This Privacy Policy is effective as of: 14 March 2023 (“Effective Date”)

Dulwich Ventures Limited, a company incorporated in the British Virgin Islands (“us”, “we”, or “Safle") is the licensee and publisher of the internet resource www.safle.com, www.getsafle.com and all the associated sub domains (authored by Inblox.me.Inc) of the or any replacement or successor domain name (“Platform” or “Website”) on the world wide web as well as the software and applications thereon, of the brand name “Safle”.

We value your privacy. In this Privacy Policy ("Policy"), we describe the information that we collect about you when you visit our website, https://getsafle.com/ (the "Website") and use the services available on the Website ("Services"), and how we use and disclose that information.

YOU UNDERSTAND THAT BY USING THE SITE OR SITE SERVICES AFTER THE EFFECTIVE DATE, YOU AGREE TO BE BOUND BY THE PRIVACY POLICY. YOU HEREBY CONSENT TO THE COLLECTION, UTILIZATION, SHARING AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT ACCEPT THE PRIVACY POLICY IN ITS ENTIRETY, YOU MUST NOT ACCESS OR USE THE SITE OR THE SITE SERVICES AFTER THE EFFECTIVE DATE.

IF YOU AGREE TO THE PRIVACY POLICY ON BEHALF OF AN ENTITY OR AGENCY, OR IN CONNECTION WITH PROVIDING OR RECEIVING SERVICES ON BEHALF OF AN ENTITY OR AGENCY, YOU REPRESENT AND WARRANT THAT YOU HAVE THE AUTHORITY TO BIND THAT ENTITY OR AGENCY TO THE PRIVACY POLICY AND AGREE THAT YOU ARE BINDING BOTH YOU AND THAT ENTITY OR AGENCY TO THE TERMS OF SERVICE. IN THAT EVENT, “YOU” AND “YOUR” WILL REFER AND APPLY TO YOU AND THAT ENTITY OR AGENCY.

Safle is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:

  1. COLLECTION OF YOUR PERSONAL INFORMATION

    We collect personal information from the individuals who want to register on our website www.getsafle.com. This information is not accessible to the visitors using Safle’s website, either directly or by submitting a request. Individuals are required to create an account to be able to access certain portions of our Website, Individuals, if and when they create and use an account with Safle need to have a “Safle ID” which is unique to every individual registering on the website, they will be required to disclose and provide to Safle information including personal contact details like name and email address. Such information gathered shall be utilized to ensure greater customer satisfaction and help a customer satiate their needs.

    During the Account registration process and during your usage of Safle’s website, we will collect information such as your name and email address only. The information collected will not be shared to any other third party without your consent. During the registration process a Safle ID is allocated to each individual which is chosen by the individual and is unique in nature. A password with 5-16 characters with a mix of uppercase, lowercase, and numbers has to be chosen by you, Safle has backup of these unique passwords but they are completely opaque from the Infrastructure. The employees of Safle also do not have access to these passwords. These unique passwords are completely secure and the same can be proven Technically.

    We also automatically collect certain computer, device and browsing information when you access the website or use Safle Services. This information is aggregated to provide statistical data about our users’ browsing actions and patterns, and does not personally identify individuals. This information may include:

    The above information is collected for ensuring user security and block unusual requests to safeguard users and their funds. For the sake of clarity, we don't use or collect information pertaining to contacts, email or any other application present inside the user's device. The Camera of the user's device is used only for QR scanning, and doesn't save any data inside the application. Also, the Microphone is opaque from the interface.

  2. Safle ID & IT’S USE

    Safle ID signifies a user name registered with our website or portal as a unique identifier for purposes including but not limited to digital identity of users, enablement of transfer of funds and transactions thereof, search and discovery of the user, assertion or confirmation of the user identity in an online environment, enablement of single sign on systems and other activities of decentralization of user data. The Safle IDs are in control with the users only which means Safle can access but cannot modify the information associated with the Safle ID like your wallets or make any transactions with it. Safle IDs cannot be deleted or transferred.

    You can connect your existing wallet to the service at your own risk, with Safle acting as a non-custodial wallet service or you may use the wallet file generated during the registration process for the purpose of pushing the wallet onto the Blockchain. The process is non-custodial in nature, the user always has their wallet private keys with them. Biometric data is locally maintained on OS and is opaque from Safle infrastructure making it completely secure. In case of PIN Based Transaction signing, keys are kept securely in Safle infrastructure using HSMs. Safle cannot end their service of offering wallet connections or allowing external wallets to be connected through their service as the same services are based on smart contracts and thus are immutable.

  3. USE OF COOKIES AND SIMILAR TECHNOLOGY

    The Safle website uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.

    Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and what difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

    We may use one or more third-party Service providers, to assist us in better understanding the use of our Site. Our Service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Site, what products are browsed and general Transaction information. Our Service provider(s) will analyse this information and provide us with aggregate reports. The information and analysis provided by our Service provider(s) will be used to assist us in better understanding our visitors’ interests in our Site and how to better serve those interests. The information collected by our Service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our Service provider(s) is/are contractually restricted from using the information they receive from our Site for any other purpose than to assist us.

    If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of our website or Services, such as logging in to your Safle Account or making Transactions. Your use of our website or Service with a browser that is configured to accept cookies constitutes an acceptance of our and third-party cookies.

  4. HOW SAFLE USES THE INFORMATION WE COLLECT

    Trusting a third party with your private information means that any action you want to perform with your funds should be confirmed by this third party. In this sense, custodial wallets are similar to traditional banks, where transactions might take up to one week because you need to get an approval of every step however small it might be. Conversely, with a non-custodial wallet, you’ll be able to perform instant withdrawals, which makes the process much easier and faster.

    1. How Personal Information Is Used

      We collect your personal information and aggregate information about the use of our Website and Services to better understand your needs and to provide you with a better Website experience. Specifically, we may use your personal information for any of the following reasons:

      • To provide our Services to you, including registering you for our Services, verifying your identity and authority to use our Services, and to otherwise enable you to use our Website and our Services;
      • For customer support and to respond to your inquiries;
      • For internal record-keeping purposes;
      • To process billing and payment, including sharing with third party payment gateways in connection with Website and/or Safle's products and Services;
      • To improve and maintain our Website and our Services (for example, we track information entered through the "Search" function; this helps us determine which areas of our Website users like best and areas that we may want to enhance; we also will use for trouble-shooting purposes, where applicable);
      • To periodically send promotional emails to the email address you provide regarding new products from Safle, special offers from Safle or other information about Safle that we think you may find interesting;
      • To contact you via email, telephone, facsimile or mail, or, where requested, by text message, to deliver certain services or information you have requested;
      • For Safle's market research purposes, including, but not limited to, the customization of the Website according to your interests;
      • We may use your demographic information (i.e., age, postal code, residential and commercial addresses, and other various data) to more effectively facilitate the promotion of goods and services to appropriate target audiences and for other research and analytical purposes;
      • To resolve disputes, to protect ourselves and other users of our Website and Services, and to enforce our Terms of Use;
      • We also may compare personal information collected through the Website and Services to verify its accuracy with personal information collected from third parties; and
      • We may combine aggregate data with the personal information we collect about you.
      • From time to time, Safle may use personal information for new and unanticipated uses not previously disclosed in our Privacy Policy. If our information practices change regarding information previously collected, Safle shall make reasonable efforts to provide notice and obtain consent of any such uses as may be required by law.
    2. Blockchain Transactions

      • Your blockchain transactions may be relayed through servers (“nodes”) and will be publicly visible due to the public nature of distributed ledger systems.
    3. Communication with Third-Party Servers

      • Exchange rates, balances, transactions and other blockchain information may be read from or relayed to, third-party servers. We cannot guarantee the privacy of your Internet connection.
    4. Aggregate Usage Statistics

      • We may collect Safle services usage information in order to improve function or UI, but will only use this information in an aggregated, anonymized fashion, and never in association with your name, email, or other personally identifying information.
  5. SECURITY

    We retain information we collect as long as it is necessary and relevant to fulfil the purposes outlined in this policy. In addition, we retain personal information to comply with applicable law where required, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our terms of use, and other actions permitted by law.

    To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

    We employ procedural and technological security measures, which are reasonably designed to help protect your personal information from unauthorized access or disclosure. Safle may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% complete. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or private communications will not be collected and used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. Safle is not responsible for the unauthorized use of your information or for any lost, stolen, compromised passwords, or for any activity on your Account via unauthorized password activity.

  6. DISCLOSURE

    We may share the information that we collect about you, including your personal information, as follows:

    1. Information Disclosed to Protect Us and Others

      We may disclose your information including Personal Information if: (i) Safle reasonably believes that disclosure is necessary in order to comply with a legal process (such as a court order, search warrant, etc.) or other legal requirement of any governmental authority, (ii) disclosure would potentially mitigate our liability in an actual or potential lawsuit, (iii) reasonably necessary to enforce this Privacy Policy, our Terms of Use etc. (iv) disclosure is intended to help investigate or prevent unauthorized transactions or other illegal activities, or (v) necessary or appropriate to protect our rights or property, or the rights or property of any person or entity.

    2. Information Disclosed to Third Party Service Providers and Business Partners

      We may contract with various third parties for the provision and maintenance of the Website, Services and our business operations, and Safle may need to share your personal information and data generated by cookies and aggregate information (collectively, "information") with these vendors and service agencies. The vendors and service agencies will not receive any right to use your personal information beyond what is necessary to perform its obligations to provide the Services to you. If you complete a survey, we also may share your information with the survey provider; if we offer a survey in conjunction with another entity, we also will disclose the results to that entity.

    3. Disclosure to Non-Affiliated Third Parties in Furtherance of Your Request

      Your request for services may be shared with third party websites with whom we have a contractual relationship in order to provide your request with maximum exposure. The post on the third party website will include the details of your request, including your location, and other contact details. Interested bidders, however, will be able to click on your request on such third party site, and will be directed to our Website where they will have access to your contact details (Partial or complete), as would any other service provider on our Website interested in bidding on your request.

    4. Links to External Websites

      The Website may contain links to other websites or resources over which Safle does not have any control. Such links do not constitute an endorsement by Safle of those external websites. You acknowledge that Safle is providing these links to you only as a convenience, and further agree that Safle is not responsible for the content of such external websites. We are not responsible for the protection and privacy of any information which you provide while visiting such external websites and such sites are not governed by this Policy. Your use of any external website is subject to the terms of use and privacy policy located on the linked to external website.

  7. WHAT CHOICES DO I HAVE REGARDING USE OF MY PERSONAL INFORMATION?

    We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send.