1.1. Privacy Principles
Proxx has three fundamental principles when it comes to collecting and processing private data:
- We have no access to any data generated by your communications with other Proxx users via Bluetooth Low Energy and we do not have access to mnemonics used to generate your bitcoin address (you have to write it down and keep in a safe place - this can be used in many bitcoin wallets to retrieve your bitcoins when you have any sent to your bitcoin address).
- We don't use your data to show you ads.
- We only store your unique username and associated with this username unique public key so you can restore your Proxx handle in case you lose access to your smartphone. You have to securely store your back up yourself - if you lose it, you will not be able to restore your username or access to bitcoins received to the above mentioned bitcoin address.
- We also store your profile pictures and undelivered via the Internet messages, deleting them from our servers immediately after they get delivered to the recipient.
1.2. Terms of Service
1.3. Table of Contents
- the legal basis for processing your personal data;
- what personal data we may collect from you;
- how we keep your personal data safe;
- what we may use your personal data for;
- who your personal data may be shared with; and
- your rights regarding your personal data.
2. Legal Ground for Processing Your Personal Data
We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protection of personal data.
3. What Personal Data We Use
3.1. Basic Account Data
Proxx is designed to discover and communicate with people around you, without knowing their phone numbers or any other social networks’ IDs. You do not provide your mobile number or email - only basic account data (which may include username, screen name, profile picture and about information) to create a Proxx account.
To make it easier for other people to identify and reach you, the screen name you choose, your profile pictures, and your username (should you choose to set one) on Proxx are always public. We don't want to know your real name, gender, age or what you like.
We do not require your screen name to be your real name.
3.2. Your Email Address
It might be unusual for you, but we do not need your email. Make sure you have a backup in place - this is the only way to restore your account in case you lose access to your smartphone.
3.3. Your Messages
3.3.1. Bluetooth Low Energy (BLE) Chats
Proxx’s main feature is communication with people around you via BLE. When two smartphones with Proxx running are close enough they make a Blind Handshake - exchanging mini profiles, and recording locally time and location of blind handshake. If both devices stay in a certain range (up to 150 ft/50 meters) the users can see each other in Who’s Around tab and send messages to each other via BLE. All data is stored locally on users' devices and we have no access to it.
3.3.2. Internet Chats
Internet chats utilize SSL to encrypt the communication channel between you and our servers. We do not store your chat history on our servers, only undelivered messages. Your messages are removed from our servers as soon as they have been delivered. You can only access those messages from the device they were sent to or from.
3.3.3. Phone Number and Contacts
Proxx does not use phone numbers and contacts.
4. Keeping Your Personal Data Safe
4.1. Storing Data
Your data (undelivered messages, profile pictures, username, screen name and public bitcoin address) is stored in a secure Tier III+ class cloud environment.
5. Processing Your Personal Data
5.1. Our Services
Proxx uses servers and cloud services for chatting via the Internet. We store a very limited amount of information ( undelivered messages ) and will process your data to deliver your undelivered chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage.
5.2. Safety and Security
Proxx supports massive dynamically forming and falling apart communities which we have to police against abuse and Terms of Service violations. Proxx users can make bonds to each other almost with no barriers which makes them a lucrative target for spammers. To improve the security of your account, as well as to prevent spam, abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and Proxx apps you've used, history of username changes, etc. If collected, this metadata can be kept for 12 months maximum.
5.3. Spam and Abuse
To prevent phishing, spam and other kinds of abuse and violations of Proxx’s Terms of Service, our moderators may check messages received via the Internet that were reported to them by their recipients. If a spam report on a message you sent is confirmed by our moderators, account sending out spam or inappropriate content may be limited in functionality temporarily or permanently. We may also use automated algorithms to analyze messages in cloud chats to stop spam and phishing.
5.4. Cross-Device Functionality
You can restore your account with twelve words mnemonics on any iOs device and restore the built-in bitcoin address in many bitcoin wallets.
5.5. Advanced Features
We may use some aggregated data about how you use Proxx to build useful features in the future, but we do not do it now.
5.6. No Ads
Unlike other services, we don't use your data for ad targeting or other commercial purposes. Proxx only stores the information it needs to function.
6. Bitcoin Address
Proxx is not a bitcoin wallet. You can not send, receive and manage your bitcoins with it as you do it with dedicated bitcoin wallet. But you have your own bitcoin address and you can use it as a destination for receiving bitcoins from anyone. Proxx uses the core principle of bitcoin wallets to backup your username and generate associated with it unique bitcoin address. That means, when other Proxx users see your profile they see your receiving bitcoin address and can send you bitcoins. To manage those bitcoins you have to install any bitcoin wallet and choose “restore”, and then enter the twelve words you have written down during Proxx backup process. Proxx has no access to your bitcoin address private keys and never will - that is why it is so important to have a backup.
7. Who Your Personal Data May Be Shared With
7.1. Other Proxx Users
7.2. Law Enforcement Authorities
If Proxx receives a court order that confirms you're a terror suspect, we may disclose your IP address to the relevant authorities.
8. Your Rights Regarding the Personal Data You Provide to Us
8.1. Your Rights
Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data.
8.2. Exercising Your Rights
If you wish to exercise any of these rights, kindly contact us using the details in section 11 below.
9. Deleting data
If you would like to delete your account, you need to log out and wait for twelve month. By default, if you Log out and stop using Proxx and do not come online for at least 12 months, your account will be deleted along with every piece of data you store in the Proxx cloud. Your twelve words mnemonics ( your back up) will be valid forever to restore the bitcoin wallet. But the pair username - bitcoin address will be destroyed and if you decide to restore your Proxx account with the same twelve words in several years it will not work.
11. Questions and Concerns
If you have any questions about privacy and our data policies, please contact us at firstname.lastname@example.org and leave a request, which we will answer at the earliest opportunity.