MNTD. App - Privacy Notice

Last Updated: 14.November 2022

The MNTD application available on IOS and Android platforms, including the associated software, tools, information, and services available therein (the โ€œApplicationโ€), is provided by MNTD PTE. LTD. (โ€œweโ€, โ€œourโ€, โ€œusโ€). With respect to personal data collected within the Application we act as a data controller.

In this Privacy Notice we explain how your personal data is collected and processed. โ€œYouโ€, โ€œyourโ€ refers to you as an individual using the Application. Personal data or personal information means any information directly or indirectly identifies you as an individual.

Unless otherwise defined herein, the capitalised terms used herein shall have the meanings provided in the MNTD App Terms of Service.

We make our best efforts to process personal data in accordance with the applicable data protection legislation. If you have any questions regarding processing of your personal data, do not hesitate to contact us via the contact details provided below.

1. Contact Details

MNTD PTE. LTD.

Unique Entity Number 202124287C

1 Marina boulevard #28-00

One Marina Boulevard Singapore (018989)

Data Protection Officer

MNTD has appointed the external DPO โ€” Sekurno Oรœ:

An information security and data protection firm.

Company number: 14992608.

Address: Estonia, Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151.

DPOโ€™s email: [email protected]

Please contact us or our DPO to receive answers to any data protection-related questions. Please note that we may record any communication to preserve the evidence of the existence of your request and our response.

EU representative

MNTD has appointed an EU Representative (as required by Article 27 of the GDPR). The representative would act as a contact point for supervisory authorities and data subjects.ย ย 

Correspondence address: Rickert Rechtsanwaltsgesellschaft mbH; ColmantstraรŸe 15, 53115, Bonn, Germany.

EU Representativeโ€™s email: [email protected]

2. What Information Is Collected

a. Wallet Address

When you start using the Application, you may need a Wallet. Therefore, in order for you to use the functionality of the Application, we process your public blockchain address associated with your Wallet (the โ€œWallet Addressโ€). However, you may be able to access the Application without a Wallet, however, in this case, the functionality of the Application will be limited.

The Wallet Address is a unique set of numbers and letters assigned to you by the Helium Blockchain Network. Please note that the Wallet Address is publicly available within the Helium Blockchain Network to any person and we retrieve it directly from the Helium Blockchain Network each time when you access the Application.

We collect and process your Wallet Address in order to allow you to connect your Wallet to the Application, associate it with your respective Hotspots, and to demonstrate the Wallet balance. The legal basis for the processing of your Wallet Address is performance of a contract with you, i.e., to let you use the Application functionality.

We process your Wallet Address as long as the Wallet is connected to the Application and you access the Application.

b. Transactions

Within the Application, you may be able to review or initiate certain transactions on the Helium Blockchain Network.

The transactions are conducted within the Helium Blockchain Network, the Application only retrieves the information and demonstrates it within the interface.

To demonstrate the transactions within the Application interface, we receive the transaction details, such as transaction hash, payer address, payee address, date, time, and amount.

The legal basis for the processing of the Transactions is the performance of a contract with you, i.e., to let you use the Application functionality.

Please note that the Transactions is publicly available within the Helium Blockchain Network to any person. We receive the Transactions directly from the Helium Blockchain Network.

We process the Transactions as long as your Wallet is connected to the Application.

c. Hotspot Address

Each Hotspot has a unique address (identificator) assigned to it by the Helium Blockchain Network (the โ€œHotspot Addressโ€). The Hotspot Address is necessary for the Helium Blockchain Network to identify each Hotspot connected to it and properly maintain the interaction of the Hotspot with the Helium Blockchain Network.

When you onboard the Hotspot within the Application, the Hotspot Address is recorded in the Helium Blockchain Network. Please note that the Hotspot Address will be: (a) processed by the Helium Blockchain Network, (b) publicly accessible by any person, and (c) processed permanently in the Helium Blockchain Network. The Hotspot Address is also automatically associated with your Wallet Address. It is not technically possible to use a Hotspot within the Application other than as described above.

Please note that you may transfer your Hotspot to a certain other Wallet Address, in which case the Hotspot will no longer be associated with the preceding Wallet Address. If you turn off the Hotspot or cease using the Application, the Hotspot Address will still be stored within the Helium Blockchain Network and will still be associated with the respective Wallet Address.

The legal basis for the processing of the Hotspot Address is performance of a contract with you, i.e., to let you use the Application and Helium Blockchain Network functionality.

We also process the Hotspot Addresses connected to the Helium Blockchain Network users to display them in the search results when a user utilises the search functionality in the Application. The legal basis for the processing of such Hotspot Addresses is our legitimate interest to provide the Application users with the search functionality of the Hotspot Addresses which are already publicly available in the Helium Blockchain Network.

We process the Hotspot Address as long as you use the Application with your respective Wallet. Accordingly, we do not process the Hotspot Address if you do not use the Application with your respective Wallet. As for the Hotspot Addresses that we demonstrate in the search results, we process them as long as they are available on the Helium Blockchain Network.

d. Hotspot Name

The Hotspot Name is a Hotspot animal name, which is composed of three (3) words automatically generated and assigned by the Helium Blockchain Network (not by us) to a certain Hotspot connected to the Helium Blockchain Network. The Hotspot Name is created with the Angry Purple Tiger algorithm.

We process the Hotspot Names in order to display them in the Application, including via search functionality.

The legal basis for the processing of the Hotspot Name is our legitimate interest to provide the Application users with the search functionality of the Hotspot Names which are already publicly available in the Helium Blockchain Network.

We process the Hotspot Names when we need to demonstrate them within the Application, including in order to display them in the Application search functionality. We retrieve the Hotspot Names from the Helium Blockchain Network.

e. Device ID

Each device using the Application is assigned with its unique identificator (the โ€œDevice IDโ€). The Device ID does not by itself constitute personal data as it represents a random set of symbols. We assign the Device ID to identify the device used by you in connection with the Application. In particular, we use the Device ID to send push notifications with respect to your Wallet, Hotspots, or Transactions.

f. Email Address

When you access the Application, you may be able to log in with a RAK ID account (the โ€œRAK ID Accountโ€), which is also operated by RAKwireless Technology Limited. More information regarding the RAK ID Account is available in the RAK ID Privacy Notice (the โ€œRAK ID Noticeโ€), which is available on the RAK ID website (the โ€œRAK ID Websiteโ€). We and RAKwireless Technology Limited are deemed independent data controllers. You may exercise your data protection rights with respect to either RAKwireless Technology Limited or us. However, to manage your RAK ID Account you should use the RAK ID Website, including to disconnect your RAK ID Account from the Application.

Please note that you can manage your RAK ID Account within the RAK ID Website. The data processing of the data associated with your RAK ID Account is also subject to the RAK ID Notice. We suggest you read the RAK ID Notice before registering and using the RAK ID Account.

If you do not have a RAK ID Account, you may register it within the RAK ID Website. In this case, the email address will be stored both within the Application and RAK ID Account.

When you log in with your RAK ID Account, we will receive the email address associated with the respective RAK ID Account. The email address will be associated with your respective Wallet Address.

Log in with RAK ID Account is optional. The legal basis for processing your email address is our legitimate interest to make the use of the Application more user friendly.

g. Location

In order to properly onboard a Hotspot to the Application, you shall provide the location of the respective Hotspot (the โ€œLocationโ€). The Location is necessary due to the nature of the Helium Blockchain Network, which is a โ€œproof-of-coverageโ€ blockchain that requires to know the precise Location of each onboarded Hotspot.

You may enter the Location either manually (by personally typing the address of the Hotspot) or by using the geolocation data of your device. In the latter case, the Application will request your permission to use the geolocation data of your device; if you do not provide such permission, you will only be able to enter the Location manually.

If you use the geolocation data of your device, the Application will use the services provided by Mapbox. Such services are operated by Mapbox, Inc. registered at 740 15th Street NW, 5th Floor, Washington DC 20005, United States.

In this case, the Location may be transferred to Mapbox pursuant to this Data Processing Agreement. For more information, please review Mapbox Privacy Documentation. Note that competent US state authorities may have access to the personal data collected via Mapbox.

When you onboard a Hotspot, we will process the Location and associate it with the respective Hotspot Address. The Application will transfer the Location to the Helium Blockchain Network, as it is necessary for the proper functioning of the Hotspot and its interaction with the Helium Blockchain Network. Please note that the Location will be permanently available within the Helium Blockchain Network and it is literally impossible to either delete or change it. You may always update the Location, however, the previous Location will still be stored within the Helium Blockchain Network.

Please note that the Location must be associated with the address of the appropriate Hotspot, not necessarily with your personal location or location of your residence.

The legal basis for the processing of the Location is performance of a contract with you, i.e., to let you use the Application and Helium Blockchain Network functionality.

We process the Location as long as you use the Application with your respective Wallet. Accordingly, we do not process the Location if you do not use the Application with your respective Wallet for example when you close the Application. Please note that the Location will be permanently stored within the Helium Blockchain Network.

h. Support

You may contact us via the contact details indicated in this Privacy Notice or within the Application, including via Discord. When you contact us or submit a request, you may provide us with certain additional personal information. Such information may include your Discord account nickname, email address, or any other personal information that you choose to provide to us.

This data is necessary to address your issue, answer your request, contact you back, or address you properly, where and as applicable depending on the type of personal information. The legal basis for processing such data โ€” our legitimate interest to assist you with your request regarding the Application.

If you contact us via Discord, certain personal data will be processed by Discord according to Discordโ€™s Privacy Policy.

i. Analytics

We use Sentry within the Application. Sentry is the error and performance monitoring software offered by Functional Software, Inc. Sentry provides us with information about crashes and malfunctions in the Application. In case of malfunction or failure, the following information is transmitted:

  1. information about the device and the browser, such as Sentry device ID, model and device type, screen parameters, name and version of the operating system, and settings of the device (e.g., language); โ€‹โ€‹โ€‹

  2. version and functionality of the Application;

  3. date, time and timezone of the crash event;

  4. place in the Application where the crash happened.

With the aforementioned information, we do not intend to identify you as an individual, however, according to the applicable data protection legislation, it may be considered personal data.

We use Sentry to improve the Application and ensure its stability. The legal basis for processing the data collected via Sentry is our legitimate interest. Information collected with Sentry is stored during 90 days from the date when the malfunction took place.

For more information regarding the data processing by Sentry, please refer to Sentryโ€™s Privacy Policy

j. PIN Code

Within the Application you may create a PIN code which may be used to login into the Application and confirm the transactions regarding the transfer of the Hotspot to the other Wallet Address. Creation of a PIN code is not mandatory.ย 

The PIN code is encrypted and stored on your device and we process it when you use the PIN code in order to verify its correctness.

The legal basis for the processing of the PIN code is our legitimate interest, i.e., to let you secure and protect the Wallet and aforementioned transactions.

We do not store your PIN code and we process it only when you use the PIN code.

k. Wi-Fi Password

In order to onboard a Hotspot to the Application, it is necessary to provide the Wi-Fi password of the network to which the Hotspot will be connected. The Application transfers the Wi-Fi password to the Hotspot, however, we do not store the Wi-Fi passwords.

The legal basis for the processing of the Wi-Fi password is performance of a contract with you, i.e., to let you use the Application functionality.

We do note store the Wi-Fi passwords and we process them only when you connect the Hotspot.

3. Your Information and Blockchain

Please kindly note that the Wallet Address, Transactions, Hotspot Address, Hotspot Name, and Location are available and used within the decentralised Helium Blockchain Network. Essentially, this data is stored within the Helium Blockchain Network. We do not control nor operate the Helium Blockchain Network. This means that due to the structure of the Helium Blockchain Network certain rights or abilities may be limited and we may not be able to influence your data on the Helium Blockchain Network. It also means that the Wallet Address, Transactions, Hotspot Address, Hotspot Name, and Location are publicly available to any person who has access to the Helium Blockchain Network. Please be aware that any transaction within the Helium Blockchain Network is irreversible and information put into the Helium Blockchain Network cannot be deleted or changed. If you do not agree with your data being processed on the Helium Blockchain Network, you should not use the Application or transact on the Helium Blockchain Network.

4. How Your Information Is Shared

We do not sell or rent out your personal data. However, we may share your personal data if it is reasonably necessary for the performance of our undertakings with you and our legitimate interest to maintain and develop the Application. In particular, your personal information is shared with the following categories of recipients:

  1. Our affiliates if necessary due to our corporate structure.

  2. Our subcontractors and team members, e.g., support team, technical team, etc.

  3. Third-party solutions related to or integrated within the Application, e.g.:

    • RAKwireless Technology Limited, if you log in using RAK ID Account;

    • Mapbox, when you use geolocation tracking within the Application;

    • Sentry, when you use the Application and a crash takes place.

  4. Service providers used to send push notifications

  5. Discord, if you use Discord to contact us.

  6. Hosting providers.

  7. Government institutions that may request access to your personal data.

Please note that certain data will be publicly available within the Helium Blockchain Network, as described in section โ€œYour Information and Blockchainโ€ above. You may also share your Wallet Address and/or Hotspot Address to third parties by using the Application functionality.

5. Your Rights

According to the applicable data protection legislation, you may have the following rights:

a. to request access to your personal data (commonly known as a โ€œdata subject access requestโ€). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;

b. to request correction (rectification) of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected;

c. to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good 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;

d. to object to processing of your personal data where we are relying on a legitimate interest 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. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

e. to request 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: (1) if you want us to establish the dataโ€™s accuracy, (2) where our use of the data is unlawful but you do not want us to erase it, (3) 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, (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

f. to 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. Also note that the data available on the Helium Blockchain Network may be collected and structured by you at any time;

g. to withdraw consent at any time where we are relying on consent to process your personal data. Note that currently we do not rely on your consent to process your personal data;

h. not to be subject to a decision based solely on automated processing of data, including profiling, which produces legal effects concerning you or similarly significantly affecting you;

i. to file a complaint with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable data protection legislation. Relevant supervisory authority will particularly depend on where you are located or where your rights were violated.

As we cannot identify you as an individual, according to the applicable data legislation, you cannot exercise your data subjectโ€™s rights, unless you provide us with additional information confirming that the data processed by us is genuinely related to you. For this reason, we may also request you to conduct certain actions (such as to conduct a blockchain transaction) to verify your identity and confirm that you have the right to exercise the data subjectโ€™s rights. For the avoidance of doubt, you cannot enforce your data subjectโ€™s rights with respect to the personal data unless we are sure that such data is associated with you. However, in any case, certain data protection rights may be limited as described below.

Please note that due to the nature of the processing operations within the Application, we may not be able to exercise certain rights that you may have pursuant to the applicable data protection legislation. When interacting with the Helium Blockchain Network we may not be able to ensure that your personal data is deleted, corrected, or restricted. This is because the Helium Blockchain Network is a public decentralised network and blockchain technology does not generally allow for data to be deleted or changed and certain rights cannot be enforced. In these circumstances, we will only be able to exercise your rights with respect to the information that is stored on our servers and not on the Helium Blockchain Network. If you want to ensure your privacy rights are not affected in any way, you should not transact on public blockchains (such as the Helium Blockchain Network) as certain rights may not be fully available or exercisable by you or us due to the technological infrastructure of the Helium Blockchain Network.

6. Third-Party Links

This Application may include links to third-party websites 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 these third-party websites and applications, and are not responsible for their privacy practices. When you leave the Application, we encourage you to read the respective privacy policy/notice/statement of the website or application you visit.

7. Children Personal Data

The Application is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use personal data of children, and in case we acknowledge that we received such data, we will, if possible, erase it within a reasonable timeframe.

8. Changes to This Privacy Notice

We keep this Privacy Notice under regular review and we may update it at any time. If we make any changes to this document, we will change the โ€œLast Updatedโ€ data above. Please review this Privacy Notice regularly.

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