Last updated: 7/6/18

A word from Impleum

Thank you for visiting! We at Impleum respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Policy is meant to help you understand what data we collect, why we collect it and what we do with it. This way you have a right to opt-out from providing any piece of information about you at any time. This is important, that is why we hope you will take time to read it carefully. In case you don’t agree with the way we treat information, please stop using the Site and/or the Wallet.

1. Introduction

These Terms of Use (‘Terms’) describe the Impleum's Internet website located at and related subdomains (the “Site” and collectively, “Impleum”, “us”, “our”, or “we”) and content hosted on this Site. "you" or "your" means the user of the Site. This Privacy Policy together with the Terms of Use form the entire legal Agreement (“Agreement”) between Impleum (“Impleum”, “Company”, “we”, “us” or “our”) and you as a user (“you”, “user”). The Agreement Applies to our Wallet (“Wallet”) and Internet web sites located at the URL’s ("Site").

2. What types of information we collect?

There are two general categories of information we collect:

  • Information we collect automatically.
  • Information you give us.

2.1. Information we collect automatically

NOTE: This section applies only to our Site. While using the Wallet we don’t collect any information, which means no information leaves your computer and/or browser while you interact with our Wallet.

While interacting with the Site some information is being collected automatically, such information includes:

  • Geolocation information When you use certain features of our SIte, we may collect information about your location using IP address. We collect such information to improve your experience.
  • Device information. We may collect information about your hardware model, operating system and version, unique device identifier, mobile network information, and information about the device’s interaction with our services.
  • Cookies and similar technologies. We use cookies and other similar technologies. You may disable cookies at your browser settings at any time. Find out more about our use of cookies further in this Privacy Policy.
  • Log information. We may collect your log information.
  • Usage information. We may collect information about your interaction with our Site. Such information includes content you view, your searches etc.

2.2. Information you give us

The only type of personal information you may choose to give us is:

  • Email - you may provide us with your email address so that we can send you our latest news, but only in case if you will show us your explicit consent to receive such emails.

3. How we use information we collect?

Our usage of information that we collect may divided into following categories:

  • Provision, improvement and development of our Site and Wallet;
  • Newsletter.

3.1. Provision, improvement and development of our Site and Wallet.

We use your information to:

  • Provide our service;
  • Conduct researches to improve our services;
  • Provide you with customer support;
  • Contact you to deliver certain services or information you have requested;
  • To improve the content and general administration of the Site and the Wallet.

3.2. Newsletter.

We use your information to:

  • Send you our latest news, but only if you have shown your explicit consent to receive such messages. If you at some point will no longer wish to receive these marketing or promotions from us, you may opt-out as set forth in the message.


If you provide us with your personal identifiable information such as email, we may share and disclose information that we collect for following reasons:

  • With your consent;
  • Safety, legal purposes, and law enforcement;
  • Business transfers.

4.1. With your consent

In cases where you have provided your explicit consent, we may share your personal information, as described at the time of consent.

4.2. Safety, Legal purposes, and Law enforcement.

We will disclose your personally identifiable information (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an ongoing investigation of a governmental authority, (b) to enforce the Impleum Terms of Use or user agreements or to protect our rights.

4.3. Business transfers

We will not sell your personally identifiable information to any company or organization, but we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Impleum participates or to a purchaser or acquirer of all or substantially all of Impleum's assets to which this Site and/or the Wallet relates. In such event we will notify you before your personal information is transferred and becomes subject to a different privacy policy.


In this section we will describe other important information that our users need to know. Such information includes:

  • Children’s privacy;
  • Link to third party sites.
  • Cookies related information.

5.1. Children’s privacy

Impleum recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children's online activities and interests. Neither the Site nor the Wallet are directed to children under the age of 13. Impleum does not target its Wallet or this Site to children under 13. Impleum does not knowingly collect personally identifiable information from children under the age of 13. If we learn that a child under the age of 13 provided us with personally identifiable information, we will delete that information. If your child has provided personally identifiable information, please contact us so we can delete it. If you are under the age of 13, please do not provide us with any personally identifiable information.

5.2. Link to third party sites

The Site may provide links to other Websites or resources over which Impleum does not have control ("External Web Sites"). Such links do not constitute an endorsement by Impleum of those External Web Sites. You acknowledge that Impleum is providing these links to you only as a convenience, and further agree that Impleum is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites. Therefore, we strongly encourage you to familiarize yourself with terms of use and privacy policies of External Web Sites prior to using them.

5.3. Cookies related information

A cookie is a piece of data stored on the user's hard drive containing information about the user. Cookies generally do not permit us to personally identify you. We generally use session cookies to save your preferences and such cookies expire when you close your browser. We also may set a persistent cookie to authenticate users (such as for password recognition) and for support for the internal operations of our Site. Impleum may track users over time and over our Sites but we do not respond to browser do not track signals. Third parties such as providers of external services like web traffic analysis services may also track users over time and over our Site and third party websites and such third parties may also place cookies, via our Site. These cookies are likely to be analytical, performance cookies or targeting cookies, including: Google Analytics cookies, which in particular are used as Impleum contracts with Google as a third party vendor. You can find out more about this popular website analytics tool here. These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and anonymous. It is only used to improve how a website works. All of this information is anonymized. You can find out more about how it protects your data here.


NOTE: This section only applies to our Site, because we don’t collect any information from our Wallet.

You remain in full control of your information at all times. In case you provide us with your personal identifiable information such as email you may exercise any of the of the rights described in this section by sending an email to Under this Privacy Policy you have following rights:

  • Manage and control your information;
  • Rectification of inaccurate or incomplete information;
  • Data access and portability;
  • Data retention and right to be forgotten;
  • Withdrawing consent and restriction of processing;
  • Objection to processing;
  • Lodging complaints;
  • Automated individual decision-making.

6.1 Manage and control your Information

Since our Site doesn’t have a personal space you may access and update your information by sending an email to our support at

6.2 Rectification of Inaccurate or Incomplete Information

You have the right to ask us to correct inaccurate or incomplete personal information concerning you by contacting our support at

6.3 Data Access and Portability

In some jurisdictions, Applicable law may entitle you to request copies of your personal information held by us. You may also be entitled to request copies of personal information that you have provided to us in a structured, commonly used, and machine-readable format and/or request us to transmit this information to another service provider (where technically feasible).

6.4 Data Retention and right to be forgotten

We generally retain your personal information for as long as is necessary for the provision of our service to you and us and to comply with our legal obligations. If you no longer want us to use your information to provide the services to you, you can execute your right to be forgotten. Please note that if you request the erasure of your personal information: Because we maintain Site and Wallet to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time.

6.5 Withdrawing Consent and Restriction of Processing

Where you have provided your consent to the processing of your personal information by Impleum you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, Applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing pursuant to Section 6.6 and pending the verification whether the legitimate grounds of Impleum override your own.

6.6 Objection to Processing

In some jurisdictions, Applicable law may entitle you to require Impleum not to process your personal information for certain specific purposes (including profiling) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an email to

6.7 Lodging Complaints

You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.

6.8. Automated individual decision-making

While using our Site and/or Wallet you will always have an option to opt-in or to opt-out. Our Site and Wallet doesn’t automatically make decisions for you.


We may employ procedural and technological measures that are generally consistent with industry practice. Such measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Impleum may use encryption, secure socket layer and password protection to help prevent unauthorized access to your personally identifiable information. Moreover, we are actively monitoring and enforcing the information protection standards during all of our activities, namely:

  • Limitation of the rendered access to information only to those employees who need it for providing services to the user;
  • Signature of non-disclosure agreements by employees;
  • Signature by partners and external companies invited for the fulfillment of particular functions of non-disclosure agreements and agreements concerning non-usage of such information for any unauthorized purposes;
  • Storing of the personal information obtained from the user in encrypted form, at protected servers secured from unauthorized access.
  • The security of your information is important to us. Nevertheless, we cannot guarantee absolute protection of your personal information. If you have a reason to believe that your interaction with us is no longer secure, please immediately notify us by contacting us in writing at


Impleum may need to update this Privacy Policy from time to time. If so, Impleum will post our updated Privacy Policy on our Site, along with notice that the Privacy Policy has been changed so you are always aware of what personally identifiable information we may collect and how we may use this information. Impleum may also send users who have signed up to receive an email communications an email notification notifying such users of any changes to the Privacy Policy. Impleum encourages you to review this Privacy Policy regularly for any changes. Your continued use of this Site or Wallet and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.


If you have any questions or complaints regarding this Privacy Policy or questions in relation to the way we handle your information please contact us via email at or