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

Last Updated: 07.09.2021

This Privacy Policy describes the policies and procedures of Anastasis
SARL (“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”). 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 Anastasis. 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@anastasis.lu.


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 Anastasis
users.  The detailed Personal Information Anastasis asks from you
during the regular backup and recovery process at the beginning is
never shared with us and only used to create a cryptographic account
identifier which does not allow us to recover any of your details.

That being said, when using our Services to recover key material, we
may inherently receive the following information (depending on your
choice of authentication method):

   * Bank account details necessary when receiving funds from you to
     authenticate via a SEPA transfer. We will store these as part of
     our business records for accounting, and our bank will also be
     legally obliged to store the details for many years.

   * Your phone number when using SMS authentication. We rely on third
     party providers (such as your mobile network operator) to deliver
     the SMS to you. These third parties will see the SMS message sent
     to you and could thus learn that you are using Anastasis. SMS is
     inherently insecure, and you should expect many governments and
     private parties to be able to observe these messages.  However,
     we do not store your SMS number on our systems, except maybe in
     short-term logs to diagnose errors.

   * Your e-mail address when using E-mail authentication. We rely on
     the Internet and your E-mail provider to deliver the E-mail to
     you. Internet service providers will see the E-mail message sent
     to you and could thus learn that you are using Anastasis. E-mail
     is inherently insecure, and you should expect many governments
     and private parties to be able to observe these messages.
     However, we do not store your E-mail address on our systems,
     except maybe in short-term logs to diagnose errors.

   * Your physical address when using postal mail authentication. We
     rely on external providers for printing and sending the letter to
     you. These providers will need to learn your address and could
     learn that you are using Anastasis. Physical mail has strict
     privacy protections by law, but governments are known to break
     postal secrecy. We do not store your physical address on our
     systems, except maybe in short-term logs to diagnose errors.

   * 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 authenticate you during secret recovery

   * to support you using Anastasis when you contact us


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

We may share your authentication data with other providers that assist
us in performing the authentication. We will try to use providers that
to the best of our knowledge respect your privacy and have good
privacy practices.  We reserve the right to change authentication
providers at any time to ensure availability of our services.

We primarily use the limited information we receive directly from you
to enhance Anastasis. 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 Anastasis application 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. By accepting
this Privacy Policy, as outlined above, you consent to any such
transfer.


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@anastasis.lu. 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.


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

Information entered into our bug tracker will be retained indefinitely
and is typically made public. We will only use it to triage the
problem.  Beyond that, we do not retain personally identifiable
information about our users for longer than one week.


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 top 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, Anastasis clients may inform you
about a change in the privacy policy once they detect 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 (currently) hosted in Germany. If you are a user
accessing the Services from the Switzerland, Asia, US, or any other
region with laws or regulations governing personal data collection,
use, and disclosure that differ from the laws of Germany, please be
advised that through your continued use of the Services, which is
governed by the law of the country hosting the service, you are
transferring your Personal Information to Germany and you consent to
that transfer.


Questions
=========

Please contact us at privacy@anastasis.lu if you have questions about
our privacy practices that are not addressed in this Privacy
Statement.
