Holdr+ Privacy Policy

Last Updated: July 1, 2022

If you download or use the Indicio, Inc. Holdr+ mobile app (“App”), Indicio (“Indicio,” “Company,” “we,” “us,” “our“) will ask to collect and store personal information about you (your “Personal Data”) on your personal cell phone or device (“Device”). We would not be able to offer the App to you without the ability to store your Personal Data in your Device. We also want to make very clear that Indicio will never collect, access, or store your Personal Data.

This document (our “Privacy Policy”) explains how your Personal Data will be collected, stored and used. This Privacy Policy is subject to the Holdr Terms of Service (“Terms”) available at indicio.tech/holdr-privacy-policy which is incorporated by reference into this Privacy Policy, and all capitalized terms (unless defined in this document) are defined in our Terms. If you have questions about this Privacy Policy, or have suggestions for how we can improve it, please contact us at support@indicio.tech.

If you do not want your Personal Data to be stored on your Device, you should not use the App.

Collection of Data

Indicio does not collect or store any Personal Data. All data including your Credentials, Messages, and Personal Data created or uploaded via the App is stored locally on your Device. As a result, we do not have any access to your Credentials, Messages, or Personal Data. Any Messages that you send via the messaging feature will also be stored locally on the recipient’s Device and are end-to-end encrypted. We use a mediator server for relaying the Messages between Users. Information about your contacts is also stored locally on your Device. Indicio can never access, collect, or store your Credentials, Messages, Personal Data, or contacts.

Sharing of Data

Issuers and Verifiers may request Personal Data from you to provide the requested Credentials or verification services. Any transfer of Personal Data to an Issuer or Verifier is governed by the Issuer or Verifier’s respective privacy policy (see Section 7: Third-Party Links), and Indicio will never have access to such information.

You may also choose to send Messages or share Personal Data or Credentials with other third parties or Users via the App. Indicio does not have access to information shared with third parties and will never collect or store your Personal Data. As such, we will never share your Personal Data with anyone.

Deletion of Data

You may delete your Personal Data from your Device at anytime by uninstalling the Holdr+ app or by selecting the “Reset Wallet” button in the “Settings” screen.

No Sale or Disclosure of Personal Information

We do not sell or disclose any personal information of any consumers, as those terms are defined under the California Consumer Privacy Act.

No Discrimination

We will not discriminate against any consumer for exercising their rights under the California Consumer Privacy Act.

Cookies and Trackers

We do not use cookies or any other activity tracking tools on our App.

We do not currently respond to “Do Not Track” or DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

Third-Party Links

The App may contain links to other websites or apps. Your access to and use of such linked sites is not governed by this Privacy Policy but, instead, is governed by the privacy policies of those third-party websites. We are not responsible for the Personal Data practices of such third-party websites. Please review the privacy policies of such sites before you disclose your Personal Data to them.

Children’s Privacy

The App is not intended for children. We do not knowingly collect, use, sell, or share any Personal Data from anyone under the age of 18. If we become aware that a child under the age 18 has provide Personal Data to us, we will delete it.

Security

We are committed to protecting the privacy and confidentiality of your Personal Data. This why we do not collect or store any of your Personal Data.

Mobile Push Notifications/Alerts

With your consent, you may receive non-promotional push notifications or alerts to your Device. You can deactivate these messages at any time by changing the notification settings on your Device.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time to reflect changes in our practices concerning the collection, use, and sharing of your Personal Data. The revised Privacy Policy will be effective immediately upon notification through the App. If you continue to use the the App after we make changes then you will be deemed to have agreed to the changes, so please check this Privacy Policy periodically for updates.