Privacy Policy

Privacy Policy

We at SuperOne are committed to protecting your privacy. We have prepared this Privacy Policy to describe to you our practices regarding the personal data we collect from users of our website.

This Privacy Policy applies to all personal information collection and processing activities carried out by SuperOne Limited (SuperOne”). SuperOne is a data controller in respect of personal information that we process in connection with our business. In this notice, references to “we”, “us” or “our” are references to SuperOne. Our principal address is Portland House, Glacis Road, Gibraltar, GX11 1AA (company REID GICO 120275-4) and our privacy email address is privacy@super.one. We respect individuals’ rights to privacy and to the protection of personal information. The purpose of this Privacy Policy is to explain how we collect and use personal information in connection with our business. “Personal Data” means information about a living individual who can be identified from that information (either by itself or when it is combined with other information). We may update our Privacy Notice from time to time. When we do we will communicate any changes to you and publish the updated Privacy Policy on our website. We encourage you to visit our website regularly to stay informed of the purposes for which we process your information and your rights to control how we process it.

By using the SuperOne website and app and the services and products thereon (the “Services”), users consent to the collection and use of their Personal Data by us. You also represent to us that you have any and all authorisations necessary to use these Services including using them to process Personal Data. We collect and use the information you provide to us, including information obtained from your use of the Services. Also, we may use the information that we collect for our internal purposes to develop, tune, enhance, and improve our Services, and for advertising and marketing consistent with this Privacy Policy. This privacy policy has been compiled to better serve those who are concerned with how their Personal Data is being used online. Please read our privacy policy carefully to get a clear understanding of how our website and app collects, uses, protects or otherwise handles users’ Personal Data.

This Privacy Policy informs you about how our website and app handles your personal data. If you do not agree to any part of this Privacy Policy, then we cannot provide our Services to you and you should stop accessing our services.

By using the Services, you acknowledge, consent and agree that we may collect, process, and use the information that you provide to us and that such information shall only be used by us or third parties acting under our direction, pursuant to confidentiality agreements, in accordance with the manner specified in this Privacy Notice. You are responsible for periodically reviewing any changes which may be made to the Policy. We will notify you of any changes to this Privacy Policy.

1. Information We Collect

We collect the following information in relation to you:

1. Usage Information: If you send us personal correspondence, such as emails or letters, or if other users or third parties send us correspondence about your activities on the Services, we may collect such information specific to you.
2. Log Information: We log information about your use of our Services, including your browser type and language, access times, pages viewed, your IP address and the Services you accessed. We collect local authentication information of your device, such as Face ID and/or Touch ID authorization information.
3. Device Information: We may collect information about the device you use to access our Services, including the hardware model, operating system and version, unique device identifier, phone number, International Mobile Equipment Identity ("IMEI"), and mobile network information.
4. Location Information: With your consent, we may collect information about the location of your device to facilitate your use of certain features of our Services.
5. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to you. A "cookie" is a small data file transferred to your computer’s hard drive that allows a Website to respond to you as an individual, gathering and remembering information about your preferences in order to tailor its operation to your needs, likes, and dislikes. Overall, cookies are safe, as they only identify your computer to customize your Web experience. Accepting a cookie does not provide us access to your computer or any Personally Identifiable Information about you, other than the information you choose to share. Other servers cannot read them, nor can they be used to deliver a virus. Most browsers automatically accept cookies, but you can usually adjust yours (Microsoft Internet Explorer, Firefox, or Google Chrome) to notify you of cookie placement requests, refuse certain cookies, or decline cookies completely. If you turn off cookies completely, there may be some Website features that will not be available to you, and some Web pages may not display properly. To support the personalized features of our Website (such as your country and language codes and browsing functions) we must send a cookie to your computer’s hard drive and/or use cookie-based authentication to identify you as a registered Website user. We do not, however, use so-called "surveillance" cookies that track your activity elsewhere on the Web. We may also collect information using web beacons (also known as "tracking pixels").
6. Personal Information: We collect personal information when you use our Services and make a profile with us, such as first and last name, address, phone number, email, gender, and date of birth.
7. Transaction Information: We may collect and maintain information relating to transactions in your wallet with us, such as amount, conversations, and incoming and outgoing information of your transactions. Where applicable, your transaction information may be recorded on the corresponding blockchain used to make your transaction.
8. Third Party Information: We collect information from third party services, such as your user profile information, name, and profile picture from third parties such as but not limited to Facebook when you enable access from such third parties.

2. How We Use Your Information:

We use the personal information we collect to fulfill your requests for Services, improve our Services, contact you, conduct research, and provide anonymous reporting for internal and external clients.

By providing us your email address, you consent to us using the email address to send you our Services and related notices, including any notices required by law, in lieu of communication by postal mail. You also agree that we may send notifications of activity on our website or app to the e-mail address you give us, in accordance with any applicable privacy settings. We may use your email address to send you other messages, such as newsletters, changes to our features, new services, events or other information. If you do not want to receive optional email messages, you may modify your settings to opt out.

Our settings may also allow you to adjust your communications preferences. If you do not wish to receive promotional email messages from us, you may opt out by following the unsubscribe instructions in those emails. If you opt out, you will still receive non-promotional emails from us about our Services.

Following termination or deactivation of your services, we may (but are under no obligation to) retain your information for archival purposes. We will not publicly disclose any of your personally identifiable information other than as described in this Privacy Policy. We will delete your data after a prescribed period in accordance with applicable data privacy law.

3. How We Share Your Information

As a matter of policy, we will not sell or rent information about you and we will not disclose information about you in a manner inconsistent with this Privacy Policy except as required by law or government regulation. We cooperate with law enforcement inquiries, as well as other third parties, to enforce laws such as those regarding intellectual property rights, fraud and other personal rights.

We may share your data with our services providers who process your personal information to provide services to us or on our behalf. We have contracts with our service providers that prohibit them from sharing the information about you that they collect or that we provide to them with anyone else, or using it for other purposes.

4. Ensuring Information is Accurate and Up-to-Date

We take reasonable precautions to ensure that the Personal Information we collect, use and disclose is complete, relevant and up-to-date. However, the accuracy of that information depends to a large extent on the information you provide. That's why we recommend that you:

1. Let us know if there are any errors in your Personal Information; and
2. Keep us up-to-date with changes to your Personal Information such as your name or address.

5. How we protect your information

We are very concerned about safeguarding the confidentiality of your personally identifiable information. We employ administrative, physical and electronic measures designed to protect your information from unauthorized access. We protect Personal Data with appropriate physical, technological and organizational safeguards and security measures. We audit our procedures and security measures regularly to ensure they are being properly administered and remain effective and appropriate. Our site has security measures in place to protect against the loss, misuse and unauthorized alteration of the information under our control. More specifically, our server uses TLS (Transport Layer Security), SSL (Secure Sockets Layer) security protection by encrypting your Personal Data to prevent individuals from accessing such Personal Data as it travels over the internet.

6. Your Rights

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. We aim to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us. Please note that in some cases, if you do not agree to the way we process your information, it may not be possible for us to continue to operate your account and/or provide certain products and services to you. In certain circumstances, you have the following data protection rights:

1. Right of confirmation:Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
2. Right of access:Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
   1. The purposes of the processing;
   2. The categories of personal data concerned;
   3. The recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
   4. Where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
   5. The existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
   6. The existence of the right to lodge a complaint with a supervisory authority;
   7. Where the personal data are not collected from the data subject, any available information as to their source;
   8. The existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.

   Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.

3. Right to rectification Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
4. Right to erasure (Right to be forgotten) Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
   1. The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
   2. The data subject withdraws consent to which the processing is based according to the point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
   3. The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
   4. The personal data have been unlawfully processed.
   5. The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
   6. The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
   7. If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us, he or she may, at any time, contact any employee of the controller. Any of our Employees shall promptly ensure that the erasure request is complied with immediately.
   8. Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. Any of our employees will arrange the necessary measures in individual cases.
5. Right of restriction of processingEach data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
   1. The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data. The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead of the restriction of their use instead. The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims. The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject. If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by us, he or she may at any time contact any employee of the controller. Our Employees will arrange the restriction of the processing.
6. Right to data portabilityEach data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
   
   Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any of our employees.
7. Right to objectEach data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions. We shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights, and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. If we process personal data for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects us to the processing for direct marketing purposes, we will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by us for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   
   In order to exercise the right to object, the data subject may contact any employee of our Company. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
8. Automated individual decision-making, including profiling Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, or (3) is not based on the data subject's explicit consent. If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject's explicit consent, we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
   
   If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any of our employees.
9. Right to withdraw data protection consent: Each data subject shall have the right granted by the European legislator to withdraw his or her consent to the processing of his or her personal data at any time. If the data subject wishes to exercise the right to withdraw the consent, he or she may, at any time, contact any of our employees.
10. Right to request accessYou also have a right to access information we hold about you. We are happy to provide you with details of your Personal Information that we hold or process. To protect your personal information, we follow set storage and disclosure procedures, which mean that we will require proof of identity from you prior to disclosing such information. You can exercise this right at any time by contacting us on the above details.
11. Right to withdraw consentWhere the legal basis for processing your personal information is your consent, you have the right to withdraw that consent at any time by contacting us.

7. Storing Personal Data

We retain your information only for as long as is necessary for the purposes for which we process the information as set out in this policy. However, we may retain your Personal Data for a longer period of time where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8. Collection of Primary Account Information

The primary information collected by our app includes the user's Name and Email for the purpose of signing up and using the application. This information is obtained either manually from the user or through their social media accounts. The social signup options available on our Android app include Google, Facebook, and Twitter.

9. Use of Subdomain as API Gateway

1. 9.1 Purpose and Functionality: SuperOne employs a subdomain as an API Gateway in our digital infrastructure, such as https://0ob0omjfjvy6.super.one. This gateway facilitates secure and efficient data transmission between our users' devices and our backend systems. Its primary role is to manage, route, and ensure the secure flow of personal data as required by our Services.
2. 9.2 Types of Data Processed: Through this API Gateway, we may handle various forms of personal data, including, but not limited to, user identification, contact details, and transactional information. The exact nature of the data processed is contingent upon the specific functionalities utilized by the user within our Services.
3. 9.3 Data Security and Protection: We adhere to stringent security protocols to safeguard personal data transmitted via the API Gateway. This includes the implementation of robust encryption and other industry-standard security measures to prevent unauthorized access and data breaches.
4. 9.4 Data Use Compliance: The processing of data through this API Gateway is in strict compliance with applicable data protection laws and our internal privacy policies. The data is used solely for the purposes outlined in this Privacy Policy and our service agreements with users.
5. 9.5 Third-Party Access and Sharing: Access to data transmitted via the API Gateway is restricted to authorized personnel and systems within SuperOne. We do not share this data with third-party entities, except as explicitly outlined in section 3 of this Privacy Policy or as required by law.
6. 9.6 Modifications to API Gateway Usage: SuperOne reserves the right to modify the use and functionalities of the API Gateway as needed. Such changes will be reflected in updates to this Privacy Policy, and we commit to communicating any significant alterations to our users in a timely manner.
7. 9.7 User Consent and Control: By using our Services, users consent to the transmission of their personal data through the API Gateway as described in this section. Users retain the right to control and limit the use of their data in accordance with the provisions outlined in sections 6 and 7 of this Privacy Policy.

10. Use and Sharing of Primary Account Information

Our app utilizes this data to create a basic user profile, primarily consisting of the user's Name. Additionally, the email is used for tasks such as account recovery (for resetting passwords) and enhancing account security through the receipt of OTPs. It's crucial to note that this information remains confined within the app and is not shared externally. We have integrated Firebase analytics to generate and analyze crash reports from various devices for the purpose of improving app stability.

11. User Consent

Users provide these details by signing up on our platform. A comprehensive privacy policy is in place, explaining how we handle user data. Moreover, users have the option to delete their account within the app if they choose to discontinue using our platform.

12. Security Measures

We have implemented both fundamental and advanced security measures to safeguard user data and the overall system. Our security measures include SSL encryption and a secure data transmission architecture for transferring data between services. The server infrastructure is isolated from external interactions, allowing only communication between our server and client apps. We regularly assess new implementations and potential vulnerabilities to further fortify our system's security.

13. Changes to this Policy

From time to time we may change the way we use your information. Where we believe you may not reasonably expect such a change we will notify you and will allow a period of at least 30 days for you to raise any objections before the change is made. However, please note that in some cases, if you do not agree to such changes it may not be possible for us to continue to provide Services to you.

14. Transferring Information Overseas

We may transfer your information, or information about you may be collected, via organizations in countries outside of the European Economic Area on the basis that anyone to whom we pass that information or who collects it directly protects it in the same way we would and in accordance with applicable laws. In the event that we transfer information to countries outside of the European Economic Area we will only do so where:

1. The European Commission has decided that the country or the organization we are sharing your information with will protect your information adequately;
2. The transfer has been authorized by the relevant data protection authority; and/or
3. We have entered into a contract with the organization with which we are sharing your information (based on the model clauses proposed by the European Commission) to ensure your information is adequately protected.