Terms and Privacy
Oct 21, 2023
Last Updated: October 2023
(IMPORTANT) Please note that Fluvi Wallet is currently in its Beta phase. The Services provided may undergo changes, additions, or removals in the future without prior notice, and we do not assume liability for any such modifications. Throughout this phase, Fluvi Wallet is committed to safeguarding users' rights to access Digital Assets. Should any impending changes potentially impact these rights, we will endeavor to notify users in advance.
Article 1. Purpose
This Terms of Service agreement is a binding contract between Fluvi Inc., herein referred to as “Fluvi Wallet,” "we," "our," or "us," and you, or the entity you represent, herein referred to as "user," "users," "you," or "your." By utilizing our services, you hereby agree to be bound by the terms stipulated in this Agreement.
Article 2: Definitions
2.1 Services: All functionalities accessible through Fluvi Wallet via a web browser extension, desktop application, Android OS, or iOS application.
2.2 Digital Assets: Assets that are processed and distributed via blockchain technology, and are tradable on blockchain networks. This includes, but is not limited to, cryptocurrencies, digital tokens, and NFTs (Non-Fungible Tokens).
2.3 DApps: Decentralized Applications provided by third parties, functioning as individual and independent services that operate through smart contracts and a series of programs on the blockchain.
2.4 Wallet: A unique identification address within the blockchain used to record transactions and changes in digital assets.
2.5 Password: A unique combination of letters, numbers, and symbols used for security purposes to unlock or recover Fluvi Wallet.
2.6 Private Key: A unique alphanumeric combination used to authorize and sign transactions associated with a wallet address.
2.7 Seed Phrase: A sequence of random words that provide the necessary data to recover a digital wallet.
All terms defined in these Terms of Service are in accordance with relevant laws and general business practices unless specified otherwise in the preceding paragraph.
Article 3: Adherence to Terms and Adaptability to Term Modifications
3.1 The utilization of our Services is contingent upon the acceptance of these Terms of Service. By engaging with our Services, you affirm your comprehensive understanding and full agreement to these Terms of Service. Should you disagree with these Terms of Service or any part thereof, we advise abstaining from the use of our Services.
3.2 These Terms of Service shall be prominently displayed on the relevant service page or communicated to users through other appropriate channels.
3.3 In the event that business necessities or internal deliberations require a revision of these Terms of Service, such amendments will be made. Under such circumstances, the details of the modifications will be announced or conveyed by Fluvi Wallet at least seven (7) days before the amendments take effect. Users retain the right to disapprove of the modified Terms of Service. Subsequently, Fluvi Wallet may cease the provision of Services or refrain from offering the applicable Services under the revised Terms of Service to the users.
3.4 Following the announcement of modifications as outlined in 3.3, users are deemed to have accepted such modifications unless a clear intention of refusal is expressed by the effective date.
3.5 In the absence of a request by Fluvi Wallet for agreement on separate Terms of Service, these Terms of Service shall extend to any new Services offered by Fluvi Wallet.
3.6 Fluvi Wallet may establish separate terms and operation policies for individual or paid Services. If the user agrees to these separate terms and operation policies, they will take precedence over this Terms of Service.
Article 4: Service Agreement
4.1 The Service Agreement shall be effective once the applicant, intending to become a user, agrees to these Terms of Service and gains access to the Service.
4.2 Users intending to utilize a third party service, including DApps, must agree to the respective Terms and Conditions of the Third-Party Service to obtain usage rights for that third party service. The Terms and Conditions of the third party service shall govern the use of that third party service, not this Fluvi Wallet Terms of Service.
4.3 Fluvi Wallet reserves the right to refuse or withdraw consent for a user to use our Service in any of the following cases, and may revoke such consent if any of the following circumstances are confirmed, even after account creation:
a. The applicant is under 14 years of age; b. The applicant has provided false information to Fluvi Wallet during the account creation process; c. A hacking attack or other security incident has occurred; d. The applicant is a resident of a country where the Service is not provided; e. The applicant is involved in, or likely to be involved in, illegal activities such as money laundering, terrorist financing, or unfair business practices; f. Approval of the application is hindered due to relevant laws and regulations, supervisory regulations, guidelines from supervisory agencies, or the Terms of Service of Fluvi Wallet; g. The use of the Service is deemed intended for acts against public order and/or good morals and manners; h. Approval of the application is challenging due to facility, technical, or operational issues; i. The required documents or information have not been submitted, or there are other reasons deeming the use of our Service inappropriate.
4.4 In the event of war, incident, natural disaster, or other equivalent emergency situations, either occurring or anticipated, we reserve the right to terminate or suspend the Service Agreement, in whole or in part.
Article 5: Protection of Personal Information and Privacy
5.1 Fluvi Wallet may collect personal information from users solely for the purpose of providing the Services, and only within the scope and for the purposes agreed upon by the user. The collected personal information will be utilized within the agreed objectives and range, aimed at effectively delivering our services to the user.
Article 6: Management of User's "Private Key," "Password," and "Seed Phrase"
6.1 Users are solely responsible for the secure management of their Private Key, Password, and Seed Phrase, ensuring these remain inaccessible to third parties.
6.2 Upon realizing that their Private Key, Password, or Seed Phrase has been compromised or is being utilized by a third party, users must promptly notify us and follow any subsequent instructions provided.
6.3 Per paragraph (6.2), Fluvi Wallet will not be held accountable for any unfavorable outcomes stemming from users' failure to adhere to our instructions or to promptly notify us, barring deliberate misconduct or negligence on our part.
6.4 Fluvi Wallet absolves itself of responsibility if a user's Private Key, Password, or Seed Phrase is unlawfully accessed or utilized by a third party due to factors beyond our control.
Article 7: Detailed Description of Services
7.1 Fluvi Wallet extends the following services:
a. Account creation with a new wallet address. b. Viewing and managing digital assets. c. Transferring Digital Assets. d. Authorizing and signing various transaction requests for Services and DApps. e. Importing and exporting recovery files and Seed Phrases. f. Displaying advertisements for third party services.
7.2 The Service remains accessible 24/7, except for significant business or technological hindrances.
7.3 Our Service facilitates users in transferring Digital Assets via their Wallet address. Users are wholly responsible for the accuracy of the recipient Wallet address. Fluvi Wallet denies liability for failures or losses stemming from transfers to inaccurately specified addresses by the user.
7.4 Although Fluvi Wallet aids in submitting user transactions to the blockchain network, it does not control the blockchain network. Users should recognize and accept that transactions may encounter delays or failures based on the blockchain network conditions, and it's incumbent upon users to verify their transaction history individually.
7.5 Services may temporarily suspend during system inspections, expansions, or malfunction rectifications, as deemed necessary by Fluvi Wallet. Users will be reasonably notified, albeit post-interruption notifications may occur if circumstances warrant.
7.6 Service usage may be wholly or partially constrained during inspections, and Fluvi Wallet disclaims liability for damages arising from these constraints unless caused by our intentional misconduct or negligence.
7.7 Fluvi Wallet acts neither as an agent nor a representative for any third party and offers no warranties, whether expressed or implied, concerning the accuracy or reliability of third-party information. Restrictions in our service functionality due to failures or inspections of linked or advertised third-party services are not Fluvi Wallet's responsibility, unless resulting from our intentional or negligent actions. Users will be notified or informed of such instances.
7.8 Fluvi Wallet may furnish live market value information of users' Digital Assets, sourced from third parties for user convenience. Users should acknowledge that this information may not reflect the current, accurate live market values, and Fluvi Wallet disclaims liability for any information discrepancies unless caused by our willful misconduct or gross negligence.
7.9 Some Services may require payment. The fees and conditions for paid Services are subject to change at any time.
7.10 With prior user consent, Fluvi Wallet may share advertising and promotional information about third parties or their services, either displayed on the Service page or conveyed through other means. Herein, Fluvi Wallet merely acts as a conduit for this information and offers no warranties, whether expressed or implied, regarding the advertisements and promotional information of third parties’ services. Fluvi Wallet shall not be held liable for the advertising and promotional information barring any willful misconduct or gross negligence on our part.
7.11 Fluvi Wallet may reward users with points or benefits like network fee discounts when users view or engage in ads under specific conditions. The benefits afforded to users may vary based on their choices post-viewing or engagement with the ads. However, users may be prompted to make a choice prior to viewing or participating.
7.12 Users may be ineligible for benefits from viewing or engaging in ads under the following circumstances, and Fluvi Wallet will not bear responsibility unless there's evidence of intent or gross negligence on its part:
a. Internet or network errors, disruptions, disconnections, or other communication service failures. b. Service interruptions due to user fault, such as turning off the Service or device errors. c. When verification of benefit provision is impossible due to data omission, corruption, desynchronization, etc.
Article 8: Obligations of Fluvi Wallet
8.1 Fluvi Wallet is devoted to offering a reliable Service in adherence to these Terms of Service.
8.2 Fluvi Wallet maintains a personnel and system infrastructure to address user complaints or requests for damage relief concerning Service use.
8.3 Fluvi Wallet enforces stringent security measures to safeguard user information, utilizing it solely for the provision, operation, or enhancement of Services. Fluvi Wallet shall not transfer user information to any other entity or individual for alternative purposes, unless authorized by the user or as mandated by pertinent laws and regulations.
Article 9: Obligations of Users
9.1 Users must diligently secure and manage their devices used for the Service, such as cellphones and applications, to prevent theft, forgery, tampering, hacking, and loss of the device. Users bear sole responsibility for managing their own Service accounts. Upon detecting any illicit use of their account, users are obliged to promptly notify Fluvi Wallet.
9.2 Users shall refrain from the following actions while utilizing the Service:
Article 10: Ownership of Rights
10.1 Copyrights and intellectual property rights pertaining to the content within the services crafted by Fluvi Wallet shall be vested in Fluvi Wallet.
10.2 Users are, in principle, prohibited from infringing upon Fluvi Wallet’s intellectual property rights regarding the Service, or from creating derivative works of the Service.
10.3 Users are also prohibited from removing or altering any information on rights such as proprietary notices, marks, or labels from the Service. Except as expressly authorized under these Terms and Conditions, users shall not reverse engineer, decompile, or disassemble the Service.
10.4 Without the prior written consent of Fluvi Wallet, users shall not translate, redistribute, re-transmit, publish, sell, rent, lease, trade, resell, pledge, mortgage, transfer, revise, modify, or expand any part of the Service. Such acts may constitute an infringement of copyright and will therefore be subject to civil and criminal liabilities.
10.5 Information collected during Service use may be employed to improve and enhance the quality of the Service, develop new Services, and for other purposes with the consent of the user.
Article 11: Limitation of Liability
11.1 Fluvi Wallet operates as a digital wallet service, not a banking or custodial service. The blockchain network or DApps' functionality is not guaranteed. Users might encounter delays, conflicts of interest, or operational decisions by third parties, potentially disadvantaging cryptocurrency owners.
11.2 Transactions initiated through Fluvi Wallet may face delays or may not be completed on the blockchain network. Fluvi Wallet bears no responsibility for transactions not verified or processed as expected. No guarantees or warranties are provided that a transfer initiated through Fluvi Wallet Services will successfully transfer ownership or rights to the cryptocurrency.
11.3 Fluvi Wallet employs Account Abstraction ("AA") to facilitate various features. Despite extensive testing, the Services are relatively new and may contain bugs or security flaws. Ongoing development may lead to substantial changes over time, which may not meet user expectations.
11.4 Some DApps may deny access to transactions conducted through Fluvi Wallet due to its use of a contract wallet utilizing AA, as opposed to an Externally Owned Account (EOA) wallet. The availability and convenience of Fluvi Wallet Services may be affected as not all DApps and contracts can be inspected. Fluvi Wallet is not liable for any issues arising from these risks.
11.5 The use of Fluvi Wallet Services may expose users to risks such as extortion or theft. Malicious entities employing various methods, including malware attacks, denial-of-service attacks, and other consensus-based attacks, may disrupt service operations. The open-source nature of the blockchain protocol may also present vulnerabilities leading to the loss of user's Digital Assets and access control over their Wallets. In the event of software bugs or weaknesses, there may be no remedy, and users are not guaranteed any relief, refund, or compensation.
11.6 All transactions, including purchases and exchanges, are final and irreversible. Once a transaction is approved and the Digital Asset is sent to the designated Wallet, it cannot be retrieved. Users agree not to expect any guarantees or refunds on completed transactions. The obligations of Fluvi Wallet towards the user are deemed fulfilled upon the approval of the transaction, and users shall not have any claims or entitlements against Fluvi Wallet thereafter.
11.7 Fluvi Wallet may provide live market value information of users’ Digital Assets for convenience. However, this information may not reflect the accurate current market value and Fluvi Wallet shall not be liable for any discrepancies in the provided information without its wilful misconduct or material negligence.
11.8 Users acknowledge and agree that the limitation of liability as set forth in this Article is a fundamental basis of the bargain between Fluvi Wallet and the user, and that Fluvi Wallet would not be able to provide the Services absent such limitation.
Article 12: Governing Law and Jurisdiction
12.1 Any dispute arising between Fluvi Wallet and the user from the use of the Services and these Terms of Service shall be governed by the laws of the Republic of Korea.
12.2 The courts of the Republic of Korea shall have exclusive jurisdiction over all disputes related to the use of Services, with the jurisdictional courts being determined in accordance with the Civil Procedure Act.
Article 13: Compensation for Damages
13.1 Should a user incur damages due to the culpable actions of Fluvi Wallet, the liability of Fluvi Wallet for compensation shall extend to ordinary damages as delineated in the Civil Code. In special circumstances, Fluvi Wallet shall be liable for compensation only if it was aware or could have been aware of such circumstances.
13.2 Notwithstanding the preceding paragraph, the user may bear full or partial responsibility in the following scenarios:
a. Inability to provide the service due to force majeure events or national emergencies of a similar nature. b. Failure to promptly notify Fluvi Wallet of the cause or fact of damages, despite being aware of them. c. Disclosure of wallet-related account and transaction information to third parties or enabling the use of the wallet through the user's intentional or negligent actions. d. In other cases where the user's intentional or negligent actions contribute to the occurrence of damages.
13.3 Fluvi Wallet shall not be liable for damages incurred by users due to reasons beyond Fluvi Wallet's control.
13.4 If the information provided by the user to Fluvi Wallet is found to be untrue, Fluvi Wallet may suspend the provision of the service at any time and terminate the entire or partial agreement in accordance with these terms and conditions. In such cases, if Fluvi Wallet suffers any damages as a result, the user may be held liable for compensating Fluvi Wallet.
13.5 If a user intentionally or negligently causes damages to Fluvi Wallet by disrupting the operation of Fluvi Wallet's services or related systems, violating laws, these terms and conditions, or social order, the user shall be liable for compensating Fluvi Wallet for all damages incurred.
Article 14: No Assignment
The user shall not assign, give, or provide as security the right to use the Service or the contractual status related to the right to use the Service to any third party.
Addendum: This agreement shall come into effect on October 21, 2023.
Article 1: Purpose of Personal Information Collection and Management
1.1 Account Creation and Management
a. Identification of individuals for service provision or user identification b. Continuous service provision and account management c. Maintenance and management of account status d. Prevention of fraudulent service usage
1.2 Service Provision
a. Service recommendations tailored to individual preferences b. Generation of digital asset wallet addresses c. Verification of digital asset transaction history d. Inspection and inquiry of held digital assets e. Connection to and utilization of third-party services like DApps f. Provision of security and convenience features through Account Abstraction (AA) g. Enforcement actions for legal and service terms violations h. Miscellaneous services
1.3 Event Information Provision
a. Dissemination of event-related and promotional information b. Recommendations and notifications for personalized services
1.4 Complaint Handling
a. Identification of user account for complaint receipt b. Review of complaints c. Reaching out to the user filing the complaint d. Guidance on the outcome of complaint review e. Remediation handling f. Account reactivation
1.5 Provision of Data for Fulfilling Statutory Obligations
Provision of data as requested by investigative agencies, courts, taxation authorities, etc., and in response to damage report requests.
Article 2: Processing and Retention Period of Personal Information
2.1 Fluvi Wallet processes and retains personal information within the retention and usage period consented to by the information subject at the time of collection, or as mandated by legal and regulatory provisions.
2.2 The processing and retention period of personal information is as follows:
a. Account creation and management: Until account deletion. b. Provision of services: Until the successful completion of service provision, and until payment/settlement is finalized in cases where expenses are incurred. (For inquiries regarding business partnerships, personal information will be retained for a period of 3 months from the date of inquiry receipt). c. Event information: 3 months following the conclusion of the event, and until consent for receiving marketing communications is withdrawn in the case of marketing information notifications. d. Complaint handling: As required by applicable law. e. Provision of data for fulfilling statutory obligations: Until the respective case is concluded.
2.3 The user's personal information will be destroyed without delay when the purpose of processing under Article 1 and the processing and retaining period under Article 2 are achieved. However, in any of the following cases, personal information may be processed and retained until the end of the relevant reason, and if the personal information processing and retaining period is different, the longest period will be applied.
a. Despite a user's request for account deletion, personal information may continue to be retained or processed with applicable laws b. To comply with legal or regulatory obligations concerning transaction record retention periods c. During ongoing investigations or inquiries into legal violations d. When settling rights and obligations related to service usage e. In case of legal disputes between the user and Fluvi Wallet
Article 3: Items of Personal Information Processed
Fluvi Wallet may process the following personal information to provide services to users:
Email address, user's own wallet addresses, device information (OS, UUID, language information), service usage records, connection logs, connection IP, etc. Until account deletion
Article 4: Provision of Personal Information to Third Parties
4.1 Fluvi Wallet processes user's personal information within the defined scope for personal information processing purposes and does not share it with third parties without user consent.
4.2 However, should a user directly consent to providing personal information to utilize services from an external partner, the company is obligated to submit personal information in accordance with relevant laws. Moreover, in emergency situations such as medical emergencies, infectious disease outbreaks, accidents, or urgent property losses, personal information may be shared with a third party.
Article 5: Handling of Personal Information of Children Under 14 Years Old
Fluvi Wallet prohibits the use of services by children under 14 years old.
Article 6: Outsourcing of Personal Information Processing
6.1 Fluvi Wallet entrusts the following entities with personal information processing tasks for efficient handling:
Google LLC (Google Cloud Platform) Data Retention and Management Until the end of the service usage period (excluding information retained separately as per applicable laws and regulations) Google Analytics 4 Data Retention and Management Until the end of the service usage period (excluding information retained separately as per applicable laws and regulations)
Article 7: Data Transfer to Other Countries
7.1 Given its engagement in global business operations, Fluvi Wallet may transfer the user's personal information to entities located in other countries for purposes as expressly outlined in this Policy.
a. Details of the personal information to be transferred b. The country to which the personal information is transferred, along with the date and method of transfer c. Name of the entity receiving the personal information (including the name of the service and contact information of the individual responsible for information management) d. The purpose of the receiving entity's use of personal information, and the duration of personal information retention and usage
7.3 For locations where personal information is transmitted, retained, or processed, Fluvi Wallet takes reasonable measures to protect such personal information.
Article 8: Disposal Procedure and Method of Personal Information
8.1 Fluvi Wallet ensures immediate disposal of personal information when it becomes unnecessary, either due to the expiration of the retention period or the achievement of the processing purpose.
8.2 However, in instances where personal information must be retained continuously as per legal provisions, such as those outlined in Article 2, 2.3, even post the expiration of the consented retention period or achievement of the processing purpose, such personal information is retained by transferring it to a separate database (DB) or storing it in a different location.
8.3 The procedure and method for personal information disposal are as follows: Fluvi Wallet selects the personal information for disposal based on the occurrence of disposal reasons and obtains approval from the personal information protection manager before proceeding with the disposal.
Article 9: Rights, Obligations, and Exercise Methods of Data Subjects and Legal Representatives
9.1 Data subjects reserve the right to exercise their rights such as access, correction, deletion, and suspension of processing of their personal information at any time with Fluvi Wallet. However, the exercise of these rights may be restricted in accordance with the provisions of related laws of the Personal Information Protection Act.
9.2 The exercise of the rights mentioned in 9.1 can be made to Fluvi Wallet in writing, by email, facsimile, or other means specified in the Enforcement Rules of the Personal Information Protection Act, and Fluvi Wallet will promptly take necessary measures in response.
9.3 The rights mentioned in 9.1 can be exercised through a legal representative or a delegate authorized by the data subject. In this case, a power of attorney according to the format specified in Attachment 11 of the "Guidelines on Personal Information Processing Methods (No. 2020-7)" must be submitted.
9.4 Requests for correction and deletion of personal information cannot be made if the personal information is specified as a collection target in other laws.
9.5 Fluvi Wallet verifies whether the requester of access, correction, deletion, or suspension of processing, as requested based on the rights of data subjects, is the data subject or a legitimate representative.
Article 10: Measures for Ensuring the Security of Personal Information
Fluvi Wallet employs the following measures to ensure the security of personal information:
10.1 Minimization and education of personnel handling personal information. Fluvi Wallet designates specific personnel to handle personal information, restricts them to a minimum, and implements measures to manage personal information.
10.2 Establishment and implementation of internal management plans: Fluvi Wallet establishes and implements internal management plans to ensure the secure processing of personal information.
10.3 Technical measures: Encryption of Personal Information - Fluvi Wallet will employ secure encryption algorithms to store and manage critical personal information. (Currently, Fluvi Wallet does not store any critical personal information).
Article 11: Collection, Use, and Provision of Behavioral Information and Rejection
11.1 Fluvi Wallet may collect, use, or provide behavioral information for online personalized advertising or other purposes in relation to the Fluvi Wallet service.
11.2 Fluvi Wallet may collect behavioral information as follows:
a. Personal information to be collected: service menu visit history. b. How we collect personal information: Collect information when running the service through third-party services including Google Analytics. c. Purpose of collecting and processing information: Service improvement and development based on user interest analysis. d. Period of retention and usage: Immediate disposal after withdrawal of membership.
11.3 Fluvi Wallet collects only the minimum behavioral information necessary for service improvement and does not collect sensitive behavioral information that may clearly violate individual rights, interests, or privacy, such as thoughts, beliefs, family and relatives, educational background, and other social activities.
11.4 Users can refuse the use of Google Analytics by visiting the Google Analytics opt-out page:
Article 12: Details of Personal Information Protection Manager
12.1 Fluvi Wallet appoints a personal information protection manager who is responsible for overseeing the processing of personal information and handling complaints and remedies related to personal information processing.
12.2 Personal Information Protection Manager
Name: Sangseung Lee
※ You will be connected to the Personal Information Protection Department.
12.3 Personal Information Protection Department
Name: Sangseung Lee
12.4 Information subjects can contact the Personal Information Protection Manager and the relevant department for any inquiries, complaints, or requests regarding personal information protection related to the Fluvi Wallet service. Fluvi Wallet will respond and handle your inquiries promptly.
Article 13: Department for Receiving and Processing Requests for Access to Personal Information
13.1 Data subjects may submit a request for access to personal information under Article 35 of the Personal Information Protection Act to the following department:
Department for Receiving and Processing Requests for Access to Personal Information:
Name: Sangseung Lee
13.2 Fluvi Wallet will make efforts to ensure prompt handling of requests for access to personal information by the data subjects.
Article 14: Remedies for Violation of Data Subject's Rights
14.1 Should there be any violations concerning personal information, data subjects have the right to seek remedies through dispute resolution or consultation from the Personal Information Dispute Resolution Committee, the Korea Internet & Security Agency Personal Information Infringement Reporting Center, or other pertinent organizations. For reporting and consultation on other personal information infringements, the following institutions may be contacted:
a. Personal Information Dispute Resolution Committee: 1833-6972 (www.kopico.go.kr) b. Personal Information Infringement Reporting Center: 118 (privacy.kisa.or.kr) c. Supreme Prosecutors' Office: 1301 d. National Police Agency: 182
14.2 Individuals who have suffered infringement of rights or interests due to a disposition or negligent act of a public institution in response to requests under the provisions of Article 35 (Access to Personal Information), Article 36 (Correction or Deletion of Personal Information), or Article 37 (Suspension of Personal Information Processing) of the Personal Information Protection Act may request administrative adjudication in accordance with the Administrative Adjudication Act.
※ For more information on administrative adjudication, please refer to the website of the Central Administrative Appeals Commission (http://www.simpan.go.kr).