Privacy Policy

WIFICOIN INC. - Protecting Your Data in the Decentralized Web

Last updated: December 2024

Introduction

WIFICOM INC.. (SIRET: 92029208300028) is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, process, and protect your data when you use our decentralized WiFi sharing network.

As a blockchain-based service operating under French and European law, we adhere to the General Data Protection Regulation (GDPR) and other applicable privacy regulations.

1. Data Controller Information

Data Controller: WIFICOM INC.

SIRET Number: 92029208300028

Registered Address: 35 RUE P ET D PONCHARDIER ESPACE FAURIEL, 42000 SAINT-ETIENNE France

Contact: privacy@wificoin.app

Data Protection Officer: dpo@wificoin.app

2. Data We Collect

2.1 Personal Information

  • Wallet Addresses: Public blockchain addresses for payments
  • Device Information: Device type, operating system, MAC addresses (hashed)
  • Location Data: Approximate location for hotspot discovery (anonymized)
  • Usage Statistics: Data consumption, connection duration (aggregated)
  • Network Identifiers: WiFi SSID, network capabilities

2.2 Technical Data

  • Blockchain Transactions: All payment and usage data on public ledger
  • Smart Contract Interactions: Automated contract executions
  • Network Performance: Bandwidth, latency, connection quality metrics
  • Security Events: Failed authentication attempts, suspicious activities

2.3 Data We Do NOT Collect

  • Personal browsing history or internet traffic content
  • Passwords or private keys (stored locally on your device)
  • Personal communications or messages
  • Precise location data (only general area for hotspot matching)
  • Real names or government identification

3. Legal Basis for Processing

Under GDPR Article 6, we process your data based on:

  • Contractual Necessity: To provide WiFi sharing services
  • Legitimate Interests: Network security, fraud prevention, service improvement
  • Consent: For optional features like location-based services
  • Legal Obligation: Compliance with telecommunications and financial regulations

4. How We Use Your Data

4.1 Service Provision

  • Facilitate WiFi connections between sharers and consumers
  • Process micropayments via blockchain smart contracts
  • Maintain network quality and performance
  • Provide customer support and troubleshooting

4.2 Security and Compliance

  • Detect and prevent fraudulent activities
  • Monitor network for security threats
  • Comply with regulatory requirements
  • Enforce terms of service

4.3 Service Improvement

  • Analyze usage patterns to improve network efficiency
  • Develop new features and services
  • Optimize pricing and incentive mechanisms
  • Enhance user experience and interface

5. Blockchain and Decentralization

5.1 Public Ledger Considerations

Our service uses blockchain technology, which means:

  • Transaction data is permanently recorded on public blockchain
  • Wallet addresses are pseudonymous but publicly visible
  • Smart contract interactions cannot be deleted from blockchain
  • We cannot modify or delete blockchain records

5.2 Privacy-Preserving Technologies

  • Zero-Knowledge Proofs: Verify usage without revealing details
  • Data Hashing: Personal identifiers are cryptographically hashed
  • Decentralized Identity: You control your identity and data
  • Minimal Data Storage: Only essential data stored off-chain

6. Data Sharing and Disclosure

We may share your data in limited circumstances:

6.1 Service Providers

  • Blockchain infrastructure providers (nodes, validators)
  • Cloud hosting services for application infrastructure
  • Security monitoring and analytics services
  • Customer support platforms

6.2 Legal Requirements

  • Court orders or legal processes
  • Regulatory investigations
  • Law enforcement requests (when legally required)
  • Protection of our rights and property

6.3 Network Participants

  • Aggregated, anonymized usage statistics for network optimization
  • Hotspot availability and performance metrics
  • Network health and security indicators

7. Data Security

We implement comprehensive security measures:

7.1 Technical Safeguards

  • Encryption: TLS 1.3 for data in transit, AES-256 for data at rest
  • Network Security: WPA3, VLANs, firewall protection
  • Access Controls: Multi-factor authentication, role-based access
  • Monitoring: 24/7 security monitoring and intrusion detection

7.2 Organizational Measures

  • Regular security audits and penetration testing
  • Employee training on data protection
  • Incident response procedures
  • Data breach notification protocols

8. Your Privacy Rights

Under GDPR, you have the following rights:

8.1 Individual Rights

  • Right of Access: Request copies of your personal data
  • Right to Rectification: Correct inaccurate personal data
  • Right to Erasure: Request deletion of your data (subject to blockchain limitations)
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a portable format
  • Right to Object: Object to processing based on legitimate interests

8.2 Blockchain Limitations

Due to the immutable nature of blockchain technology, some rights may be limited:

  • Blockchain transactions cannot be deleted or modified
  • We can only control off-chain personal data
  • Wallet addresses remain on public ledger permanently
  • Smart contract data cannot be erased from blockchain

8.3 Exercising Your Rights

To exercise your privacy rights, contact us at: privacy@wificoin.app

9. Data Retention

  • Account Data: Retained while account is active plus 2 years
  • Transaction Records: Permanent on blockchain, 7 years off-chain
  • Usage Analytics: Aggregated data retained indefinitely, personal data 1 year
  • Security Logs: Retained for 3 years for security and compliance
  • Support Communications: Retained for 3 years

10. International Data Transfers

As a decentralized network, data may be processed globally:

  • Blockchain nodes operate worldwide
  • Cloud infrastructure may span multiple jurisdictions
  • Transfers are protected by appropriate safeguards
  • We comply with GDPR transfer requirements

11. Policy Updates

We may update this Privacy Policy to reflect:

  • Changes in our services or technology
  • Updates to legal requirements
  • Improvements to our privacy practices
  • User feedback and requirements

We will notify users of significant changes via email or in-app notifications.

12. Contact Us

For privacy-related questions or concerns:

Privacy Officer: WIFICOM INC..

Email: privacy@wificoin.app

DPO: dpo@wificoin.app

SIRET: 92029208300028

Supervisory Authority: Commission Nationale de l'Informatique et des Libertés (CNIL)

This Privacy Policy is effective as of December 2024 and applies to all users of the WIFICOIN decentralized WiFi sharing network. Your continued use of our services indicates acceptance of this policy.

Follow on Twitter
Follow on LinkedIn