Privacy Policy
This Policy explains how your personal data may be processed when you use the Sparx Wallet browser extension and/or mobile application (hereinafter - the Wallet). It does not address Broxus Services FZ LLC’s other personal data processing operations, for example where we provide services to you on the basis of a contract between us. Additional policies and procedures addressing these processes are in place and we provide information to data subjects at the point of data collection or subsequently, as required by law.
Data controller
The Wallet is developed and operated by Broxus Services FZ LLC, a company registered in the United Arab Emirates at the address Yas Creative Hub, Yas South Podium 1, PMI Unit ID Number: C40-P1-0104-HDJ6, Community Hub, Building C40, Abu Dhabi, Abu Dhabi, United Arab Emirates. Contact us via email at dpo@broxus.com with any questions regarding this Policy or any other data protection issue related to the Wallet.
What we do not collect
In line with our mission and values, we have built the Wallet so that we do not collect any data from users for any purpose. Our only interest is maintaining the security of the Wallet, therefore:
• we do not set any cookies;
• we do not collect any data whatsoever about people who use the Wallet;
• we do not conduct any analysis of how people use the Wallet;
• we do not allow third-party tracking of any kind on the Wallet.
• we do not set any cookies;
• we do not collect any data whatsoever about people who use the Wallet;
• we do not conduct any analysis of how people use the Wallet;
• we do not allow third-party tracking of any kind on the Wallet.
Third-party data processing and retention
Due to the nature of the Wallet, we use the facilities of Google Chrome Store, Google Play Store, and Apple Store (hereinafter - the Stores) to distribute the Wallet to our users. Although we do not provide any user data to the Stores, they may collect some information about you, as stipulated in their Privacy Policies.
Information security
As no user data is collected at our servers, the Wallet stores such information as seed phrases and private keys at your device in an encrypted form. The access to these data is controlled solely by you by setting the password for encryption and/or using the biometry features of your device (subject to the Privacy Policy of the device manufacturer).
Your rights
Where Broxus Services FZ LLC processes your personal data you may have the right:
• to be informed as to whether Broxus Services FZ LLC holds personal data about you;
• to access that data;
• to have inaccurate data corrected;
• to have your data deleted;
• to opt-out of particular data processing operations;
• to receive your data in a form that makes it “portable”;
• to object to data processing;
• to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.
You can seek to exercise these rights via email to dpo@broxus.com. You also have the right to lodge concerns or complaints with the competent data protection supervisory authority, including the competent authority in the United Arab Emirates where applicable. Data subjects covered by EU law may also be entitled to lodge complaints with the data protection supervisory authority in their country of residence.
• to be informed as to whether Broxus Services FZ LLC holds personal data about you;
• to access that data;
• to have inaccurate data corrected;
• to have your data deleted;
• to opt-out of particular data processing operations;
• to receive your data in a form that makes it “portable”;
• to object to data processing;
• to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.
You can seek to exercise these rights via email to dpo@broxus.com. You also have the right to lodge concerns or complaints with the competent data protection supervisory authority, including the competent authority in the United Arab Emirates where applicable. Data subjects covered by EU law may also be entitled to lodge complaints with the data protection supervisory authority in their country of residence.
Changes and revisions
We may update this Policy in the future. We will maintain an accessible record of any such changes.