Privacy policy

Tonhub is a software service accessible via a mobile device application and a browser service for the TON Network (the "Network") distributed by Whales Corp ("Whales" or "we" or "us" or "our") that enables users to self-custody digital assets; access a digital asset browser and link to decentralized applications and decentralized exchanges; view addresses and information that are part of digital asset networks and broadcast transactions additional services provided by Partners; andadditional functionality as Whales may add to the app from time to time (collectively, the "App" or "Tonhub" or "Tonhub Wallet"). This Privacy Policy ("Privacy Policy") helps explain how we collect, use, store, and protect your information when you use the App, our developer software, or our website at https://tonhub.com/ (collectively the "Services"). Please also read Tonhub Wallet's Terms of Service (the "Terms"), which describe the terms under which you use the Services.

Information we collect

As the Application is a non-custodial crypto asset software wallet, we do not have customer accounts. We do not require you to provide your personal data to us to use the Application. We will never ask you to share your private keys or wallet seed. Never trust anyone or any site that asks you to enter your private keys or wallet seed. It is important to note that your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems. We may collect limited information about you from your devices or from various sources, as described below.

Information You Give Us

We may collect some personal information from you when you communicate with us, including your contact information, such as your name, email address or phone number (depending on how you contact us).

Information Automatically Collected

We may automatically collect information about you and your devices when you use the Application, including:

• information you create through the Application, such as public wallet addresses
• the IP address of the device you use to access the Application
• the type of browser software you are using
• the operating system you are using
• the date and time you access or use the Application
• other non-personally identifiable information

We are especially sensitive about children's information. We are not targeted towards children, and we don't knowingly collect information from children under the age of 13. If you believe that we might have any information from a child under 13, please contact us.

How we use the information

We use the information we collect for the following purposes:

• To enable you to access and use the Application, and to process and complete transactions, and send you related information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
• To understand and analyze how you use our Application and develop new products, services, features, and functionality.
• To communicate with you about promotions, upcoming events, and other news about products and services offered by us.
• For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you.
• To personalize your experience of the Application such as identifying you as a repeat visitor.
• To facilitate the connection of third-party services or applications.
• In order to optimize your user experience, we may use your information to operate, maintain, and improve our Application.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• For compliance purposes, including enforcing our terms of use or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
• To contract with third-party API providers, including providing customer service, providing advertising or marketing services, providing analytic services.

Legal basis for processing your personal information

If you are located in the European Economic Area, we only process your personal data when we have a valid “legal basis”, including when:

• Performance of a contract: This is when processing of personal data is needed in order to perform our obligations under a contract (to provide services) concluded with you.
• Legal obligation or for public interest: This is when we are required to process your personal data to comply with a legal obligation.
• Legitimate interests: Where necessary, we may process personal data where there is a legitimate interest for us in pursuing commercial and business interests (for example, for product development and internal analytics purposes), except where such interests are overridden by your interests, fundamental rights and freedoms.

Sharing of information

We only share the User's Personal Data when We have a valid reason for it, namely, to provide the Services and products to the User and when we are legally permitted to do so.

We may disclose the User's Personal Data to:

• Data processors (including banking partners, technology providers, customer support center) – Whales uses carefully selected service providers (data processors) that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect the User's Personal Data. Whales has concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of the User's Personal Data.
• Third parties – in some circumstances, Whales also shares the User's Personal Data with third parties who act as independent data controllers as regards the User's Personal Data. Whales only shares the User's Personal Data with third parties if stipulated herein, if required under the applicable law (e.g., auditors, national regulators or other authorities), when Whales needs to protect the User's legal rights (e.g. disclosing Personal Data to attorneys or debt collection agencies) due to Whales's legitimate interest for the performance of an agreement, or with the User's consent.
• Acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of Whales’s business assets. In such case, Whales makes sure that the User's rights and conditions when the data may be processed as a data subject shall not be decreased.
• The User's representatives, advisers, and other third parties the User has contacted regarding the Service or which the User has authorized to interact with Whales on the User's behalf. Please note that Whales considers such authorization as the User's consent and therefore the User's request for such an activity must be present to Whales in a written form.
• With the User's Consent – Whales may share information with other third parties with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions. Use of the information you agree to share will be subject to those third parties' respective privacy notices.

Cross-border information transfer

Please be aware that your information will be transferred to, processed, and stored out of the EEA. You consent to the transfer of your information, including personal information, out of the EEA as set forth in this Privacy Policy by using the Application. Whenever we transfer your personal information out of the EEA to the countries not deemed by the European Commission to provide an adequate level of personal information protection, the transfer will be based on a data transfer mechanism recognized by the European Commission as providing adequate protection for personal information. Please contact us if you want further information on the specific mechanism used by us when transferring your personal information out of the EEA.

Your rights

You have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold: Opt-out. You may contact us anytime to opt-out of: (i) any consent you previously provided to us regarding the processing of your information; or (ii) the transfer of your information outside the EEA. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent. Please note that your use of parts of our Application may be ineffective upon opt-out. You may unsubscribe from our promotional emails via the link provided in the emails. Even if you opt out of receiving marketing and promotional messages from us, you will continue to receive administrative messages from us. Access. Provide you with information about our processing of your information and give you access to your information. Amend. You may update or correct any inaccuracies in your information by contacting us. Restrict. Restrict the processing of your information. Object. Object to our reliance on our legitimate interests as the basis of our processing of your information that impacts your rights. Delete. In certain situations, for example when the information we hold about you is no longer relevant or is incorrect, you may request that we erase your data. You can submit these requests by email to [email protected]. We may request specific information from you to help us process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your information, you may contact us at [email protected] or submit a complaint to the data protection regulator in your jurisdiction.

Retention period

We will only retain your information as long as reasonably required for us to provide the requested customer support and inquiry services. If you delete uninstall the Application from your device or request that your information be deleted, we still may retain some information that you have provided to us to maintain our Application or to comply with relevant laws.

Security

We use reasonable organizational, technical, and administrative measures to protect your information. Even with all these precautions, we cannot fully guarantee against the access, disclosure, alteration, or deletion of data through events, including but not limited to hardware or software failure or unauthorized use. Any information that you provide to us is done so entirely at your own risk. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem.

Third party services

Our Application may contain links or API connections to other websites, products, or services such as https://ton.org or similar that we do not own or operate. We are not responsible for the privacy and confidentiality practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party API providers or any information you disclose to these third parties. We recommend you to read their privacy policies before providing any information to them.

Changes and updates to privacy policy

We reserve the right to update and revise this Privacy Policy at any time. We occasionally review this Privacy Policy to make sure it complies with applicable laws and conforms to changes in our business. We may need to update this Privacy Policy, and we reserve the right to do so at any time. If we do revise this Privacy Policy, we will update the effective date at the top of this page so that you can tell if it has changed since your last visit and will do our best to notify you. Please review this Privacy Policy regularly to ensure that you are aware of its terms. Any use of the Application after an amendment to our Privacy Policy constitutes your acceptance to the revised or amended agreement.

Contact Information

If you have questions about your privacy related to the Application or this Privacy Policy, you may contact us at the address below. Whales Corp e-mail: [email protected].