Towo Labs AB ("we", "us", "our" or "Towo Labs") values your privacy. We strive to protect your personal data in the best possible way. When you use our non-custodial crypto asset software Bifrost Wallet, we do not process your personal data other than to:
- 1) Develop, maintain and improve our software and services
- 2) Respond to your support requests, questions or feedback
- 3) Provide you with updates and information on our websites
- 4) To defend ourselves from any claims or complaints
To ensure secure and lawful processing of your personal data, Bifrost Wallet is developed in accordance with the principles of privacy by design and data minimization. It means, in practice, that we are always thinking about your privacy when designing our software and services and that we do not process any personal data not necessary for the specific purpose.
Who is responsible for processing your personal data?
Towo Labs AB, a company duly incorporated under Swedish law with registration number 559209-4873, address P.O. Box 194, SE-581 02 Linköping, Sweden is responsible for the processing of your personal data that we process (the controller).
Who do we share your personal data with and why?
Your personal data is initially collected and processed by Towo Labs. As a principle, we do not share your data with third parties other than when we hire suppliers, for example IT-suppliers providing cloud services to us. The suppliers will only get access to your personal data to the extent necessary in order for them to fulfill their obligations in relation to Towo Labs. The suppliers will only process your personal data on behalf of Towo Labs as data processors.
Furthermore, your personal data may be controlled and processed by other data controllers, such as but not limited to participants in the relevant blockchain networks and/or third-party service providers that you access within Bifrost Wallet. We are not involved in any transaction you may participate in, meaning we are neither a joint controller nor a data processor in such cases.
Do we transfer your personal data outside of the European Union?
We, as well as our processors, mainly process and store your personal data within EU/EEA. For the transfer of your personal data outside of the EU/EEA, we have entered into standard contractual clauses with our IT-suppliers or taken other appropriate safeguards (if there is no adequacy decision taken by the EU Commission) that we may base our transfer and our suppliers' processing upon.
From whom do we obtain your personal data?
We only obtain your personal data directly from you.
What are your rights when we process your personal data?
Under applicable data protection legislation, depending on the circumstances, you are entitled to a variety of rights when we process your personal data.
Right to object to processing
You have a right to object to our processing of your personal data when the processing is based on the legal basis “legitimate interest”. The situations when we base our processing on our legitimate interest are stated in the sections below. In some instances, we may continue to process your personal data even if you have objected to our processing. This can be the case if we can show compelling legitimate reasons for the processing that outweigh your interests or if it is for the purpose of establishing, exercising or defending legal claims.
Right to information and access
You have the right to obtain confirmation as to whether or not we are processing personal data about you and information about the personal data that we process, such as the purposes of the processing, categories and receipts of your personal data, and for how long we store your personal data. You can gain access to this information and obtain a copy of the personal data processed by us by contacting us as described below.
Right to rectification
You have a right to correct or update any inaccurate personal data concerning you that we may be processing and to ask us to have incomplete personal data completed. We may need to verify the accuracy of the new data you provide to us.
Right to erasure
Under certain circumstances, you have a right to request that we delete your personal data. This is the case for example where the personal data is no longer necessary for the purposes for which they were collected or otherwise processed, or you withdraw your consent on which the processing is based and where there is no other legal ground for our continued processing of your personal data.
You also have a right to request that we restrict our processing of your personal data. This is the case for example when the accuracy of the personal data is contested by you, or the processing is unlawful, but you do not want us to delete it and instead you request that we restrict our use of it.
Right to lodge a complaint
You always have the right to lodge a complaint with a supervisory authority. You may do this in particular in the EU/EEA member state where you live, work or where there is an alleged infringement of the applicable data protection laws. The supervisory authority in Sweden is the Swedish Authority for Privacy Protection (IMY). You also have the right to seek a remedy or other decision from a national court.
Right to data portability
You have a right to ask us to transfer any of the personal data we have about you to another company, where technically feasible (“data portability”), provided that our processing is based on consent, or on a contract and our processing is carried out by automated means.
Data processing details and data retention
Here you can read more about how and to which extent we process your personal data, which categories of personal data we process and our legal basis for processing your personal data. You can also read for how long we process your personal data for each purpose.
When you use Bifrost Wallet
As a basis, we do not process your personal data when you use our Bifrost Wallet. Bifrost Wallet does not have any user accounts and we do not ask for any user data. Any information in Bifrost Wallet, such as your PIN code, your Private Keys and your Recovery Phrase, are stored on your mobile device and are not processed by us. We can neither access your Bifrost Wallet and Crypto assets nor get hold of your personal data, if any, in any other way. When you are adapting Bifrost Wallet to your settings and preferences, as well as when you customize Bifrost Wallet, such settings are solely stored on your mobile device. You are deciding how to process your personal data. In other words, we are not processing the data in Bifrost Wallet for you, only providing you with the infrastructure.
When we improve Bifrost Wallet and our Services
We may collect anonymized and aggregated data from Bifrost Wallet in order to develop, maintain and improve our Services. Anonymized data are data which are not considered personal data, as we cannot identify you based on the data and/or identify you/your data even if we get additional information from you. The data we process in order to develop and improve Bifrost Wallet and our services may be information about your version of Bifrost Wallet, bug-reporting information, and model of phone or operating system.
When you visit our websites
We may process your personal data when you visit any of our websites towolabs.com, bifrostwallet.com or other related subdomains. The purpose is to give you a decent user experience and answer your support requests. Your data may also be used in an aggregated format for the purpose of evaluating, developing and improving our services.
Personal data we process: IP address, user agent, functional cookies, e-mail address, time and date of your visit.
Legal basis: The processing is justified by our legitimate interest to enable you to visit our websites and to provide you with information and necessary features through the websites. The processing of cookies may be based on your consent to our processing. Please note that you may withdraw your consent at any time by contacting us at firstname.lastname@example.org, which will not affect the legality of the processing performed before the withdrawal. The storage of cookies may be directed through your browser settings as well.
Retention time: The personal data is processed during the duration of your visit, and thereafter until the cookies' expiration date, in no case longer than 9 months.
When you contact us for support
We may process your personal data to provide you with support, answer your questions, administrate your request and improve our services.
Personal data we process: e-mail address, other personal data you provide us.
Legal basis: The processing is necessary for performance of contract concerning your use of the Bifrost Wallet and our Services. If the data is not provided to us, we will not be able to give you support and service. If you contact us without having entered into a contract with us by accepting our Terms, we will process your personal data on the basis of our legitimate interest, namely to provide you with answers of your requests.
Retention time: The personal data is processed until you have received the support you need and/or until we have responded to your request, but in no case longer than 90 days. If you have contacted us via the customer chat function at support.bifrostwallet.com, we may process your data longer (see “When you visit our websites” above).
If you subscribe to our newsletter
We may process your personal data to provide you with our newsletter and written information about our Services.
Personal data we process: e-mail address
Legal basis: The processing is based on your consent to our processing. You may withdraw your consent at any time by clicking on “Unsubscribe” at the bottom of the e-mails we send you or by contacting us at email@example.com, which will not affect the legality of the processing performed before the withdrawal.
Retention time: The personal data is processed until you withdraw your consent. We may regularly ask you to update your consent in order to keep our records up to date.
If you complain, make a claim, or want to exercise your rights as a data subject
We may collect your data to handle your rights as a data subject, complaints or other claims.
Personal data we process: Name, postal address, e-mail address, information from our communication with you regarding your complaint or claim, other information which contain your personal data (if any).
Legal basis: The processing is necessary in order for us to act in accordance with law and to comply with a legal obligation. We also have a legitimate interest in being able to defend ourselves against a possible legal complaint or claim.
Retention time: The personal data is processed from the time you submit your complaint or claim and is processed as long as the process of the complaint or claim is in progress.
Balance of interests' tests when processing data based on the lawful basis "legitimate interests"
As we state above, for some purposes, we process your personal data based upon our "legitimate interest". By carrying out a balancing of interests' assessment concerning our processing of your personal data, we have concluded that our legitimate interest for the processing outweighs your interests or rights which require the protection of your personal data. If you want more information in relation to our balancing of interests' assessments, please do not hesitate to contact us.
How do we protect your personal data?
We, and when applicable our partners and suppliers, have taken several security measures to protect the personal data that is processed. For example:
- a) Awareness program and employee trainings
- b) Encryption at rest and in transit
- c) Hardened server configurations
- d) Design software in accordance with privacy by design and data minimization principles
- e) Continuous system monitoring
- f) Independent security audits
Although we are doing our best in order to protect your data (not only your personal data), you remain responsible for keeping your credentials, passwords, PIN code, Private Keys and Recovery Phrase confidential and secure. We cannot access or retrieve any such information for you.