Privacy Policy
Version 20240321
SEMILLA3 LLC, EIN: 35-2834903, address 2093 Philadelphia Pike #7574, Claymont, DE 19703, New Castle County, Delaware (USA) (hereinafter “Cuvex”) processes personal data of individuals who use the information society service cuvex.io (cuvex.io and its subdomains, including but not limited to store.cuvex.io, hereinafter referred to as cuvex.io).
1. GENERAL PROVISIONS
- 1.1 Cuvex ensures that the processing of personal data is in accordance with the legislation regarding the protection and security of personal data (including the General Data Protection Regulation of the European Union, hereinafter “GDPR”), other personal data protection legislation, and good business practices.
- 1.2 Cuvex considers the privacy of individuals and the protection of their data important and makes best efforts to ensure the security and protection of the information system and other data carriers.
- 1.3 Please note that cuvex.io is used in different countries. Personal data processing conditions may differ from country to country, and the corresponding data processing notice can be found on localised versions of cuvex.io.
2. DEFINITIONS
- 2.1 User means a person who uses the E-commerce Store or the Cuvex App.
- 2.2 Processing of personal data means viewing, collecting, saving, storing, altering, transmitting, or receiving personal data and other activities related to personal data.
- 2.3 Cuvex Device means a cold encryption device, without internet connection and multi-signature with which you can encrypt your seeds, private keys or any secret and record them on an NFC card.
- 2.4 E-commerce Store means the website https://cuvex.io/
- 2.5 Cuvex App means the mobile application developed and provided by Cuvex, find more information at https://cuvex.io/pages/cuvex-app
- 2.6. Services means the services available via the Cuvex App: updating the Cuvex device firmware, the Watch Only Service, and the Balance Alerts Service, find more information at https://cuvex.io/pages/cuvex-app
3. PURPOSE OF THE PROCESSING OF PERSONAL DATA AND ITS LEGAL BASIS
- 3.1 Cuvex processes personal data necessary for (i) managing orders and payments made on the E-commerce store when purchasing the Cuvex Device (ii) managing payments made on the Cuvex App when using the Balance Alerts Service (iii) updating the Cuvex Device firmware (iv) using the features available on the E-commerce Store. No personal data is being processed by Cuvex if the User is using the Watch Only Service.
- 3.2 In general, the legal basis for such a purpose is carried out in accordance with Article 6(1)(b) of the GDPR. Such processing is necessary for the performance of a contract to which the User is a party or in order to take such steps at the specific request of the User prior to entering into a contract. Sometimes the processing of data is necessary for legitimate interests under Article 6(1)(f) of the GDPR provided those interests are not outweighed by the Users’ rights and interests.
- 3.3 Cuvex is operating an E-commerce Store which provides several functions for data processing activities.
![](https://cdn.shopify.com/s/files/1/0730/2863/2918/files/20231017_legal_privacy_policy.webp?v=1719898943%0A)
- 3.4 Read more about the privacy and security implementations and good practices of Cuvex on the website https://www.cuvex.io/privacy-security
4. TRANSMISSION OF THE PERSONAL DATA
- 4.1 Cuvex processes personal data in the United States Of America and European Union (EU) and within the European Economic Area (EEA). Cuvex receives, transmits, and processes personal data only digitally. If Cuvex transfers data outside of the EEA, it undertakes to use enter into SCC with the service providers or use service providers that have adhered to the US DPF.
5. DISCLOSURE OF PERSONAL DATA
- 5.1 We integrate third-party services, which may collect various personal data both directly from you and indirectly from the third parties by acting strictly in accordance with all applicable laws and regulations, and the goals of personal data collection.
- 5.2 Infrastructure service providers:
![](https://cdn.shopify.com/s/files/1/0730/2863/2918/files/20231017_LEGAL_2_privacy_policy.webp?v=1719898963)
6. RETENTION AND DELETION OF PERSONAL DATA
- 6.1 The storage period of personal data depends on the legal obligations to store data (i.e. accounting regulations), contractual obligations, and legitimate interest or consent to provide the best services.
![](https://cdn.shopify.com/s/files/1/0730/2863/2918/files/20231017_LEGAL_3_privacy_policy.webp?v=1719898957)
7. RIGHTS OF THE USER (DATA SUBJECT)
- 7.1 The User (data subject) shall have the right at any time to request:
- 7.1.1 access to personal data;
- 7.1.2 correction of inaccurate personal data;
- 7.1.3 require the deletion of personal data;
- 7.1.4 restriction of processing of personal data;
- 7.1.5 transfer personal data to the controller designated by the User;
- 7.1.6 withdrawal of data-processing consent.
- 7.2 In order to exercise these rights, the User must submit a declaration to team@cuvex.io. The application shall be responded to within a maximum of 30 calendar days.
- 7.3 The User has the right to lodge a complaint against the processing of personal data with the supervisory authority.
8. CHANGES AND VALIDITY
- 8.1 Cuvex has the right to change the conditions for processing personal data. In the event, that there are substantial changes, Cuvex will provide at least 1 (one) month’s notice in advance through the E-commerce Store before the substantial changes take effect.
- 8.2 The conditions for processing personal data are valid from march 21, 2024.