Privacy Policy

1. Who we are

The NB Wallet is a digital identity wallet that allows organisations and their representatives to receive, store and present verifiable attestations (such as company registrations, roles and mandates).

The app and the portal are developed and published by:

• Legal entity: Mayer Software Development
• Chamber of Commerce (KVK) number: 54090385
• Developer name on Google Play: Mayer Software
• App name: NB Wallet (Android package name org.nbwallet.wallet; iOS bundle identifier org.nbwallet.app)
• Website: https://nbwallet.org

Mayer Software Development is the data controller for the personal data processed by the app and the portal. Where an organisation offers the Wallet to you under its own name (for example your employer), that organisation acts as the data controller for the attestations it issues to you, and we process those on its behalf.

2. What data we collect

Depending on how you use the Wallet, we may process the following categories of personal data:

• Identity data, such as your name, date of birth and the identifier from your personal wallet.
• Organisational data, such as your company registration number, your role and any mandates or authorisations granted to you.
• Account and authentication data, such as session tokens and login records used to sign you in securely.
• Attestation data that you receive, store or present through the Wallet.
• Technical data, such as device type, app version, IP address and language preference.
• Usage data, such as log records of actions you take in the portal (for example issuing or revoking a mandate).

3. How and why we use your data

We use your personal data to:

• Provide the Wallet and authenticate you when you log in.
• Issue, store, present, verify and revoke attestations and mandates.
• Keep the service secure and prevent fraud and abuse.
• Comply with our legal and regulatory obligations.
• Improve the reliability and usability of the service.

4. Legal basis for processing

We process your personal data on the following legal bases under the GDPR: the performance of a contract with you or your organisation, compliance with a legal obligation, our legitimate interests in operating and securing the service, and, where required, your consent. Where we rely on consent, you may withdraw it at any time.

5. Data sharing

Personal data is only shared when necessary to provide the service. This may include sharing attestations with relying parties that you explicitly choose to present them to, and with service providers that host or support the Wallet under a data processing agreement.

You are always in control of which attestations you present. We do not sell your personal data.

6. Data retention

We retain personal data only for as long as necessary for the purposes described in this policy or as required by law. Attestations remain under your control in your wallet until you delete them or they expire. Log data is kept for a limited period for security and auditing purposes.

7. Security

We apply appropriate technical and organisational measures to protect your personal data, including encryption, access controls and cryptographic protection of attestations. No system is completely secure, but we work continuously to safeguard your data.

8. Your rights

Under the GDPR you have the right to:

• Access the personal data we hold about you.
• Request correction of inaccurate or incomplete data.
• Request erasure of your data in certain circumstances.
• Restrict or object to certain processing.
• Data portability, where applicable.
• Lodge a complaint with your national data protection authority.

9. Cookies and local storage

The web portal uses local storage and strictly necessary cookies to keep you signed in and to remember your language preference. We do not use tracking or advertising cookies.

10. International transfers

Your personal data is primarily processed within the European Economic Area (EEA). If data is transferred outside the EEA, we ensure appropriate safeguards, such as European Commission adequacy decisions or standard contractual clauses, are in place.

11. Changes to this policy

We may update this Privacy Policy from time to time. The date at the top of this page indicates when it was last revised. Material changes will be communicated through the Wallet or portal.

12. Contact

If you have questions about this Privacy Policy or wish to exercise your rights, contact Mayer Software Development through the support contact details shown on the app's Google Play or App Store listing, or through nbwallet.org.

If your Wallet is offered to you by another organisation, you can also contact that organisation or the data protection officer named in your onboarding materials.