WrapLink Privacy Policy

1. Who is responsible for your data?

The entity operating the WrapLink service is responsible for determining how personal data is processed.

Before production publication, this section must identify the actual legal entity operating WrapLink, its registered address and the appropriate privacy contact.

• Legal entity: WrapLink is currently operated by the project owner as an individual software project.
• Registered address: Not applicable while WrapLink is operated as a personal project.
• Privacy contact: mahdi.asgari@gmail.com
• Data Protection Officer: No Data Protection Officer is currently appointed. If appointment becomes legally required, the relevant contact details will be published here.

2. Information we may collect

The information processed depends on which WrapLink features you use.

• Account information such as name, email address and account identifiers.
• Authentication and security information necessary to protect the account.
• Connection information such as IP address, connection status, network information and service telemetry.
• Bandwidth and usage information necessary to operate and report on network services.
• Wallet, order and payment information necessary to process purchases and maintain transaction records.
• Support information contained in support tickets and communications with WrapLink.
• Device, browser and technical information necessary for security, diagnostics and service operation.
• Information you voluntarily provide to WrapLink.
• Information required to comply with applicable legal obligations.

3. Why we process personal data

We process personal information only for purposes connected with operating, securing and improving the WrapLink service or complying with applicable obligations.

• Create and manage user accounts.
• Authenticate users and protect accounts.
• Provide connectivity and network services.
• Monitor bandwidth and service usage.
• Process wallet transactions, purchases and orders.
• Detect payment abuse, fraud and unauthorized activity.
• Provide customer and technical support.
• Diagnose service problems and improve reliability.
• Communicate about account, security, payment and service matters.
• Meet legal, regulatory, accounting and security obligations.

4. Legal bases for processing

Where applicable data-protection law requires a legal basis, processing may rely on one or more of the following bases depending on the purpose and circumstances.

• Performance of a contract or steps requested before entering into a contract.
• Compliance with a legal obligation.
• Legitimate interests, where those interests are not overridden by applicable rights and freedoms.
• Consent, where consent is required or appropriate.

5. Account and authentication data

When you create an account, WrapLink processes information necessary to establish and maintain the account.

Passwords should be stored by the backend using an appropriate one-way password hashing mechanism. WrapLink should never require or store a user's plaintext password in ordinary application records.

• Name and email address may be used to identify the account.
• Email verification information may be generated to verify ownership of an email address.
• Authentication and security events may be recorded to protect the account.
• Login and session information may be processed for security and account management.

6. Network, connection and IP information

WrapLink may process technical network information necessary to provide and secure connectivity services.

• IP addresses.
• Connection state and connection timestamps.
• Network and routing information.
• Latency, packet-loss and diagnostic measurements.
• Bandwidth consumption and usage statistics.
• Security-related network events.

Network information may be used to provide the service, diagnose problems, detect abuse and maintain security.

7. Wallet, payments and transactions

When you add funds to a WrapLink Wallet, purchase a plan, place an order or request a refund, transaction information may be processed.

• Order and transaction identifiers.
• Amount and currency.
• Payment method.
• Payment status.
• Wallet balance and wallet transaction history.
• Payment verification information.
• Refund and cancellation information.
• Cryptocurrency transaction identifiers where cryptocurrency payment is supported.

Where a third-party payment provider is used, payment-card or financial information may be processed directly by that provider according to its privacy policy and applicable contractual arrangements. WrapLink should not store sensitive payment credentials unless specifically required and lawfully permitted.

8. Cryptocurrency information

If cryptocurrency payments are supported, WrapLink may process blockchain transaction information required to identify and verify a payment.

• Transaction hash.
• Wallet address involved in the payment.
• Blockchain network.
• Asset/token.
• Amount.
• Confirmation status and timestamps.

Blockchain transactions may be publicly visible and may be difficult or impossible to alter or delete. Users should therefore consider the public nature of blockchain networks before making a cryptocurrency payment.

9. Support communications

• Support tickets and their contents may be stored to investigate and resolve issues.
• Support agents may access information reasonably necessary to resolve the request.
• Do not send passwords, private keys, recovery codes or other unnecessary secrets through support tickets.
• Support records may also be retained for security, dispute resolution and legal obligations.

10. Cookies and local storage

WrapLink may use browser storage, cookies or similar technologies to maintain sessions, remember preferences, provide security and operate the website.

The production implementation should document each non-essential cookie or tracking technology and obtain consent where required by applicable law.

Local browser storage should not be treated as a secure location for long-lived authentication secrets.

11. Security

WrapLink uses reasonable technical and organisational measures intended to protect personal information against unauthorized access, loss, misuse and alteration.

• Access controls and authentication.
• Encryption where appropriate.
• Security monitoring and logging.
• Fraud and abuse detection.
• Restricted administrative access.
• Security reviews and incident response procedures.

No Internet service can guarantee absolute security. Users should protect their credentials and promptly report suspected account compromise.

12. Who may receive personal data?

Personal information may be disclosed only where reasonably necessary for the purposes described in this Policy, where required by law, or where otherwise permitted by applicable law.

• Infrastructure and hosting providers.
• Payment and financial service providers.
• Email and communication providers.
• Security, monitoring and fraud-prevention providers.
• Customer-support providers.
• Professional advisers where necessary.
• Government authorities or law-enforcement bodies where legally required.

13. International data transfers

Some service providers or infrastructure used by WrapLink may process information outside your country or outside the European Economic Area.

Where applicable data-protection law requires safeguards for an international transfer, appropriate legal mechanisms should be used.

The final production policy should identify the relevant transfer mechanisms and categories of recipients.

14. Data retention

Personal information should be retained only for as long as necessary for the purpose for which it was collected, unless a longer period is required or permitted by law.

• Account information may be retained while the account is active and for an appropriate period afterwards.
• Transaction and accounting records may need to be retained for legally required periods.
• Security logs may be retained for a limited period appropriate to security and incident investigation.
• Support records may be retained for service, dispute and legal purposes.
• When information is no longer required, it should be securely deleted or anonymised where appropriate.

15. Your privacy rights

Depending on your location and applicable law, you may have rights concerning your personal information.

• Right to access personal information.
• Right to correct inaccurate information.
• Right to request deletion in applicable circumstances.
• Right to restrict certain processing.
• Right to object to certain processing.
• Right to data portability where applicable.
• Right to withdraw consent where processing is based on consent.
• Right to lodge a complaint with the applicable data-protection supervisory authority.

Requests should be made through the official privacy contact. WrapLink may need to verify the identity of the requester before responding.

16. Marketing communications

Marketing communications are separate from messages necessary to operate your account or provide services.

Where marketing consent is required, it must be optional and must not be required merely to create an account.

You can withdraw marketing consent through the available unsubscribe or account-preference mechanism.

17. Children

WrapLink is not intended to knowingly collect personal information from children where doing so would violate applicable law.

If you believe that a child has provided personal information improperly, contact WrapLink through the official privacy channel.

18. Automated security and fraud decisions

WrapLink may use automated technical controls to identify suspicious login activity, payment abuse, account compromise, malicious traffic or other security risks.

Where applicable law provides rights concerning solely automated decisions that produce legal or similarly significant effects, the production implementation should provide the appropriate safeguards and review mechanisms.

19. Security incidents

If WrapLink becomes aware of a personal-data security incident, it will assess the incident and take steps required by applicable law, including notification to authorities or affected individuals where legally required.

20. Changes to this Privacy Policy

WrapLink may update this Privacy Policy when its services, processing activities or legal requirements change.

Material changes should be communicated through an appropriate channel where required.

The effective date and version displayed at the beginning of the Policy identify the version applicable to the document.

21. Privacy contact

For privacy questions or requests concerning personal information, contact the official WrapLink privacy contact published on the website.

The final production version must replace the placeholders in this document with the actual legal entity and privacy contact information.