• “Cookies”. Cookies are files with small amount of data which may include an anonymous
    unique identifier. Cookies are sent to your browser from a website and stored on your device.
    You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.
    For more information about cookies, and how to disable cookies, visit
    http://www.allaboutcookies.org.
    Two types of cookies may be used on the Website - "session cookies" and "persistent cookies".
    Session cookies are temporary cookies that remain on your device until you leave the
    Services. A persistent cookie remains on your device for much longer or until you manually
    delete it (how long the cookie remains on your device will depend on the duration or "lifetime"
    of the specific cookie and your browser settings).
    We collect “Necessary Cookies” and “Performance Cookies” which do not identify you as an
    individual.
    If you do not agree to our use of Cookies, you should set your browser settings accordingly
    or not use our Services. By continuing to use our Services without changing your settings,
    you are agreeing to our use of Cookies and the terms with regard to Cookies of this Privacy
    Policy.
  • “Log files”. Log files track actions occurring in the Services, and collect data including your IP
    address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you
    browse the Services.
  • “Google Analytics”. Google Analytics is a web analytics service offered by Google Inc. that
    tracks and reports website traffic (such as navigation path, length of stay, returning or new
    user, end device). Google uses the data collected to track and monitor the use of our Services.
    This data is shared with other Google services. Google may use the collected data to
    contextualize and personalize the ads of its own advertising network. We do not use the
    information and personal data collected by Google Analytics to identify individuals unless we
    become aware of specific indications of illegal use. For more information on the privacy practices
    of Google, please visit the Google Privacy Terms web page:
    http://www.google.com/intl/en/policies/privacy/. We also encourage you to review the
    Google's policy for safeguarding your data:
    https://support.google.com/analytics/answer/6004245. You can also opt-out of Google
    Analytics here: https://tools.google.com/dlpage/gaoptout. By continuing to use our Services
    without opting out to Google Analytics, you are agreeing to the collection of data by Google
    Analytics.
  • “Firebase”. Firebase is analytics service for mobile applications, provided by Google Inc. You
    may opt-out of certain Firebase features by following the instructions provided by Google in
    their Privacy Policy: http://www.google.com/intl/en/policies/privacy/. For more information
    on what type of information Firebase collects, please visit the Google Privacy Terms web
    page: http://www.google.com/intl/en/policies/privacy/.
    PURPOSE OF THE COLLECTION OF PERSONAL DATA
    Tangem uses the Personal Data you provided to us for the following purposes:
  • To fulfill and deliver any purchase orders placed through the Services;
  • To screen the purchase orders for potential risk or fraud;
  • To deliver our products and / or provide the Services;
  • To allow you to participate in interactive features of our Services when you choose to do so;
  • To provide customer support;
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  • To process invoices payments and transaction history;
  • To manage unpaid bills and claims;
  • To provide you with news, special offers and general information about other goods, services
    and events which we offer that are similar to those that you have already purchased or
    enquired about unless you have opted not to receive such information.
    Tangem uses the Personal Data collected automatically like Device Information and Tracking
    Cookies Data for the following purposes:
  • To enable the use of our Services;
  • To gather analysis or valuable information so that we can improve our Services and offer you
    more enjoyable and efficient experience;
  • To monitor the usage of our Services;
  • To detect, prevent and address technical issues;
  • For internal statistical purposes.
    LEGAL BASIS FOR PROCESSING PERSONAL DATA UNDER GENERAL DATA PROTECTION
    REGULATION (GDPR)
    Tangem’s legal basis according to the GDPR for collecting and using the personal Data
    described in this Privacy Policy depends on the Personal Data we collect and the specific
    context in which we collect it.
    Tangem may process your Personal Data because:
     We need to perform a contract with you (fulfillment of an agreement in accordance
    with Art. 6 Par. 1 lit. b of GDPR),
     You have given us permission to do so (consent in accordance with Art. 6 Par. 1 lit. a
    of GDPR),
     The processing is in our legitimate interests and is not overridden by your rights
    (legitimate interest in the processing of Data in the sense of Art. 6 Par. 1 lit. f. of
    GDPR),
     It is required to comply with a legal obligation (Art. 6 Par. 1 lit. c of GDPR).
    RETENTION OF DATA
    The retention period of Personal Data processed by Tangem may vary depending on common
    practice, and considered in accordance with the legal obligations and the applicable limitation
    rules. In any way, Tangem will process and store the Personal Data only for the period
    necessary to achieve the purpose of storage or as far as this is granted by the applicable laws
    or regulations.
    If the storage purpose is not applicable anymore, or if the storage period prescribed by the
    applicable laws and regulations expires, the Personal Data is routinely erased in accordance
    with legal requirements.
    TRANSFER OF DATA
    Your data, including Personal Data, may be transferred to — and maintained on — computers
    located outside of your state, province, country or other governmental jurisdiction where the
    data protection laws may differ than those from your jurisdiction.
    Your consent to this Privacy Policy followed by your submission of such information represents
    your agreement to that transfer.
    Tangem will take all steps reasonably necessary to ensure that your data is treated securely
    and in accordance with this Privacy Policy and no transfer of your Personal Data will take place
    5
    to an organization or a country unless there are adequate controls in place including the
    security of your data and other personal information.
    DATA DISCLOSURE
    We do not sell, lease, rent, or otherwise disclose your Personal Data to third parties except to the
    technical and logistic service provider of our Website and to suppliers, who are contractually bound
    to confidentiality, such as outsourcing service providers, logistics, storage providers, marketing
    and communication providers. When we do so we take steps to ensure they meet our data security
    standards, so that your Personal Data remains secure.
    Tangem may further disclose your Personal Data in the good faith belief that such action is
    necessary to:
     To comply with a legal obligation;
     To protect and defend the rights or property of Tangem;
     To prevent or investigate possible wrongdoing in connection with the Services;
     To protect the personal safety of users of the Services or the public;
     To protect against legal liability.
    The transfer of data is for purpose of providing and maintaining the functionality of our
    Website. This is our legitimate interest in the sense of Art. 6 Par.1 lit. b and lit f of GDPR.
    If you pay by credit card through the website, we forward your credit card information to the
    credit card issuer and the credit card acquirer. If you choose to pay by credit card, you will
    be asked to provide all the necessary information. The legal basis for passing on the data lies
    in the fulfilment of an agreement in the sense of Art. 6 Par. Lit. b GDPR.
    We transmit your Personal Data only to such our employees who are authorized to process
    them as part of their duties.
    All Personal Data used by these third parties is solely used for the purposes of the services
    provided at your request. Any use for other purposes is strictly prohibited. In addition, any
    Personal Data processed by third parties will be in accordance with the terms of this Privacy
    Policy and in compliance with the GDPR and any other applicable laws and regulations. The
    third party providers we use will only collect and use your information to the extent necessary
    to enable them to perform the services they provide to us.
    If the level of data protection in a country where a service provider is located does not
    correspond to the European data protection level, we contractually ensure that the protection
    of your personal data corresponds to that in the EU at all times by concluding agreements
    using the standard contractual clauses complying with the GDPR.
    SECURITY OF DATA
    The security of your data is important to us, but remember that no method of transmission
    over the Internet, or method of electronic storage is 100% secure. While we guarantee to use
    commercially acceptable means to protect your Personal Data in accordance with the GDPR
    and other applicable laws and regulations, we cannot guarantee the absolute security and
    accept no liability of the transmission of your Personal Data through our Services.
    We also periodically review and adjust security safeguards as the threat landscape evolves.
    Ultimately no security system is impenetrable, and we cannot guarantee the security of our
    systems 100%. In the event that any information under our control is compromised as a
    result of a breach of security, our policy is to take reasonable steps to investigate the situation
    and, where appropriate, communicate with affected individuals.
    SERVICE PROVIDERS
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    We may engage the below mentioned Partner Service providers to facilitate our Services, to
    provide the Services on our behalf, to perform Services’ related services or to assist us in
    analyzing how our Service is used.
    These Partner Services have access to your Personal Data only to perform these tasks on our
    behalf and are obligated not to disclose or use it for any other purpose.
    We use Moonpay to provide you with the on-ramp and off-ramp services - you can read
    more about how Moonpay uses your Personal Data here: https://www.moonpay.com/
    privacy_policy.
    You can read more about how Google uses your Personal Data here:
    https://www.google.com/intl/en/policies/privacy/.
    As described above, we use your Personal Data to provide you with targeted advertisements or
    marketing communications we believe may be of interest to you. For more information about how
    targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational
    page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.
    You can opt out of targeted advertising by using the links below:
  • Facebook: https://www.facebook.com/settings/?tab=ads
  • Google: https://www.google.com/settings/ads/anonymous
    Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s
    opt-out portal at: http://optout.aboutads.info/.
    By continuing to use our Services without opting out as described above, you are agreeing to the
    collection of data by the mentioned Partner Service providers.
    DO NOT TRACK
    Please note that we do not alter our Service’s data collection and use practices when we see a Do
    Not Track (“DNT”) signal from your browser.
    Our third party partners, such as web analytics companies, may collect information about you and
    your online activities over time and across our Services and other online properties. These third
    parties may not change their tracking practices in response to DNT settings in your web browser
    and we do not obligate these parties to honor DNT settings.
    YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION
    (GDPR)
    Depending on your jurisdiction you may have certain data protection rights. Tangem aims to take
    reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.
    If you wish to be informed what Personal Data we hold about you and if you want it to be removed
    from our systems, please contact the Responsible Person as stated in this Privacy Policy.
    In certain circumstances, you have the following data protection rights:
     The right to access, update or to delete the information we have on you. If you would like
    to exercise this right, please contact us through the contact information below.
     The right of rectification. You have the right to have your information rectified if that
    information is inaccurate or incomplete.
     The right to object. You have the right to object to our processing of your Personal Data.
     The right of restriction. You have the right to request that we restrict the processing of
    your Personal Data.
     The right to data portability. You have the right to be provided with a copy of the
    information we have on you in a structured, machine-readable and commonly used format.
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     The right to withdraw consent. You also have the right to withdraw your consent at any
    time where Tangem relied on your consent to process your Personal Data. Please note that
    we may ask you to verify your identity before responding to such requests.
     You have the right to complain to a Data Protection Authority about our collection and use
    of your Personal Data.
    CUSTOMERS FROM CALIFORNIA
    California law provides California customers with specific rights with regard to the collection, sale,
    and disclosure of their Personal Data. If you are a California resident, you have the following rights:
     The right to request that we delete any Personal Data about you which we have collected from
    you. Nevertheless, we will not be required to comply with your request to delete your Personal
    Data if it is necessary for us to maintain your Personal Data for the reasons provided under
    California Civil Code Section 1798.105(d).
     The right to request that we disclose to you the following:
    (1) The categories of Personal Data we have collected about you;
    (2) The categories of sources from which your Personal Data is collected;
    (3) The business or commercial purpose for collecting or selling your Personal Data;
    (4) The categories of third parties with whom the business shares your Personal Data; and
    (5) The specific pieces of Personal Data we have collected about you.
     The right not to be discriminated against because you have exercised any of your rights under
    the CCPA.
    We do not sell your Personal Data or collect data to facilitate or enable third parties to advertise
    to you.
    LINKS
    The activation of certain links in the Services may cause you to leave the Services. Tangem does
    not review any of these linked websites and does not warrant or guarantee, either expressly or
    implicitly, the quality, pertinence, accuracy, completeness, update status, availability or legality of
    the content of these sites, nor will it be in any way responsible for the products, services,
    information and other content offered via these linked sites or the processing of your Personal
    Data through these websites. The same applies to websites offering links to the Services.
    Furthermore, prior written approval must always be obtained before a link from an external
    website or mobile application to Services can be created. We advise you to read the privacy policy
    applicable to such other websites before using them.
    MINORS
    You must be at least eighteen (18) years of age to register with and use the Services. This Service
    is not directed to children under 18. We do not intend to collect Personal Data from children under
    18.
    CONTACT US
    For more information about our privacy practices, if you have questions, or if you would like to
    make a complaint, please contact us by e‑mail at store@tangem.com or by mail using the details
    provided below:
    Tangem AG
    Re: Privacy Compliance
    Baarerstrasse 10, Zug CH-6300, Switzerland
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    CHANGES TO THE PRIVACY POLICY
    From time to time we may change this Privacy Policy in order to reflect, for example, changes
    to our practices or for other operational, legal or regulatory reasons. You can tell when changes
    have been made to the Privacy Policy by referring to the “Last Updated” legend at the top of
    this page. If we materially change the ways in which we use and disclose personal data, we
    will post a notice in the Services and send an email to our registered users. Your continued
    use of the Services following any changes to this Privacy Policy constitutes your acceptance
    of any such changes made.
    LAST UPDATED: [June 27, 2022]