Privacy Policy
**************

Last Updated: 11.12.2019

This Privacy Policy describes the policies and procedures of Taler
Systems SA (“we,” “our,” or “us”) pertaining to the collection, use,
and disclosure of your information on our sites and related mobile
applications and products we offer (the “Services” or “Taler Wallet”).
This Privacy Statement applies to your personal data when you use our
Services, and does not apply to online websites or services that we do
not own or control.


Overview
========

Your privacy is important to us. We follow a few fundamental
principles: We don’t ask you for personally identifiable information
(defined below). That being said, your contact information, such as
your phone number, social media handle, or email address (depending on
how you contact us), may be collected when you communicate with us,
for example to report a bug or other error related to the Taler
Wallet. We don’t share your information with third parties except when
strictly required to deliver you our Services and products, or to
comply with the law. If you have any questions or concerns about this
policy, please reach out to us at privacy@taler-systems.net.


How you accept this policy
==========================

By using our Services or visiting our sites, you agree to the use,
disclosure, and procedures outlined in this Privacy Policy.


What personal information do we collect from our users?
=======================================================

The information we collect from you falls into two categories: (i)
personally identifiable information (i.e., data that could potentially
identify you as an individual) (“Personal Information”), and (ii) non-
personally identifiable information (i.e., information that cannot be
used to identify who you are) (“Non-Personal Information”). This
Privacy Policy covers both categories and will tell you how we might
collect and use each type.

We do our best to not collect any Personal Information from Taler
Wallet users. We believe that the Taler Wallet never transmits
personal information to our services without at least clear implied
consent, and we only process and retain information with a strict
business need. That being said, when using our Services, we inherently
have to collect the following information:

   * Bank account details necessary when receiving funds from you to
     top-up your wallet or to transfer funds to you when you are being
     paid via Taler. At the current experimental stage, only the
     pseudonym and password you entered in the bank demonstrator is
     stored.

   * The amounts being withdrawn or deposited, with associated unique
     transaction identifiers and cryptographic signatures authorizing
     the transaction. Note that for purchases, we cannot identify the
     buyer from the collected data, so when you spend money, we only
     receive non-personal information.

   * When you contact us. We may collect certain information if you
     choose to contact us, for example to report a bug or other error
     with the Taler Wallet. This may include contact information such
     as your name, email address or phone number depending on the
     method you choose to contact us.


How we collect and process information
======================================

We may process your information for the following reasons:

   * to transfer money as specified by our users (Taler transactions);

   * to assist government entities in linking income to the underlying
     contract as required by law and local regulations

   * to support you using the Taler Wallet or to improve our Services


How we share and use the information we gather
==============================================

We may share your Personal Data or other information about you only if
you are a merchant receiving income, with your bank, to the degree
necessary to execute the payment.

We retain Personal Data to transfer funds to the accounts designated
by our users. We may retain Personal Data only for as long as mandated
by law and required for the wire transfers.

We primarily use the limited information we receive directly from you
to enhance the Taler Wallet. Some ways we may use your Personal
Information are to: Contact you when necessary to respond to your
comments, answer your questions, or obtain additional information on
issues related to bugs or errors with the Taler Wallet that you
reported.


Agents or third party partners
==============================

We may provide your Personal Information to our employees,
contractors, agents, service providers, and designees (“Agents”) to
enable them to perform certain services for us exclusively, including:
improvement and maintenance of our software and Services.


Protection of us and others
===========================

We reserve the right to access, read, preserve, and disclose any
information that we reasonably believe is necessary to comply with the
law or a court order.


What personal information can I access or change?
=================================================

You can request access to the information we have collected from you.
You can do this by contacting us at privacy@taler-systems.net. We will
make sure to provide you with a copy of the data we process about you.
To comply with your request, we may ask you to verify your identity.
We will fulfill your request by sending your copy electronically. For
any subsequent access request, we may charge you with an
administrative fee. If you believe that the information we have
collected is incorrect, you are welcome to contact us so we can update
it and keep your data accurate. Any data that is no longer needed for
purposes specified in the “How We Use the Information We Gather”
section will be deleted after ninety (90) days.


What are your data protection rights?
=====================================

Anastasis would like to make sure you are fully aware of all of your
data protection rights. Every user is entitled to the following:

**The right to access**: You have the right to request Anastasis for
   copies of your personal data. We may charge you a small fee for
   this service.

**The right to rectification**: You have the right to request that
Anastasis correct any information you believe is inaccurate. You also
have the right to request Anastasis to complete information you
believe is incomplete.  The right to erasure - You have the right to
request that Anastasis erase your personal data, under certain
conditions.

**The right to restrict processing**: You have the right to request
   that Anastasis restrict the processing of your personal data, under
   certain conditions.

**The right to object to processing**: You have the right to object to
   Anastasis's processing of your personal data, under certain
   conditions.

**The right to data portability**: You have the right to request that
   Anastasis transfer the data that we have collected to another
   organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you
would like to exercise any of these rights, please contact us at our
email: privacy@taler-systems.com

You can always contact your local data protection authority to enforce
your rights.


Data retention
==============

If you uninstall the Taler Wallet mobile applications from your
device, or request that your information be deleted, we still may
retain some information that you have provided to us to maintain the
Taler Wallet or to comply with relevant laws.


Data security
=============

We are committed to making sure your information is protected. We
employ several physical and electronic safeguards to keep your
information safe, including encrypted user passwords, two factor
verification and authentication on passwords where possible, and
securing connections with industry standard transport layer security.
You are also welcome to contact us using GnuPG encrypted e-mail. Even
with all these precautions, we cannot fully guarantee against the
access, disclosure, alteration, or deletion of data through events,
including but not limited to hardware or software failure or
unauthorized use. Any information that you provide to us is done so
entirely at your own risk.


Changes and updates to privacy policy
=====================================

We reserve the right to update and revise this privacy policy at any
time. We occasionally review this Privacy Policy to make sure it
complies with applicable laws and conforms to changes in our business.
We may need to update this Privacy Policy, and we reserve the right to
do so at any time. If we do revise this Privacy Policy, we will update
the “Effective Date” at the bottom of this page so that you can tell
if it has changed since your last visit. As we generally do not
collect contact information and also do not track your visits, we will
not be able to notify you directly. However, the Taler Wallet may
inform you about a change in the privacy policy once it detects that
the policy has changed. Please review this Privacy Policy regularly to
ensure that you are aware of its terms. Any use of our Services after
an amendment to our Privacy Policy constitutes your acceptance to the
revised or amended agreement.


International users and visitors
================================

Our Services are hosted in Switzerland. If you are a user accessing
the Services from the European Union, Asia, US, or any other region
with laws or regulations governing personal data collection, use, and
disclosure that differ from Swiss laws, please be advised that through
your continued use of the Services, which is governed by Swiss law,
you are transferring your Personal Information to Switzerland and you
consent to that transfer.


Questions
=========

Please contact us at privacy@taler-systems.net if you have questions
about our privacy practices that are not addressed in this Privacy
Statement.