TanglePay Privacy Policy

Last Updated: Oct 25, 2021.

Dear Users,

TANGLEPAY FOUNDATION PTE. LTD. (“TPF” or “we”) respects and protects the privacy of Users (“you” or “Users”). TPF will collect and use your Personal Information, generated from your use of TanglePay in accordance with this Privacy Policy (“Policy”).

TPF recommends that you shall carefully read and understand the whole contents of this Policy before your use of the product (“TanglePay”). Additionally, significant information including the Disclaimer is in bold form in this Policy. Definitions of key words in this Policy are consistent with those in the TanglePay Terms of Service of TPF.

TPF reserves the right to update this Policy online from time to time, and the new policy will immediately replace the older one once posted. In particular, if you do not accept the revised policies, please immediately stop your use of TanglePay. Your continuous use of TanglePay will be regarded as your acceptance of the revised policy. Furthermore, the revised policies will take into effect immediately upon being posted on TanglePay.

You acknowledge and accept that this Policy and other relevant rules apply to TanglePay and the DApps owned by TPF on TanglePay.

Information We Collect

We collect your information in order to provide the services you requested on TanglePay, and we highly value the protection for your privacy. We strictly abide by the principle of “lawful, justifiable and necessary” during our collection of your information. You acknowledge that, if you do not provide us with necessary information, your user experiences on TanglePay may be influenced.

1.1 You confirm that your Wallet Password, Private Key, Mnemonic Words, Keystore on TanglePay (the decentralized solution) are not stored or synchronized on TPF’ servers. TPF does not offer the service to restore your Wallet Password, Private Key, Mnemonic Words or Keystore.

1.2 Apart from the foregoing provisions, when you are using specific function of TanglePay, we may give you special notification to ask for more Personal Information.

1.3 After you link to the third-party-developed DApps from TanglePay, your Personal Information will be collected and held by the third-party-developed DApps instead of being collected or held by TanglePay. When you fill in your Personal Information on a third-party-developed DApp, you should pay attention to the Terms of Use and Privacy Policy of the third-party-developed DApp. We are not accountable for any losses caused by your operation on the third-party-developed DApp.

1.4 To the extent permitted by laws and regulations, TPF may collect and use following Personal Information without your prior consent or authorization:

a. information related to national security and national defense;

b. information related to public security, public health, significant public interests;

c. information related to criminal investigation, prosecution, trial and enforcement;

d. the Personal Information collected is publicized by yourself;

e. the Personal Information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

f. the Personal Information is necessary to maintain the security and compliance of services, such as to detect or to solve the malfunction of products and services;

g. other circumstances prescribed by laws and regulations. We collect information in the following way,

1). we collect information during your use of TanglePay, including your mobile devices information and your operation records on TanglePay, etc. How We Use Your Information

2.1 We may associate you with your wallet by the unique serial number of your mobile device.

2.2 We may promptly push important notifications to you, such as software update, update of Terms of Service and this Policy.

2.3 We may offer you the “Touch ID” option in the “Settings” column of TanglePay to provide you with a convenient and safe way to manage your digital Tokens.

2.4 We deal with your feedbacks by using the Wallet Address and the mobile device information provided by you.

2.5 According to TanglePay Terms of Service and other rules of TPF, TPF will manage and handle the use behaviors of Users through Users’ information.

2.6 We may use your information in accordance with laws, regulations and to cooperate with regulatory authorities.

How You Control Your Own Information

You are entitled to control your Personal Information provided to TanglePay:

3.1 You may import your other wallets into TanglePay through synchronization of wallets and you may export your wallets from TanglePay to other wallets.

3.2 TanglePay will display the information of imported wallets to you. You may add or delete Tokens using the “Assets” column.

3.3 When we collect information from you for a specific purpose, we will ask for your consent in advance to which you are entitled to refuse. However, you understand that when you refuse to give such consent, you also give up the choice to use specific services provided by TanglePay.

3.4 You acknowledge that since IOTA network is an open source system, your transaction records are automatically public and transparent in the whole network.

3.5 You understand that after you link to the third-party-developed DApps from TanglePay, the TanglePay Terms of Service and TanglePay Privacy Policy will no longer apply. You are encouraged to carefully review its privacy policies and related terms of service before you start to use the third-party-developed DApps.

3.6 You are entitled to ask us to update, revise, and delete your relevant information.

3.7 We reserve the right to collect your information without your prior authorization or consent according to the Article 7 of Section 1 of this Policy.

Information We may Share or Transfer

4.1 The Personal Information will not be sold, traded or transferred to the third parties without your consent.

4.2 The Personal Information may be disclosed to these entities if you agree to our disclosure of the personal information to strategic partners or related parties. These entities will only use your personal information for the purposes you have agreed to.

4.3 TPF will not share with or transfer your Personal Information to any third party without your prior consent, except for the following circumstances:

a. the collected Personal Information is publicized by yourself;

b. the Personal Information is collected from public information which was legally disclosed, such as news (lawfully reported), government information disclosure and other channels;

c. we may share your Personal Information with our affiliates only when necessary and to the extent permitted by this Policy;

d. in order to abide by applicable laws, regulations, legal procedures, and administrative or judiciary authorities, TPF will provide or implement this Policy to protect our or other parties' rights, assets or security;

e. in the case of mergers and acquisitions, if transfer of Personal Information is involved, TPF may require the receivers of Personal Information to be continuously bound by this Policy.

How We Collect Data Automatically

5.1 We use automatic data collection technology in the application. E.g:

a. cookies (or browser cookies). Cookies are small text files set by the operator of a website or application to identify your browser or device. We may use cookies on our apps to store and track information, such as the number and frequency of use of users, user distribution, and users' online preferences. Cookies do not capture information that can identify you, but the information they collect can help us analyze the usage of the application to improve your experience. You can turn off cookies in your browser settings. However, this may affect the functionality of the application.

b. network analysis. Web analytic is a method of collecting and evaluating the operation of visitors to web pages and mobile applications. This includes analyzing traffic patterns, such as determining the frequency of visits to certain functions of a website or mobile application, or to understand the information or services that visitors are most interested in. We use network analysis services provided by third-party tools.

How We Protect Your Information

6.1 If TPF terminates operation, TPF will stop the collection of your Personal Information in time, post the announcement on TanglePay and delete or anonymize your Personal Information held by us within a reasonable period.

6.2 To protect your Personal Information, TPF may adopt data security techniques, improve internal compliance levels, provide security training for our staff, and set security authority for access to relevant data to protect your Personal Information.

6.3 We will send you messages about information security in the “Wallet Guide” column and update articles concerning the use of wallets and information protection in the “Wallet Guide” column on TanglePay for your reference.

Protection for the Minors

The following special provisions apply to minors who are under the age of 18 years old:

7.1 The minors shall not use TanglePay without the guidance from their parents or guardians.

7.2 The parents and guardians of the minors shall provide guidance to the minors on using TanglePay after they read this Policy, TanglePay Terms of Service and other relevant rules.

7.3 TanglePay will ensure the confidentiality and security of the minors’ Personal Information in accordance with national laws and regulations.


8.1 After you link to the third-party-developed DApps from TanglePay, the privacy policies of the third-party-developed DApps will apply. The collection and use of your Personal Information by the third-party-developed DApps will be controlled neither by TPF, nor by this Policy.

8.2 You shall carefully select and use the third-party-developed DApps and protect your Personal Information. TPF shall not be held liable for the privacy protection obligation of any third-party-developed DApps.

8.3 You acknowledge and accept that, to the maximum extent permitted by applicable law, TPF will adopt measures as reasonable as possible to protect your Personal Information under current techniques on an “as is”, “as available” and “with all faults” basis, to avoid the disclosure, tampering or damage of information. since TPF transfers data wirelessly, TPF makes no guarantee on the privacy and security of wireless internet data transferring.


9.1 As a company that provides services to you, we will not actively provide your Personal Information to third parties other than the agreement, unless we obtain your consent and inform the other party's identity, contact information, processing purpose, processing method, etc. If there is service demand of processing your personal sensitive information in the future, we will ask your opinions once again, and use it after obtaining your consent.

9.2 If you are a user outside of Singapore, you shall fully understand and conform to the laws, regulations and rules in your jurisdictions which are relevant to use of TPF. 9.3 During your use of TPF services, if you come across any problems related to your Personal Information use, you may contact us through the submission of your feedback on TanglePay.

9.4 You may access this Policy and other service rules of TPF on TanglePay. We encourage you to check the Terms of Service and Privacy Policy of TPF each time you log into TanglePay.

This Policy shall become effective on October 10, 2018.

As for any issues not covered in this Policy, you shall comply with the announcements and relevant rules as updated by TPF from time to time.