Brillion Privacy Notice

Last updated: 22 January 2023

Who are we and what do we offer?

We are SAWG Labs (us and/or we). We have developed and facilitate the Brillion Smart Wallet (Wallet), a smart wallet that provides users (Users) self-custody of digital assets and identity.

You can create an account (User Account) and access your Wallet on our Website: https://brillion.finance. The creation of a User Account, the use of a Wallet, visiting the Website and all services related thereto are collectively referred to as the Services.

Our website has been developed by the Webflow agency Gemeos.

Privacy Notice

This is our Privacy Notice. In this document, we explain what kind of Personal Data we may collect via our Services. We also explain what role we have in the processing of Personal Data, how long we retain them, and what rights you have as a data subject.

Personal Data and Controller

With your use of our Services, we may process Personal Data. Personal Data means all information by which a person can be directly or indirectly identified. Although we generally have no access to or control over the Personal Data that you enter as part of your use of the Services, under the General Data Protection Regulation (GDPR) we still qualify as the so-called Controller of your Personal Data. This means that we determine the purposes and the means of the processing of your Personal Data.

If you have questions about the processing of your Personal Data, you can always contact us through the contact details listed at the bottom of this Privacy Notice.

What Personal Data do we collect as Controller?

If you create a User Account, we may process the following Personal Data:

• contact details (name, email address, username).
• username and account details of chosen social media platform (Brillion supports several social media platforms such as Twitter, Facebook, Discord, and GitHub).
• username and account details (Brillion currently supports Web3 wallets such as MetaMask, Rainbow and Trustwallet).

We use these Personal Data to:

• allow you to register your User Account to our Services; and
• contact you for the Services as requested.

We may process these Personal Data to perform our agreement with you, i.e. with respect to creating a User Account.

Online onboarding or Know-Your Customer (KYC) information:

We only process the outcomes of the following Personal Data points:

• information on your ID card: including your full name, date of birth, nationality, place of birth, place and date of the issuance of the document, date of expiry of the document, document type, document number, signatory and your photo. We will never process your social security number.
• current address and telephone number.
• face and Liveness validation.

If you use zero-knowledge proofs, we use these Personal Data to generate the following zero-knowledge truths:

• I am a real person,
• I am over 18/over 21,
• I am not from a high-risk country; and
• I am not from a jurisdiction under increased monitoring.

Use of zero-knowledge proofs increases the security and trustworthiness of our Services.

We may process these Personal Data to perform the agreement we have with you to deliver our Services and because we have a legitimate interest to protect our Services against unlawful and unethical financial transactions.

If you use your Wallet, we may process the following Personal Data:

If you use your Wallet to view, send, buy, receive or swap assets (such as cryptocurrencies, NFTs or other tokens):

• username, wallet address, overview of digital wallets, transaction history, transaction confirmation data, and verifiable credentials.
• payment information (IBAN-number, name account holder, and credit card number)

We use these Personal Data to:

• provide you with the Services as requested;
• process and administer payments; and
• include in our administration on behalf of the tax authorities.

We may process these Personal Data to perform the agreement we have with you to deliver our Services.

We are also legally obligated to share (some of) these data with the national financial and/or tax authorities.

Remittance Payments:

• username, wallet address, and transaction confirmation data.
• payment information (IBAN-number and name account holder).

We use these Personal Data to:

• provide you with our remittance payments services; and
• process and administer payments.

We may process these Personal Data to perform the agreement we have with you to deliver our Services.

Targeting you with specific offers that may interest you:

• contact details (name, e-mail address, username).
• information obtained to determine zero-knowledge proofs.

We use these Personal Data to:

• present potentially interesting opportunities for our Users; and
• connect third parties offering specific offers with you.

We may process these Personal Data because we have a legitimate interest to provide you with the full extent of our Services, which may include offers based on the outcomes of the zero-knowledge proofs.

Personal Data we may process of Users and Website visitors:

Technical information:

• information on your device type, browser type, session date and time, IP address, and browser type.

We use these Personal Data to:

• communicate in the same language of the browser;
• adapt our Website to the used device;
• enable you to use our Website; and
• improve the usability of our Website.

We may process these Personal Data because we have a legitimate interest to do so, i.e. to provide you with a good functioning Website and improve our Services for our Users and Website visitors.

If you contact us:

• your name, e-mail address, and the content of the correspondence.

We use these Personal Data to:

• answer your questions and/or handle any complaints;
• support you in using our Services; and
• improve our Services as a result of questions and feedback from you.

We may process these Personal Data because we have a legitimate interest to contact and assist you based on your comment or question and to improve our Services as a result of the questions and feedback we receive.

If you subscribe to our newsletter:

• name, surname, and e-mail address

We use these Personal Data to:

• send you our newsletter and keep you informed on all our (future) Services.

We may process these Personal Data if you gave us your consent to do so (by subscribing via our Website).

We may send our Users - who paid for our Services - newsletters because we have a legitimate interest to do so.

In every newsletter, there is a link via which you can unsubscribe.

How long do we keep the Personal Data?

It is our policy to store and process only those Personal Data that are essential to provide you with the best possible service.

We will not process or store any Personal Data that we do not need. We store Personal Data for as long as we need it for the above purposes, unless we are legally obliged to retain the Personal Data for a longer period.

With regard to the Personal Data that you enter as part of your User Account and your activities within your Wallet, you are solely in control of your Personal Data. We do not, and cannot access this Personal Data. With regard to other Personal Data we may process, we apply the following retention periods:

• Newsletters | We retain the Personal Data used for sending newsletters until you unsubscribe from our newsletter.
• Other information | We store other Personal Data only for as long as it is necessary to fulfill the purposes for processing. This is deleted as soon as it is no longer necessary for the purposes for which we processed it.

After the expiry of the retention period(s), we may process and retain certain Personal Data to comply with legal retention obligations and/or for fraud/misuse investigations or to substantiate a (judicial) claim. In such events, we will retain the Personal Data separately and only use such Personal Data for these purposes.

Do we share your Personal Data with others?

We may use third parties to assist us in our Services provided as Controller. For example, we use companies for identity verification and KYC-services and we allow the sharing of your Personal Data with banks and/or payment service providers through which remittance payments are issued.

Export of Personal Data outside the European Union

We may transmit Personal Data to parties outside the European Union. The Personal Data will only be transferred to countries and/or parties that provide an adequate level of protection in accordance with European standards. You may contact us if you wish to receive more information or a copy of the safeguards we take in this scope where necessary.

Third-party websites

You may find advertising or other (hyper)links on our Website that link to the websites, products, and services of partners, suppliers, advertisers, sponsors, licensors, or other third parties. We do not control the content or the links that appear on these websites and we are not responsible for the practices employed by websites linked to or from our Website. In addition, these websites, products, and services, including their content and links, may be constantly changing. These websites, products, and services may have their own privacy notices, user terms, and customer service policies. Browsing and interaction on any other website, including websites that are linked to or from our Website, are subject to the terms and policies of that website.

Your rights as a data subject and our contact details

You are always entitled to file a complaint with a data protection supervisory authority if you believe that we are not processing your Personal Data in accordance with the GDPR. In France, the supervisory authority for data protection is:

CNILWebsite: https://www.cnil.fr/

Changes to the Privacy Notice

The Privacy Notice may be changed from time to time. Please check our Privacy Notice frequently. The new Privacy Notice will be effective immediately upon posting on our Website. If we change our Privacy Notice significantly, then we will state so on our Website together with the revised Privacy Notice.

Contact details

If you have questions or concerns about this Privacy Notice or your privacy, you can contact us at hello@brillion.finance

SAWG Labs102 avenue des Champs-Élysées75008 ParisFRANCE

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