Privacy Policy
Effective [date] · Version 0.1
This policy describes how Coined Investment Pool Company AB processes personal data when you use the CiP app and the services behind it.
1. Controller
2. What we process
| Data | Why | Legal basis |
|---|---|---|
| First name, last name, phone number and any email address | Create and recover your account, verify that the number is yours, show your name to people you pay | Contract |
| Verification codes and times of sign-in attempts, IP address and browser/app information at sign-in | Secure sign-in, abuse prevention and troubleshooting | Legitimate interest (security) |
| User ID and the public part of the app's key | Identify your account and check that transfers are signed by you | Contract |
| Transactions: amount, sender, recipient, time and any message | Carry out and prove payments | Contract; legal obligation [confirm, e.g. bookkeeping/AML] |
| Phone numbers you look up when paying someone | Find the right recipient. Used only for the lookup. | Contract |
| Push token, phone type (iOS/Android/web), language, app version and whether notifications are allowed | Send notifications, e.g. when you receive a payment, and provide support | Contract; legitimate interest (support) |
| Messages to us (email) | Answer questions | Legitimate interest |
The camera is used only to read QR codes in the app. Images are processed on your phone and are not sent to us. We do not use advertising or tracking tools in the app.
3. The ledger
Payments are recorded on the CiP ledger, which runs on several servers (nodes) that together confirm each transfer. The ledger holds your user ID, your public key and your transactions, but not your name, phone number or email. Those are kept only in our administrative system.
Ledger transactions are designed so that they cannot be changed or deleted afterwards. This means we cannot delete a completed transaction, even if we delete your contact details. [Describe how this relates to the right to erasure.]
4. Where data is stored and who we share it with
We never sell personal data. We use the following providers (processors):
- Amazon Web Services: the administrative system and database (Stockholm), SMS verification codes and the ledger nodes (within the EU and the UK).
- Google Firebase Cloud Messaging: push notification delivery. Google may process data outside the EU/EEA; transfers rely on the European Commission's standard contractual clauses [confirm].
- Apple and Google: delivery of notifications to your phone through their push services.
- Cloudflare: hosting of the web version of the app and of this website.
Price data for valuing the collateral comes from an external source. No personal data is sent there.
Someone who receives a payment from you sees your name and the amount. If authorities request data under the law, we may have to disclose it.
5. How long we keep data
- Account details: as long as you have an account, and then [X months/years].
- Sign-in attempts, IP addresses and verification history: [X months].
- Push token and phone information: until you sign out on the phone or delete the account.
- Transactions: permanently on the ledger (see section 3). Data required by law is kept as long as the law requires [e.g. 7 years under the Swedish Bookkeeping Act].
6. Your rights
You have the right to access, rectify and erase your personal data, to restrict or object to certain processing and to receive data you gave us in a machine-readable format (data portability). Contact info@cip.se. We reply within one month.
You can turn off notifications in your phone's settings at any time, and remove the app from your phone under Settings → Remove from this device.
If you are unhappy with how we process your data, you can complain to the Swedish Authority for Privacy Protection (IMY), www.imy.se.
7. Security
The app's private key is created and stored in the phone's secure storage and never leaves the phone. Communication is encrypted, and each transfer is signed by your phone and confirmed by several independent nodes.
8. Changes
We may update this policy. We announce material changes in the app. Earlier versions are available on request.