This Policy explains how your personal data may be processed when you use the EVER Wallet browser extension and/or mobile application (hereinafter - the Wallet). It does not address Finstream OU’s other personal data processing operations, for example where we provide services to you on the basis of a contract between us. Additional policies and procedures addressing these processes are in place and we provide information to data subjects at the point of data collection or subsequently, as required by law.

The Wallet is developed and operated by Finstream OU, a company registered under the legislation of the Republic of Estonia at the address Harjumaa, Tallinn, Lasnamae linnaosa, Katusepapi tn. 4/2, 11412, Estonia. Contact us via email at dpo@broxus.com with any questions regarding this Policy or any other data protection issue related to the Wallet.

In line with our mission and values, we have built the Wallet so that we do not collect any data from users for any purpose. Our only interest is maintaining the security of the Wallet, therefore:

• we do not set any cookies;
• we do not collect any data whatsoever about people who use the Wallet;
• we do not conduct any analysis of how people use the Wallet;
• we do not allow third-party tracking of any kind on the Wallet.

Due to the nature of the Wallet, we use the facilities of Google Chrome Store, Google Play Store, and Apple Store (hereinafter - the Stores) to distribute the Wallet to our users. Although we do not provide any user data to the Stores, they may collect some information about you, as stipulated in their Privacy Policies.

As no user data is collected at our servers, the Wallet stores such information as seed phrases and private keys at your device in an encrypted form. The access to these data is controlled solely by you by setting the password for encryption and/or using the biometry features of your device (subject to the Privacy Policy of the device manufacturer).

Where Finstream OU processes your personal data you may have the right:

• to be informed as to whether AWO holds data about you;
• to access that data;
• to have inaccurate data corrected;
• to have your data deleted;
• to opt-out of particular data processing operations;
• to receive your data in a form that makes it “portable”;
• to object to data processing;
• to receive an explanation about any automated decision making and/or profiling, and to challenge those decisions where appropriate.

You can seek to exercise these rights via email to dpo@broxus.com. You also have the right to lodge concerns or complaints with the Estonia Information Commissioner’s Office. Data subjects covered by EU law may also be entitled to lodge complaints with the data protection supervisory authority in their country of residence.

We may update this Policy in the future. We will maintain an accessible record of any such changes.

Policy published 14th February 2022.