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Privacy Policy

Latest update: 2 June 2023

This privacy policy is applicable to Web3Auth's Products (https://auth.web3auth.io), Torus wallet (https://app.tor.us). This privacy policy explicitly excludes business and developer interactions including the website (https://dashboard.web3auth.io). The policy does extend to Web3Auth/Torus's interactions with clients that integrate its SDK, but does not include what data our clients manage and collect themselves.

Owner and Data Controller​

Torus Labs Private Limited, 38 Lor Stangee, Singapore 425021

Contact email: hello@tor.us

Types of Data Collected​

Among the types of Data that Web3Auth collects, by itself or through third parties, there are: Anonymized Identifiers; Anonymized Usage Data.

The only data that Web3Auth requires is anonymised unique strings from third party authentication providers or clients, while user identifiable data from third party sources may be used to personalise user accounts on the user's client side, no user personal data is collected or stored by Web3Auth.

With regards to Anonymized Usage Data, details on each type of Anonymized Usage Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection. Anonymized Usage Data is collected automatically when using Web3Auth.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Web3Auth speficically does not use cookies to track users on its services. Cookies are explicitly used only on static sites defined in our Cookie Policy.

Mode and Place of Processing the Data​

Methods of Processing​

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data whilst on the users client-side. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Owner's (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place​

The Data is processed Owner's software on user devices. There is no user specific data that is processed on servers that can identify the user.

The users' Anonymized Usage Data is processed on the Owner's offices and premises as well as cloud setups managed by the Owner.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Retention Time​

Anonymized Usage Data shall be processed and stored for as long as required by the purpose they have been collected for.

Furthermore, the Owner may be obliged to retain Anonymized Usage Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Anonymized Usage Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The Purposes of Processing​

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Tag Management, Registration and authentication, Displaying content from external platforms and Traffic optimization and distribution.

Users can find further detailed information about such purposes of processing and about the specific Anonymized Usage Data used for each purpose in the respective sections of this document.

Detailed Information on the Processing of Anonymized Usage Data​

Anonymized Usage Data is collected for the following purposes and using the following services:

Analytics​

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to optimized Web3Auth software.

Displaying Content from External Platforms​

This type of service allows you to view content hosted on external platforms directly from the pages of Web3Auth and interact with them. This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

Registration and Authentication​

By registering or authenticating, Users allow Web3Auth to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, Web3Auth will be able to access some Data (that it will not store), by these third-party services, for registration or identification purposes.

Google OAuth (Google LLC)

Google OAuth is a registration and authentication service provided by Google LLC and is connected to the Google network.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Tag Management​

This type of service helps the Owner to manage the tags or scripts needed on Web3Auth in a centralized fashion. This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data collected: Cookies; Anonymized Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Traffic Optimization and Distribution​

This type of service allows Web3Auth to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Web3Auth and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc. The way Cloudflare is integrated means that it filters all the traffic through Web3Auth, i.e., communication between Web3Auth and the User's browser, while also allowing analytical data from Web3Auth to be collected.

Personal Data collected: Cookies; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

The Rights of Users​

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, if they can identify their Anonymized Data. Much of this exists for the right of the user, but may not be technically enforcable by Web3Auth as Personal Data is not stored:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Anonymized Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Personal Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if any forms of Personal Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Personal Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

How to Exercise these Rights​

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Web3Auth uses Cookies on some static sites. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing​

The User's Anonymized Usage Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Web3Auth or the related Services. The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional Information About User's Anonymized Usage Data​

In addition to the information contained in this privacy policy, Web3Auth may provide the User with additional and contextual information concerning particular Services or the collection and processing of it upon request.

System Logs and Maintenance​

For operation and maintenance purposes, Web3Auth and any third-party services may collect files that record interaction with Web3Auth (System logs) use other Usage Data (such as the IP Address) for this purpose.

Information not Contained in this Policy​

More details concerning the collection or processing of Anonymized Usage Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” Requests are Handled​

Web3Auth automatically respects “Do Not Track” requests as we do not store any user Personal Data. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this Privacy Policy​

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within Torus Labs and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Anonymized Identifier

Data used to identify unique accounts, which can include third party authentication token IDs and randomized strings.

Anonymized Usage Data

Information collected automatically through Web3Auth (or third-party services employed in Web3Auth), which can include: the IP addresses or device type of the computers utilized by the Users who use Web3Auth, the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using Web3Auth who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Web3Auth. The Data Controller, unless otherwise specified, is the Owner of Web3Auth.

Web3Auth (or this Application)

The means by which the Data of the User is collected and processed.

Service

The service provided by Web3Auth as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User's device.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to Web3Auth, if not stated otherwise within this document.