Privacy Policy

Solve.Care Foundation OÜ, a company incorporated and acting under the law of Estonia, having its registered office at Narva mnt 5, Tallinn 10117, Estonia (“Solve.Care”) and its affiliates (collectively, the “Solve.Care Group” or “we” or “us” or “our”) have updated our Privacy Policy (“Policy”).

We have provided short summaries in this Privacy Policy to help you understand what information we collect, how we use it, and what choices or rights you may have. While these summaries help explain some of the concepts in a simple and clear way, we encourage you to read the entire Privacy Policy to understand our data practices.

  1. Purpose Of This Policy

    The purpose of this Privacy Policy is to describe how we collect, use, retain, share and secure the personal information through our online interfaces (e.g., mobile applications and websites) owned and controlled by us, including mobile applications Care.Wallet, Care.Wallet for Family, Care.Cards, Care.Coin or the website (the “Website”), and any other websites, features, applications, widgets or online services that are owned or controlled by Solve.Care Group and that post a link to this Privacy Policy (together with the Site, the “Service”), as well as any information Solve.Care collects offline in connection with the Service. It also describes the choices available to you regarding the use of, your access to, and how to update and correct your personal information. Note: that we combine the information we collect from you from the Website, through the Service, or offline.

  2. Scope Of This Policy
    • When this Policy applies:

      In addition to the Services and Websites that link to this Policy, this Policy applies to the following:

      • The Solve.Care Platform, which is an online healthcare administration platform designed for use by patients, employers, physicians, healthcare agencies, and insurance companies. When we post an application and the application links to this Policy, this Policy applies. The Solve.Care Platform uses blockchain technology as the underlying distributed ledger for all care events between patient, doctor, pharmacy, laboratory, insurer, and other parties. Patients are empowered to manage their healthcare decisions. Employers can use the platform to administer benefits, reduce costs, and reward their employees. Physicians and hospitals can issue prescriptions, manage appointments, and coordinate with a specialist. The goal of the Solve.Care Platform is to coordinate all stakeholders and eliminate inefficient processes and save billions of dollars in costs per year.
      • The know your customer (“KYC”) verification – if you acquire, use or hold our SOLVE Tokens and some other services under our name, our Anti-money laundering (“AML”) and Counter-terrorist financing (CTF”) Policy (“AML/CTF Policy”) can be applicable. The AML/CTF Policy was created to prohibit and actively prevent money laundering (“ML”) and any activity that facilitates ML or the financing of terrorism (FT) or criminal activities by complying with all applicable laws and regulations. Solve.Care Group puts reasonable efforts in place to control and to limit ML/FT risk. Therefore Solve.Care implemented the Know-Your-Customer (“KYC”) verification, which requires due diligence and the formal identification for an identity of the SOLVE Token holder.
    • When this Policy does not apply – Third party websites:

      Our Websites may contain links to other websites. The information and the content of such websites are not under our control and are governed by the privacy statements of such other websites. We encourage you to review the privacy statements of any such other websites to understand their information practices.

  3. Consent

    By using our Service, you unconditionally consent to the collection, use, disclosure, retention and transfer of your personal data and other information by us.

    You also represent to us that you have any and all authorizations necessary to use our Service including to use it to process the personal data and other information. We collect and use the information you provide to us, including information obtained from your use of the Service. Also, we may use the information that we collect for our internal purposes to develop, tune, enhance, and improve our Service in consistency with this Privacy Policy.

    If you do not agree with any provisions of this Privacy Policy or Cookies Policy, please do not use our Service and do not provide any your personal data or information to us.

    If you refuse or withdraw your consent, or if you choose not to provide us with any required personal data or information, we may not be able to provide you with the services that can be offered by us. Consent can be withdrawn at any time. To remove your consent or deleting your personal account, please check the respective instructions in the Service you use or contact as by using the details set out in Section 16 below.

    Please note that we may also rely on legitimate interests as the basis for processing your personal data in the limited circumstances set out below:

    • In situations where we obtain your personal data from a source other than you, we process your data on the basis of legitimate interests, until the earlier of (a) the point at which you provide your consent; or (b) the point at which you ask us to stop processing your data on the basis of our legitimate interests;
    • We may retain your records for our own compliance and verification, including KYC verification purposes (including where we are required to do so by law or by legitimate interest of our partners), even after you withdraw your consent to our processing of your data;
    • We will archive information about your use of our Service, even after you withdraw your consent to our processing of your data. This information will only be used in very limited circumstances, such as for defending legal claims relating to contracts, we have with you or a third party and retention for audit purposes relating to commercial contracts; and
    • We will use information relating to your use of our services for statistical analysis and research purposes, however we delete your name, mobile number, email address, billing addresses and other identifiable data from such information before we do so.
  4. Information That You Provide To Us

    You may give us information about you by using or Service, filling in forms through our Service or by corresponding with us by phone, email or otherwise. This includes information you provide when you registerto use the Service and when you report a problem with it.

    • Information that you may provide to us

      During your registration at our Service or using our Service or interacting with our Service in other way, you provide us your information required to achieve the purposes set out in this Policy (see above), and you have the ability to limit such collection, as specified in Section 12 of this Policy. We only process the minimal amount of data required to provide our Service, such as:

      • Personal Data: when you use our Service you voluntarily give us personal data that identifies you as a specific individual and can be used to contact or identify you (“Personal Data”). Examples of Personal Data include your name, your date of birth, nationality, phone number, email address, address, billing address, card number, gender, details of the organization to which you belong.
      • Special Categories of Personal Data: when you use our Service you voluntarily may provide us with personal data that in some jurisdictions (for instance in the EU) called as a “special categories of personal data”, which includes among others physical or mental health or condition, generic data and biometric data. As we mentioned some laws require that we have your explicit consent to collect and use it. Please note, by accepting this Privacy Policy, you consent and agree to the collection, use, disclosure, retention and transfer of these special categories of personal data by us.
      • Data on your Activity: When you use the Service, we may also collect information related to your feelings, your use of the Service, including your data with regard to your account information (password and username), certain transactions as well as information on your activity made through the Service. With that, information on your activity can be available to other users which will be defined by you.
      • Third Party Personal Data: you may provide us with information about your contacts or family or friends if, for example, you would like to add those contacts to a Care.Wallet or Care.Wallet for Family or similar. Such personal data about your contacts, family or friends includes: First name, last name, email address. We collect this information for the purpose of providing certain Service to them and/or you such as sharing of information, updates etc.
      • Other Data: we are trying to do our best and provide you with a good products and services quality, in which regard we may upgrade our Service and establish new partnership relations in the future, which would result in obtaining further additional data. If we start collecting new types of personal data or significantly alter the processing of your data, then relevant amendments will be incorporated into this Privacy Policy and we will notify you of such amendments.
    • Information we may collect from other sources

      • Personal Data Received from Third Parties: we may obtain your Personal Data from third parties entitled to provide such data; other organizations collaborating with us, including but not limited to, improvement, proper work, configuration, maintenance, analysis and advertising the Service. Any thirdparty services may collect information as determined by their own privacy policies.
    • Information Collected Automatically

      • Device Data: we may collect data on devices and networks used by you during the use of our Service (e.g. IP-address, URLs, GPS tracking of your current location, operating system and browser software used, Internet Service Provider, device identifiers, language and regional settings, information about the software installed on your devices). Also, we may use cookies and web beacons when you visit our Service. For more information on our use of cookies and web beacons, please refer to our Cookie Policy.
    • Identity Verification and KYC

      In some circumstances, where you hold Solve Tokens, we may ask you or otherwise collect your identity verification information.

      • Identity Verification and KYC: we may collect documents to verify your Personal Data, such as image of your government issued ID, passport, national ID card or driving license; residence verification information, such as utility bill details, phone bill or similar document; under special conditions also a social security number, to validate your identity or other information and documents as may be required by the KYC standards and applicable law and regulations.
      • Solve Tokens Transactions: if you intend to hold or if you are holding the Solve Token, we may also collect certain transaction information, such as credit card or other financial account information, and billing address, Ethereum/ Bitcoin or other cryptocurrency wallet address.
      • General Audience of Solve Tokens: the Solve Token is general audience and intended for users 18 and older. We do not knowingly collect Personal Data from Solve Token holders younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Data, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that Solve.Care has collected Personal Data from your child – a Solve Token holder, please contact us by using the details set out in Section 16 below. For more information regarding children’s data, please refer to Section 13 below.

      You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us by using the details set out in Section 16 below.

  5. Why Do We Collect Information

    We use your personal data and other your information to make it possible to accommodate your requests, and so that we are able to provide you with the Service when using (any of) our Services and for the purposes set out in this Privacy Policy. In addition, we use your personal data and other information to maintain the general and personified content and functionality of our Service.

  6. How We Use Information That We Collect

    We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to:

    • Enabling our Service: We use the Personal Data and information provided by you with the aim to (i) register you in our Service and create your user account (Care.Wallet); (ii) create your profile and make it visible inside the Service; (iii) process and complete transactions, and send you related information; (iv) provide an individual approach by providing content (for example, information from other services) within the Service, including targeted advertisement Service and partner services, which we believe may be of most interest to you; (v) notify you when your contacts (Family, friends) become active on the Service; and (vi) provide you with access to the Service and provide the requested information, products and services.
    • Technical support and security: We may use Personal Data and information to provide technical support to you, where required, and to ensure the security of our services.
    • Updates: We use Personal Data and information collected when you sign-up to send you the messages in connection with the Service or news related to it. We may also archive this information and/or use it for future communications with you, where we are legally entitled to do so.
    • Communications with or from us: When you send us an email message or otherwise contact us, we may use the information provided by you to respond to your communication and/or as described in this Privacy Policy. We may also archive this information and/or use it for future communications with you where we are legally entitled to do so. Where we send you emails, we may track the way that you interact with these emails (such as when you open an email or click on a link inside an email). We use this information for the purposes of optimizing and better tailoring our communications to you.
    • Disclosure to Solve.Care Group: We may provide the information we collect about you, including your Personal Data and information, within the Solve.Care Group of companies, including our subsidiaries and affiliates for with the aim to provide our Service properly, the proper implementation of our obligations, as well as to comply with the requirements of the law.
    • Disclosure to third parties: you agree and consent that we have the right to disclose your information including your Personal Data, to service providers and other third parties under contract who help us providing you and to other users with our Service on our behalf, or other services provided by third parties through Service (including but not limited to investigation of fraud and spam activities, site analytics, provision of special partnerships opportunities with our Service - either without identification of users, or using a unique identifier, not tied to the identity of the user). This is necessary to protect the data they receive. Please note, we will only provide the minimal amount of data required or legally requested.
    • Disclosure to our operations and maintenance contractors: We use various service providers, vendors and contractors (collectively, "Contractors") to assist us in providing our products and services to you. Our Contractors may have limited access to your Personal Data and information in the course of providing their products or services to us, so that we in turn can provide our products and services to you. These Contractors may include vendors and suppliers that provide us with technology, services, and/or content related to the operation and maintenance of the Service. Access to your Personal Data and information by these contractors is limited to the information reasonably necessary for the Contractor to perform its specific function for us.
    • Government authorities, legal rights and actions: We may share your Personal Data and information with various government authorities in response to investigation of fraud, subpoenas, court orders, or other legal process; to establish or exercise our legal rights or to protect our property; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us. We also may share your Personal Data and information when we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of Solve.Care, the Service, our users, customers, or others; and in connection with our Terms and Conditions or Terms of Use and other agreements.
    • Disclosure to Acquirers: Solve.Care may disclose and/or transfer your Personal Data and information to an acquirer, assignee or other successor entity in connection with a sale, merger, or reorganization of all or substantially all of the equity, business or assets of Solve.Care to which your Personal Data and information relates.
  7. International Transfer Of Personal Data And Information

    As mentioned above, we may share your personal data and information with third parties only in cases, where it is necessary to carry out your request, for our professional or legitimate business needs, or as required or permitted by law. Where we do transfer your personal data and information to third parties or service providers, appropriate arrangements will be made in order to ensure correct and secure data processing in compliance with applicable data protection law.

    We store personal information about our users within the European Economic Area (EEA), the United States and in other countries and territories. To facilitate our global operations, we may transfer and access such personal information from around the world, including from other countries in which the Solve.Care Group has operations. Therefore, your personal data and information may be processed outside of the EEA and in countries which are not subject to an adequacy decision by the European Commission and which may not provide for the same level of data protection as the EEA.

    We will do our best to ensure that the recipient of your personal data and information offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (Article 46 GDPR), or we will ask you for your prior consent to such international data transfers.

    We have implemented safeguards to ensure an adequate level of data protection where your personal information is transferred to countries outside the EEA, such as:

    • the European Commission’s Standard contractual clauses: We use standard contractual clauses for the transfer of personal data and information to organizations outside the EEA. These contractual commitments have been adopted by the European Commission and ensure adequate protection for personal data transferred to countries outside the EEA by binding recipients of personal data and information to certain data protection standards including obliging them to apply appropriate technical and security measures. We use standard contractual clauses when we transfer data to other Solve.Care Group companies and for transfers to recipients that are neither Privacy Shield certified nor located in a country covered by an adequacy decision.
    • Adequacy Decisions: Where the European Commission has determined that a country outside the EU offers an adequate level of data protection, personal data and information may be transferred to that third country without implementing any other safeguards mentioned above. Solve.Care may rely on adequacy decisions when transferring data to companies based in countries where such assurances have been given.
    • the EU-US Privacy Shield and Swiss-US Privacy Shield: The EU – US Privacy Shield and Swiss-US Privacy Shield are a programs agreed between the EU and US, and Switzerland and US which aims to protect the personal data of anyone in the EU or Switzerland when it is transferred to the US by placing data protection obligations on US companies that receive personal data from the EU or Switzerland. We will do our best to comply with these safeguards when transferring data to companies based in the US where those companies are Privacy Shield certified.
    • Binding Corporate Rules: Solve.Care will do its best to comply with its Binding Corporate Rules which enable us to transfer personal information lawfully from EEA member states to other Solve.Care group companies around the world and guarantee an adequate level of data protection wherever your data is physically kept.

    You can obtain more details of the protection given to your personal data and information when it is transferred outside EEA (including a sample copy of the model contractual clauses) by contacting us using the details set out in Section 16 below.

  8. Technical, Organizational And Other Measures

    Solve.Care endeavor to ensure that the data disclosed by you are as secure as possible. To that end we constantly strive to improve and introduce new number of technical and organizational measures which protect your personal data from unauthorized or unlawful processing and from unintentional loss, destruction or damage. We aim at minimizing the processing of personal data. We only process information which is indispensable or information which you provide us with your consent beyond the scope of the necessary processing.

    As mentioned above in this Privacy Policy, we disclose your personal data and information to third persons in certain cases in which we have an obligation to do so. In such cases we choose trustworthy partners of whom we can be sure they are going to apply personal data protection standards that offer at least the same level of security as those adopted by Solve.Care. When personal data is transferred to state administration bodies, we use the most suitable and the most secure options offered by the given body.

  9. Confidentiality And Security

    We consider the confidentiality and security of your information to be of the utmost importance. We will use industry standard, physical, technical and administrative security measures to keep your personal data confidential and secure and will not share it with third parties, except as otherwise provided in this Privacy Policy, or unless such disclosure is necessary in special cases, such as a physical threat to you or others, as permitted by applicable law. Due to the fact that the Internet is not a 100% secure environment we cannot guarantee the security of your intimation, and there is some risk that an unauthorized third party may find a way to circumvent our security systems or that transmission of your information over the Internet will be intercepted. Please note that e-mails communications are typically not encrypted and should not be considered secure.

  10. Your Information And Blockchain

    Solve.Care uses both public and private blockchain technology. None of your personal information is stored by us in any blockchain. The only data stored in a blockchain will be your Wallet ID, Transaction Amount, and Destination Wallet ID.

  11. Data Retention

    Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. Upon deactivation of your account or revoking your consent on processing your data, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We may keep activity data on a non-identifiable basis to improve our Service.

    Please note, we can store certain data of deactivated accounts in order to comply with legal requirements, prevent fraud, assist with investigations, resolve disputes, analyzes or troubleshoot programs, and with the aim to enforce our Terms of Use, Terms and Conditions or other agreement with you, or undertake other actions provided by law. Likewise, if your account has been closed or temporarily disabled, we can save some information to prevent your re-registration.

  12. How To Exercise Your Data Protection Rights

    You have choices when it comes to your personal data and information. Here below is a summary of those choices, how to exercise them and any limitations.

    • Right to information

      We respect the principle of transparency of personal data and information processing. In accordance with this principle we will provide information to you on the manner in which your personal/sensitive data is processed. If you wish to know in general which of your personal data we process, you may submit your request using the details set out in Section 16 below and specify the Service name via of which the data is processed.

      If you wish to find out concrete personal data which are processed directly from you, you may submit your request by using the details set out in Section 16 below and specify which concrete piece of information you require and the Service name, via of which the data is processed. The information to which you are entitled is described in Articles 13 and 14 of the GDPR. If you do not submit specific requirements, your request will be viewed as a general request.

      Please note, if we are not able to verify your identity electronically or if there is reasonable doubt as to your identity, we may ask you to submit proof of identity at our office. Your request will be handled in as short a time as possible or as applicable by law. Keep in mind that often this is a very complicated process which may take several weeks.

    • Right to accessing, reviewing, and rectification your data

      If you provide us with any of your information, please be sure to update it promptly if it changes or becomes inaccurate. If you reside or are located in the EEA, you have the right to request that we:

      • provide access to any personal data we hold about you;
      • prevent the processing of your personal data for direct-marketing purposes;
      • update any personal data which is out of date or incorrect;
      • delete any personal data which we are holding about you;
      • restrict the way that we process your personal data;
      • provide your personal data to a third party provider of services; or
      • provide you with a copy of any personal data which we hold about you.

      If you would like further information in relation to your rights or would like to exercise any of them, you may also contact us by using the details set out in Section 16 below and specifying your request and the name of Service you have used and via of which the data is processed. In certain cases, we cannot rectify your personal data. This includes cases when your incorrect or outdated personal data are contained in documents which we have to archive by law.

    • Withdrawal of consent to personal data processing and right to erasure (‘right to be forgotten’)

      If we process your personal data on the basis of your consent with such processing, you can stop their further use or processing at any time. It is your responsibility to withdraw consent to such use or processing.

      You can also exercise your right to be forgotten. In such case we apply the appropriate safeguards, these measures may include pseudonymization. Exception is cases when the processing is performed on the basis of a statutory obligation or for our legitimate interest. Also, in this case we may demand your identification before destroying the personal data.

    • Opt-out of communications

      We offer those who provide personal contact information a means to choose how we use the information provided. You may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of our marketing emails or you may send a request by using the details set out in Section 16 below. You may opt-out of receiving promotional communications from us by using this unsubscribe link within each email.

    • Other data protection rights

      If you wish to exercise any other data protection rights that are available to you under your local data protection laws (such as the right to data portability or to data restriction) then please send your request to us by using the details set out in Section 16 below and we will action your request in accordance with applicable data protection laws.

      You have the right to complain to your local data protection authority if you are unhappy with our data protection practices.

  13. Age Requirement (Children’s Privacy)

    If you are under the age of consent in your country to form a binding agreement, you should only use our Service if you are either an emancipated minor, or have the legal consent of your parent or guardian for your use of our Service. You should use our Service only if you are fully able to understand and enter into and comply with this Privacy Policy. Our Service is not intended for children under 18: if you are under 18, please wait until you turn 18 to use them.

    By using our Service, you confirm that you have reached 18 years, or the statutory minimum age established by law of your country, which allows you to enter into legally binding agreements or to act without the consent of both parents or guardian.

    We encourage parents and legal guardians to monitor their children’s internet usage and to help enforce this Privacy Policy by instructing their children never to provide personal information through the Website or Services without their permission. If you have reason to believe that a child under the age of 18 has provided personal information to us through the Website or Service, please contact us by using the details set out in Section 16 below, and we will use commercially reasonable efforts to delete that information.

  14. Additional Terms And Conditions For Certain Regions
    • Australia:

      Personal information collected, stored, used and/or processed by the Solve.Care Group, as described in this Privacy Policy, is collected, stored, used and/or processed in compliance with the Australian Privacy Act 1988 (Commonwealth) and the Australia Privacy Principles. If you are dissatisfied with our handling of a complaint or do not agree with the resolution proposed by us, you may make a complaint to the Office of the Australian Information Commissioner (“OAIC”) by contacting the OAIC using the methods listed on their website at Alternatively, you may request that we pass on the details of your complaint to the OAIC directly.

    • Brazil:

      Personal information collected, stored, used and/or processed by Solve.Care Group, as described in this Privacy Policy, is collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. Those individuals who use or access our Services expressly consent to the collection, use, storage and processing of their personal information by us for the purposes described in this Privacy Policy.

    • Canada:

      Personal information (as the term is defined in the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”)) will be collected, stored, used and/or processed by the Solve.Care Group in compliance with the Solve.Care Group’s obligations under PIPEDA.

    • California (USA):

      Personal information collected, stored, used and/or processed by the Solve.Care Group, as described in this Privacy Policy, is collected, stored, used and/or processed in compliance with California’s "Shine the Light" Law, according to which California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the your information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared your information for the immediately prior calendar year (e.g. requests made in 2018 will receive information regarding 2017 sharing activities).

      To obtain this information, please email us by using the details set out in Section 16 below with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your e-mail address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.

    • New Zealand:

      Personal information collected, stored, used and/or processed by the Solve.Care Group, as described in this Privacy Policy, is collected, stored, used and/or processed in compliance with New Zealand’s Privacy Act 1993 and its 12 Information Privacy Principles (“NZ IPPs”).

    • Singapore:

      Personal information collected, stored, used and/or processed by the Solve.Care Group, as described in this Policy, is collected, stored, used and/or processed in compliance with the Solve.Care Group’s obligations under the Personal Data Protection Act 2012 of Singapore (“PDPA”).

  15. Changes To Our Privacy Policy

    This Privacy Policy may be updated from time to time to reflect changing legal, regulatory or operational requirements. We encourage you to periodically review this page for the latest information on our privacy practices.

    If there are any essential changes to this Privacy Policy, you will be notified by our posting of a prominent notice on the Website or Service or to your email address of record prior to the change becoming effective. If we are required by law to do so, we will seek your consent prior to those essential changes becoming effective.

    If you do not accept any changes made to this Privacy Policy, please discontinue use our Website and any of our Services.

  16. Contact Us

    If you have any questions regarding this Privacy Policy or about the Solve.Care Group’s privacy practices, please contact us by email at [email protected] or at:

    Solve.Care Foundation OÜ
    Attn: Chief Data Protection Officer
    Narva mnt 5, Tallinn 10117, Estonia
    [email protected]

    Solve.Care’s United States Representative:
    Solve.Care USA INC.
    Attn: Chief Privacy Officer
    16192 Coastal Highway, Lewes, Delaware 19958, USA
    [email protected]

  17. English Version Controls

    Non-English translations of this Privacy Policy are provided for convenience only. In the event of any ambiguity or conflict between translations, the English version is authoritative and controls.