Privacy Notices

Privacy Notice

TOPPAN Wallet

TOPPAN Security provides this Privacy Notice to demonstrate our commitment to protecting your privacy. This Notice applies to your use of the TOPPAN Wallet on a mobile device.

You should bear in mind that your use of the TOPPAN Wallet is at the request of a TOPPAN Security customer ("TOPPAN Security Customer"). The TOPPAN Security Customer may collect and use your personal data independently of TOPPAN Security. This Privacy Notice does not apply to any personal data you provide directly to the TOPPAN Security Customer.

Changes to the privacy notice

This Privacy Notice may be updated from time to time for any reason. You are advised to consult the Privacy Notice regularly for changes via the TOPPAN Wallet. By continuing to use the TOPPAN Wallet after such notifications, you expressly acknowledge and accept the changes.

What information does the TOPPAN Wallet obtain, and how is it used?

When you install and use the TOPPAN Wallet, we do not collect any data. If we need to collect information or access certain parts of your device, we will first inform you and/or ask for your consent (as applicable), and the data will only be used in accordance with this Privacy Notice.

Does the TOPPAN Wallet collect precise real-time location information of the device?

No. Enabling Location Services on the device is voluntary and necessary for BLE data transfer. We do not collect precise real-time location information of the device.

These services are used by the device to optimize the App's ability to communicate with readers over the BLE communication protocol. The App accesses, but does not store, your device's location data to determine your current location in conjunction with presenting a Mobile ID to a reader.

Does the App connect to a web service?

The user may trigger the App to connect to the Internet when:

  • A credential document is being provisioned
  • A check for updates or revocation of a provisioned credential is requested
  • Involved in a transaction with a web service

    • Do third parties see and/or have access to information obtained by the TOPPAN Wallet?

    No

    What are my opt-out rights?

    Opt out of information collection by uninstalling the TOPPAN Wallet – You can stop the collection and access of information by the TOPPAN Wallet by uninstalling it. You may use the standard uninstall processes available on your mobile device or through the mobile application marketplace or network.

    Managing your information

    Requests to manage your information should be directed to the TOPPAN Security Customer, who is the controller of your data.

    Children

    We do not use the TOPPAN Wallet to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, they should contact us at: info@toppansecurity.com. We will delete such information from our files within a reasonable time.

    Security

    We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect the information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know it in order to operate, develop, or improve our application. Please be aware that, although we endeavor to provide reasonable security for the information we process and maintain, no security system can prevent all potential security breaches.

    Users in the European Union

    If you're a user in the European Union, you should know that TOPPAN Security is the processor of your personal information, which means that we are providing a service to a TOPPAN Security Customer. Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons, which will be provided to you, if applicable, at the time of your request.
  • Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object to processing on this ground, as you feel it impacts your fundamental rights and freedoms. You also have the right to object when we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
  • Request restriction of the processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy (b) where our use of the data is unlawful, but you do not want us to erase it (c) where you need us to hold the data even if we no longer require it, as you need it to establish, exercise, or defend legal claims (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.

    • International transfers

    TOPPAN Security may process personal information related to individuals in the European Union (EU) and may transfer that information from the EU under data processing agreements based on the EU Standard Contractual Clauses. We are committed to ensuring your information is protected and apply safeguards in accordance with applicable law. Data collected in the EU and the European Economic Area (the "EEA") may be stored, processed, or transferred outside of the EEA.

    Complaints

    If you're based in the EU, you can file a complaint with the supervisory authority in your Member State. For example, if you're based in Ireland, you can file a complaint with the Data Protection Commission.

    Last Updated: February, 2026