The WalletSaver PRIVACY POLICY

WalletSaver is committed in protecting your privacy by collecting only the minimum amount of information needed to provide our software, website, and services.

We collect and use the personal information of our registered Users in accordance with the provisions of Legislative Decree No. 196/2003 (Code relating to the protection of personal data) and with the GDPR (General Data Protection Regulation).

The insertion of the User's personal data, to be done during registration, complies with the provisions of the Information Statement pursuant to article 13 of Legislative Decree 196/2003.

The User consents to the processing of his/her personal data by adhering to and accepting the contractual General Conditions and this Privacy Policy.

Why WalletSaver needs to collect data

The Data concerning the User is collected to allow WalletSaver to provide its main Services, as well as for the additional purposes:

  1. Improving the quality and structure of WalletSaver services and the creation of new functions, features and services;
  2. The operation, maintenance and technical support relating to the Services;
  3. Communicating with you about the Services and/or responding to communications from you;
  4. Verification of the legitimate User's regular use of the account and the protection of the account from unauthorized access;
  5. The reporting of illegal activities to the Competent Authorities.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Which data we collect

Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at dataprotection@walletsaver.com.

The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of this Application.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.

Information not requiring specific permission

For the following information, the user must agree to this Privacy Policy and to the Terms and Conditions in order to give us the right to have access to them.

Personal Information

The Personal information gathered and stored in the User profile are related to the Registration and to the actual Services provided by our app.

Registration Data

The following data will be directly provided by the user or extracted from the device in order to create User Profile:

  1. Name
  2. Surname
  3. Email
  4. User's Country

To create the User Profile, the user will be able to use also the Facebook login  (more info about Facebook permissions documentation) or Google Login, and in these cases our Service will access the following information:

Other data necessary for our Services

Phone Usage Information

In order to provide our Services, our app requires the access to information related to the User’s phone usage.

Approximate location permission (continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

If the User refuses to provide personal information, he/she may not enter into any contract with WalletSaver, may not create an account, or access any of the services for which registration is required.

The disclosure of personal data is required for each User in order to open an account and to use Services regulated by the account.

Information requiring specific permission

In order to allow WalletSaver to have access to the following information, the user must agree to this Privacy Policy and to the Terms and Conditions AND provide specific permission, asked inside the app.

Contacts permission

Used for accessing contacts and profiles on the User's device. This will be necessary in order to show the correct Contacts inside the app and to allow the user to know which carrier they are using.

Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.

By allowing this permissions, the User will authorize our Service to extract and process the following information:

  1. The duration of incoming and outgoing of phone calls;
  2. The phone calls date and time;

Messages permission

Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.

By allowing this permissions, the User will authorize our Service to extract and process the following information:

  1. The SMS sent and received;
  2. The SMS date and time.

Usage Access permission

Permission needed to track the internet consumption of the User’s device splitted per app.

By allowing this permission, the User will authorize our Service to extract and process the following information:

  1. Connection type (Mobile, Wifi, Roaming)
  2. Data session
  3. Date & time
  4. Per app consumption
  5. IP address
  6. Wifi network name and SSID & BSSID

Location permission

It is necessary to provide permission to this app for the “Location” data in order to enable the Services connected to network analysis and suggestion.

Precise location permission (continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

Analytics information

WalletSaver can record information regarding the use of the software and the website by the User (frequency of access, use of favorite Services, size of data transfers, the information displayed by the User, and so on).

WalletSaver will also use information that does not allow direct identification of the User (such as anonymous usage data, cookies, IP addresses, clickstream data, browser, etc.) to improve the service and for each new feature and function of the same, with the right to verify and monitor preferences, activities and communications and trends of the User for improvement and functional purposes.

In case of an error in the app while the User is using our Service or the app is running in background, WalletSaver will collect data and information (through third party products) on the User's phone called Log Data. This Log Data may include information such as your devices's Internet Protocol ("IP") address, device name, operating system version, configuration of the app when utilising our Service, the time and date of your use of the Service, and other statistics.

Cookies and Other Reporting Services

WalletSaver also uses 'clear GIF' cookies and log file information in order to: (A) verify the effectiveness of promotional campaigns; (B) store the information entered by the User so that they do not need to be repeated; (C) monitor elements such as the total number of visitors, pages viewed, etc.; (D) trace Contents submitted by the User.

Management of User Data

WalletSaver will not give the User's personal details to third parties or personally use the User's personal data, and his/her e-mail address, for the sending of commercial, promotional, advertising or marketing messages without the User's consent, except for messages regarding the functioning of the site or specific programs in relation to which the option to accept or reject will be available.

In any case, WalletSaver will use the User's e-mail, without further consent, for non-commercial or marketing purposes.

User’s rights

In relation to the processing of data, the User can exercise the rights provided for in article 7. of the Code and in the GDPR regarding the protection of personal data at any time. In particular, the interested party has the right to:

  1. Access the user’s personal data and obtain information about them, such as:
  1.  The source of the personal details;
  2.  The purposes and methods of processing;
  3.  The logic applied when data is processed by electronic means;
  4. Any identity information for the subject, for managers or for the designated representative pursuant to Article 5 (2);
  5. The parties or categories of parties to whom the personal data may have been communicated, or who may come into contact with it as appointed representatives in the country in question, as managers or other employees.

  1. and to rectify (modify or ask for modification) them;
  2. Delete her/his personal data;
  3. Withdraw consent to the Privacy Policy and Terms of Service, without affecting the legality of the processing, which was made on the basis of consent prior to its withdrawal by sending request to the following address: dataprotection@walletsaver.com
  4. Fill a complaint to the Authority

The party concerned is entitled to obtain:

a. Updating, amendment or, where required, addition of further details;

b. The deletion, transformation into anonymous form, or blocking of data processed unlawfully, including data that does not need to be retained for the purposes for which it was collected or subsequently processed;

c. Certification that the activities mentioned in (a) and (b) have been notified, including their exact content, to those to whom the data was disclosed, unless this requirement proves impossible or implies manifestly disproportionate measures with respect to the protected right.

The party concerned is entitled to object, in whole or in part:

  1. For legitimate reasons, to the processing of his/her personal data, even if it is pertinent for collection purposes;
  2. To the processing of personal data for the purpose of sending advertising materials, direct sales or for the carrying out of market research or promotional communication".

Providing the personal data is voluntary, but it is a necessary requirement for the conclusion of the contract and to use our services. Without providing your data, WalletSaver will not be able to provide its services.

To exercise the rights provided for by Legislative Decree No. 196/03 article 7, the User must contact dataprotection@walletsaver.com.

External services providers

To facilitate our Service to provide the Service on our behalf, to perform Service-related services, or to assist us in analyzing how our Service is used, we inform the Users of this Service that these third parties may have access to the user's Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.

The main external services providers used are the following:

  1. Facebook - in order to get analytics and login information from the users;
  2. Google - in order to allow an easier login;
  3. Loggly - to track logs from the users which are vital to maintain and improve product stability;
  4. Appsflyer - to get analytics related to downloads and registrations and understand specific in-app actions;
  5. Firebase - to store data and have deeper analytical information to improve our services;
  6. Crashlytics by Fabric - used to track crashes and logs information of the apps installed and websites used and improve the quality of our services;
  7. Amazon Web Services (AWS) - to store and manage data. Our services and also the users’ data are stored in servers in Ireland.

Children’s privacy

We do not knowingly collect, maintain, or use Personal Information from children under 16 years of age, and no part of the Service is directed to children under the age of 16. If you learn that your child has provided us with personal information without your consent, then you may alert us at dataprotection@walletsaver.com. If we learn that we have collected any Personal Information from children under 16, then we will promptly take steps to delete such information.

Links to Other Sites

This Service may contain links to third-party sites. If the User clicks on a third-party link, he/she will be directed to that site. Note that these external sites are not operated by WalletSaver. Therefore, it is strongly advised for the Users to review the Privacy Policy of these websites.

WalletSaver has no control over, and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

How we protect your information

All the communication is done using encrypted secure channel. Each user has access to only it’s own private data (unless explicitly stated otherwise), secured by authentication using password or third-parties trusted authenticators, such as Google and Facebook authentication systems.

All data is stored using major Platform as a Service (PaaS) or Infrastructure as a Service (IaaS) providers, that follows all the best practices in terms of data security.

Contact Us

For further information on privacy, the User may contact:

Data Protection Officer (DPO)

WalletSaver S.r.l

Jacopo Soria

Via Arcivescovo Calabiana 6, 20139 Milan, Italy

dataprotection@walletsaver.com 

We will answer, within maximum 1 month, to any doubts, questions or requests related to data and privacy protection you might have.

The User states that he/she has read, understands, expressly agrees and adheres to the WalletSaver "Privacy Policy".