What information do we collect?
- Your full name
- Your e-mail address
- Your nationality
- Your IBAN
- Information about your device, browser or operating system
- your IP address used to access the website or app.
- Any information regarding your Lightning Network wallet, derived from invoices that you shared with us throught the application
- Any clicks on links within the application, which may use referal codes.
How and why we use/share your information
- Information that is required for logging into and using the app such as your e-mail and device information is shared with Google and/or Apple, depending on the platform that you use.
- Your bank account information is shared with our banking partner.
- We will never sell any customer data with 3rd parties, even in anonymized or aggregated form.
- In case of a law enforcement request regarding a criminal investigation we may share any information we have that’s needed to comply with a law enforcement request.
- We are obligated to monitor your account for suspicious activity and share any findings of suspicious activity with Belgian regulators, as described in the Belgian law VERPLICHTINGEN VAN DE ONDERWORPEN ENTITEITEN INZAKE DE VOORKOMING VAN HET WITWASSEN VAN GELD EN DE FINANCIERING VAN TERRORISME.
Your data may be stored and or processed on one or more cloud platform. As of today, these cloud platforms are:
- Amazon AWS
- Google Firebase
How long we keep your information
We will hold your personal information on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data: see ‘Your Rights’ below for further information.
As a data subject you have a number of rights in relation to your personal data. Below, we have described the various rights that you have as well as how you can exercise them.
Right of Access
You may, at any time, request access to the personal data that we hold which relates to you (you may have heard of this right being described as a “subject access request”).
Please note that this right entitles you to receive a copy of the personal data that we hold about you in order to enable you to check that it is correct and to ensure that we are processing that personal data lawfully. It is not a right that allows you to request personal data about other people, or a right to request specific documents from us that do not relate to your personal data.
You can exercise this right at any time by writing to us (email@example.com) and telling us that you are making a “subject access request”. You do not have to fill in a specific form to make this kind of request.
Your Right to Rectification and Erasure
You may, at any time, request that we correct personal data that we hold about you which you believe is incorrect or inaccurate. Please note that we may ask you to verify any new data that you provide to us and may take our own steps to check that the new data you have supplied us with is right.
You may also ask us to erase personal data that we control if you do not believe that we need to continue retaining it (you may have heard of this right described as the “right to be forgotten”). Although we will do everything to respect your request and personal data, it may not always be possible to erase all of your personal data as there may be legal requirements to keep certain personal data or technical limitations to the data we can delete.
There may also be legitimate interests in keeping certain data including, amongst others, if the data is required for the App to function. If this is the case, we will continue to process this data.
If erasure is not technically possible or we believe that we have a good legal reason to continue processing personal data that you ask us to erase, we will tell you this and our reasoning at the time we respond to your request.
You can exercise this right at any time by writing to us (firstname.lastname@example.org) and telling us that you are making a request to have your personal data rectified or erased and on what basis you are making that request. If you want us to replace inaccurate data with new data, you should tell us what that new data is. You do not have to fill in a specific form to make this kind of request.
Your Right to Restrict Processing
Where we process your personal data on the basis of a legitimate interest, you are entitled to ask us to stop processing it in that way if you feel that our continuing to do so impacts on your fundamental rights and freedoms or if you feel that those legitimate interests are not valid.
You may also ask us to stop processing your personal data a) if you dispute the accuracy of that personal data and want us verify that data’s accuracy; b) where it has been established that our use of the data is unlawful but you do not want us to erase it; c) where we no longer need to process your personal data (and would otherwise dispose of it) but you wish for us to continue storing it in order to enable you to establish, exercise or defend legal claims.
Please note that if for any reason we believe that we have a good legal reason to continue processing personal data that you ask us to stop processing, we will tell you what that reason is, either at the time we first respond to your request or after we have had the opportunity to consider and investigate it.
You can exercise this right at any time by writing to us (email@example.com) and telling us that you are making a request to have us stop processing the relevant aspect of your personal data and describing which of the above conditions you believe is relevant to that request. You do not have to fill in a specific form to make this kind of request.
Your Right to Portability
Where you wish to transfer certain personal data that we hold about you, which is processed by automated means, to a third party, you may write to us and ask us to provide it to you in a commonly used machine-readable format.
Because of the kind of work that we do and the systems that we use, we do not envisage this right being particularly relevant to the majority of individuals with whom we interact. However, if you wish to transfer your data from us to a third party we are happy to consider such requests.
Your Right to object to processing
You may object to processing of your personal data where we rely on legitimate interest for processing that personal data. We will comply with your request unless we have a compelling overriding legitimate interest for processing or we need to continue processing your personal data to establish, exercise or defend a legal claim.
Your Right to stop receiving communications
To unsubscribe from communications at any time, please click on the unsubscribe link at the bottom of any email and update your notification preferences in the App. For details on your rights to ask us to stop sending you various kinds of communications, please contact us (firstname.lastname@example.org).
Your Right to object to automated Decision Making and Profiling
You have the right to be informed about the existence of any automated decision making and profiling of your personal data, and where appropriate, be provided with meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing that affects you.
Withdrawal of Consent
Where we are relying on consent to process your personal data, you may withdraw consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Exercising your rights
When you write to us making a request to exercise your rights, we are entitled to ask you to prove that you are who you say you are. We may ask you to provide copies of relevant ID documents to help us to verify your identity.
It will help us to process your request if you clearly state which right you wish to exercise and, where relevant, why it is that you are exercising it. The clearer and more specific you can be, the faster and more efficiently we can deal with your request. If you do not provide us with sufficient information, then we may delay actioning your request until you have provided us with additional information (and where this is the case, we will tell you).
You can mail us at (email@example.com).