of receipt of the request, together with the reasons for the delay.

10. Cookies

What are cookies? These are tiny pieces of code that remain in your computer or mobile device when you visit the Website. These pieces then enable the server to provide you with the information that is customized to your needs when you use Website as a returning user.

If you visited our Website and came here, to the Privacy Policy, cookies consent message was the first message that you likely saw that prompted you about the fact that cookies are used and active on our Website. Please see the detailed information on how we use cookies in our Cookies Policy here . Cookies Policy is an integral part of this Privacy Policy.

11. Are you already 16 years old?

The privacy of children is one of our major concerns. At EOSPortfolio we can provide services only in case if you as the user are aged 16 or older (or you are of an age of majority and fully able and legally competent to enter into agreements). If you are under 16 you will need to get your parent’s/guardian’s permission before providing any private information to EOSPortfolio.

We hope this Privacy Policy helped you understand how your personal information is dealt with at EOSPortfolio.  EOSPortfolio will undertake its best effort to make your personal data protected. Should you have any questions, please e-mail us at privacy@kepler.finance . We will be glad to receive any information or comment from you to make our services better for our users and community.

Your EOSPortfolio team