Privacy Policy
I. Important information and who we are
WalliD is an online protocol, developed by WalliD, S.A., with registered headquarters at Rua Fernanda Seno no. 6, 7005-485 Évora, Portugal and registration number 514988436 (hereinafter “WalliD”), that allows you to encrypt, store and share your identification documents online by using blockchain.
As used in this Privacy Policy, "we" and "us" means WalliD, and “you” and “user” means the person using WalliD.
WalliD respects your privacy and is committed to protecting your personal data. This privacy notice aims to give you information on how WalliD collects and processes your personal data through your use of the protocol.
Please also read WalliD Terms and Conditions ("Terms”),which describe the terms applicable to your use of StoreiD.
PLEASE NOTE THAT WALLID IS A PROTOCOL THAT IS BASED ON BLOCKCHAIN SOFTWARE AND, BECAUSE OF THAT, RECORDS INFORMATION IN PUBLIC BLOCKCHAINS.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
As used in this Privacy Policy, "we" and "us" means WalliD, and “you” and “user” means the person using WalliD.
WalliD respects your privacy and is committed to protecting your personal data. This privacy notice aims to give you information on how WalliD collects and processes your personal data through your use of the protocol.
Please also read WalliD Terms and Conditions ("Terms”),which describe the terms applicable to your use of StoreiD.
PLEASE NOTE THAT WALLID IS A PROTOCOL THAT IS BASED ON BLOCKCHAIN SOFTWARE AND, BECAUSE OF THAT, RECORDS INFORMATION IN PUBLIC BLOCKCHAINS.
We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
II. Contact details
● Full name of legal entity: WalliD, S.A.
● E-mail: privacy@wallid.io
You have the right to make a complaint at any time to the Portuguese Data Protection Commission (CNPD), the Portuguese supervisory authority for data protection issues (www.cnpd.pt). We would, however, appreciate the chance to deal with your concerns before you approach CNPD so please contact us in the first instance.
● E-mail: privacy@wallid.io
You have the right to make a complaint at any time to the Portuguese Data Protection Commission (CNPD), the Portuguese supervisory authority for data protection issues (www.cnpd.pt). We would, however, appreciate the chance to deal with your concerns before you approach CNPD so please contact us in the first instance.
III. Third-Party Links
WalliD may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control those third-party websites and we are not responsible for their privacy statements. When you leave WalliD, we encourage you to read the privacy notice of every website use.
IV. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed and the connection to the identity of the person is no longer possible (anonymous data).
The data we collect and store about you is encrypted data, which means that WalliD only receives and manipulates your data in a form or code that can only be accessed to or read with a secret key or password that you are the sole owner of.
By manipulating only encrypted data, WalliD does not receive any information that allows the identification of the end user.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
If you fail to provide personal data where we need to collect it, we will not be able to provide you WalliD services.
The data we collect and store about you is encrypted data, which means that WalliD only receives and manipulates your data in a form or code that can only be accessed to or read with a secret key or password that you are the sole owner of.
By manipulating only encrypted data, WalliD does not receive any information that allows the identification of the end user.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
● Identity Data: includes attributes of your identification document (such as: name, surname, address, gender, height, country, birth date, nationality, type of document, document number, document version, issuance date, expiry date, place of request, issuing entity, signature, civil status, name of your parents, taxpayer number, social security number, health number, digital certificate associated with your identification document), wallet address, wallet signature.● Transaction Data: pointers generated by WalliD which link each blockchain transaction to the WalliD digital wallet address.
● Technical Data: includes internet protocol (IP) address, unique device identifier, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services, device model.
● Usage Data: includes information about how you use our website, products and services.
● Aggregated Data: we also collect and use Aggregated data, such as statistical or demographic. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may be provided with aggregated data collected by third parties to understand the percentage of users accessing a specific website feature. We do not combine or connect Aggregated Data with your personal data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
● Technical Data: includes internet protocol (IP) address, unique device identifier, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our services, device model.
● Usage Data: includes information about how you use our website, products and services.
● Aggregated Data: we also collect and use Aggregated data, such as statistical or demographic. Aggregated Data may be derived from your personal data but is not considered personal data as this data does not directly or indirectly reveal your identity. For example, we may be provided with aggregated data collected by third parties to understand the percentage of users accessing a specific website feature. We do not combine or connect Aggregated Data with your personal data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data where we need to collect it, we will not be able to provide you WalliD services.
V. How is your personal data collected?
We use different methods to collect data from and about you, including through:
● Direct interactions. You may give us your Identity Data by filling in forms or by corresponding with us by email or otherwise. This includes personal data you provide when you:
● Third parties or publicly available sources. We may receive Aggregated Data from various third parties and public sources from the analytics providers, based in the EU and outside the EU.
i. use our services;
ii. give us some feedback or contact us.
● Automated technologies or interactions. As you interact with WalliD, we may automatically receive, collect or generate Transaction, Technical and Usage Data. We collect this personal data by server logs, plug-ins and other similar technologies. ii. give us some feedback or contact us.
● Third parties or publicly available sources. We may receive Aggregated Data from various third parties and public sources from the analytics providers, based in the EU and outside the EU.
VI. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
● Where we need to provide you our services.
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal or regulatory obligation.
● Where you have given to us your consent to use your personal data. Whenever we need your consent to proceed with any usage of data, we will collect it. You have the right to withdraw consent at any time by Contacting Us .
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● Where we need to comply with a legal or regulatory obligation.
● Where you have given to us your consent to use your personal data. Whenever we need your consent to proceed with any usage of data, we will collect it. You have the right to withdraw consent at any time by Contacting Us .
VII. Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal grounds we are relying on to process your personal data, where more than one ground has been set out in the table below.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact Us if you need details about the specific legal grounds we are relying on to process your personal data, where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To store part of your identification document in the blockchain | ● Identity Data (attributes of your identification document). ● Transaction Data (pointers). | Provision of services to you. |
| To store part of your identification document in StoreiD database | ● Identity Data (digital certificate of your identification document, wallet signature). ● Transaction Data (pointer to your wallet address). | Provision of services to you. |
| To store information in the Relayer database | ● Transaction Data (pointers which link your wallet address to the Identity Data stored in the blockchain). | Provision of services to you. |
| To manage and reply to your requests under this privacy policy | ● Identity | Legal obligation. |
| To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). | ● Identity ● Technical | ● Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise). ● Necessary to comply with a legal obligation. |
| To use data analytics to improve our website, products/services, customer relationships and experiences. | ● Technical Data ● Usage Data | Necessary for our legitimate interests (to define types of users for our products and services, to keep our website updated and relevant, to study how customers use our products/services and to develop our business). |
Change of Purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
VIII. Cookies
A cookie is a small file placed onto your device that enables the website features and functionality. We only use cookies on the website.
At any moment, you can set your browser to accept or reject new cookies or to deactivate cookies already installed in your computer or mobile device. This action could retrieve on an unsatisfying use of the website.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
At any moment, you can set your browser to accept or reject new cookies or to deactivate cookies already installed in your computer or mobile device. This action could retrieve on an unsatisfying use of the website.
● How do we use cookies: On our website we use cookies for performance, analytics and research purposes. That means that cookies help us learn how well our website performs in different locations. We also use cookies to understand, improve, and research products, features, and services, including when you access the website from other websites, applications, or devices such as your computer or your mobile device.
● Types of cookies we use: We only use “Third Party Cookies”, which are cookies placed by a third party (including, for example, providers of external services like web traffic analysis services) in the website, over which we have no control. These cookies are analytical/performance cookies.
● Types of cookies we use: We only use “Third Party Cookies”, which are cookies placed by a third party (including, for example, providers of external services like web traffic analysis services) in the website, over which we have no control. These cookies are analytical/performance cookies.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
| Name | Domain** | Description | Expiry | Opt-out |
|---|---|---|---|---|
| 1P_JAR, CONSENT | gstatic.com | Set by Google. This group sets a unique ID to remember your preferences and other information such as website statistics and track conversion rates. | Various | https://support.google.com/analytics/answer/6004245 |
*Please note that the names of cookies may change over time.
If you don’t want to receive cookies, you can change your browser settings on your computer or other device you’re using to access our websites. If you use our website without changing your browser settings, we’ll assume that you’re happy to receive all cookies related with the website. Most browsers also provide functionality that lets you review and erase cookies.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit: www.allaboutcookies.org , www.aboutcookies.org.
● Controlling cookies: Most browsers allow you to control cookies through their settings preferences. However, if you limit the ability of websites to set cookies, you may worsen your overall user experience, since it will no longer be personalized to you. It may also stop you from saving customized settings like login information.
If you don’t want to receive cookies, you can change your browser settings on your computer or other device you’re using to access our websites. If you use our website without changing your browser settings, we’ll assume that you’re happy to receive all cookies related with the website. Most browsers also provide functionality that lets you review and erase cookies.
To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit: www.allaboutcookies.org , www.aboutcookies.org.
IX. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table above:
● Public Blockchain: due to the particular nature of WalliD, parts of your identification document will be recorded in public blockchains, in an encrypted manner. Please note that by using WalliD parts of your data will be store in public blockchains which servers may be located anywhere in the world. This means that your personal data may be stored in other jurisdictions, including from the European Economic Area and outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
● External Third Parties:
i. Service providers, acting as processors, who provide IT, IT infrastructure services and provision of analytics services.
ii. Regulators and other authorities who require reporting of processing activities in certain circumstances.
iii. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to guarantee the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
● Public Blockchain: due to the particular nature of WalliD, parts of your identification document will be recorded in public blockchains, in an encrypted manner. Please note that by using WalliD parts of your data will be store in public blockchains which servers may be located anywhere in the world. This means that your personal data may be stored in other jurisdictions, including from the European Economic Area and outside the European Economic Area, in countries which may not be regarded as providing the same level of protection as the jurisdiction you are based in.
● External Third Parties:
i. Service providers, acting as processors, who provide IT, IT infrastructure services and provision of analytics services.
ii. Regulators and other authorities who require reporting of processing activities in certain circumstances.
iii. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to guarantee the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
X. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed.
To ensure the security of your personal data, WalliD has taken the following measures:
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
To ensure the security of your personal data, WalliD has taken the following measures:
● Construed the protocol in a way that it does not allow WalliD to have access or store your personal data in an unencrypted manner. The data stored by WalliD can only be decrypted by you.
● o ensure that, WalliD protocol only receives your personal data encrypted by you, using your digital wallet public key
● Your identification data (already encrypted by you and divided in “blocks” of data), is then encrypted once again by WalliD.
● After the second encryption, the blocks of your identification data is sent to WalliD’s backend services.
● The Relayer Service on WalliD’s backend is called, which triggers the creation of a pointer that links each blockchain transaction to the WalliD digital wallet address (and not to your digital wallet address). ● To increase security, WalliD has designed the protocol to keep part of your personal information in separate databases:
● o ensure that, WalliD protocol only receives your personal data encrypted by you, using your digital wallet public key
● Your identification data (already encrypted by you and divided in “blocks” of data), is then encrypted once again by WalliD.
● After the second encryption, the blocks of your identification data is sent to WalliD’s backend services.
● The Relayer Service on WalliD’s backend is called, which triggers the creation of a pointer that links each blockchain transaction to the WalliD digital wallet address (and not to your digital wallet address). ● To increase security, WalliD has designed the protocol to keep part of your personal information in separate databases:
● the StoreiD off-blockchain database stores the digital certificate of your identification document, a pointer to your digital wallet address and your wallet signature. This data is encrypted with your wallet public key. Please note that depending on the type of your identification document, the database that stores this information may not be the StoreiD database, but a database managed and controlled by a third-part.
● The attributes of your identification document (“User ID attributes”) are stored on the blockchain associated to the pointer generated within WalliD’s Relayer Service
● The attributes of your identification document (“User ID attributes”) are stored on the blockchain associated to the pointer generated within WalliD’s Relayer Service
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so
XI. Data retention
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
Please note that, in what relates to the data recorded in public blockchains, due to the nature of such blockchains, we will not be able to erase, delete or change the data recorded.
owever, we have construed the WalliD protocol in a way that allows the storage limitation of your personal data and the unavailability of your personal data from a technological perspectivellows the storage limitation of your personal data and the unavailability of your personal data from a technological perspective.
Upon receiving a request from you to erase your personal data, we will irreversibly eliminate WalliD Key that is necessary to decrypt your personal data posted in the blockchain and the data stored in the Relayer database that is needed to map the pointers linking the transactions written in the blockchain.
Please note that, in what relates to the data recorded in public blockchains, due to the nature of such blockchains, we will not be able to erase, delete or change the data recorded.
owever, we have construed the WalliD protocol in a way that allows the storage limitation of your personal data and the unavailability of your personal data from a technological perspectivellows the storage limitation of your personal data and the unavailability of your personal data from a technological perspective.
Upon receiving a request from you to erase your personal data, we will irreversibly eliminate WalliD Key that is necessary to decrypt your personal data posted in the blockchain and the data stored in the Relayer database that is needed to map the pointers linking the transactions written in the blockchain.
XII. Your Legal Rights
You are entitled to exercise the following rights:
● Request access to your personal data. This enables you to obtain confirmation that your personal data is being processed by us and, if that is the case, to request access to your personal data and check that we are lawfully processing it.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data until we verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw your consent at any time where we are relying on consent to process your personal data. 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.
If you wish to exercise any of the rights set out above, please Contact us.● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law.
● Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
● Request the restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data until we verify whether we have overriding legitimate grounds to use it.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw your consent at any time where we are relying on consent to process your personal data. 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.
XIII. No fee usually required
You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
XIV. What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure the exercise any of your rights. This is a security measure to ensure that personal data is not disclosed to unauthorised third parties. We may also contact you to ask you for further information in relation to your request to speed up our response.
XV. Time limit to respond
We try to respond to all requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.