Privacy notice
1. Who is responsible
21 Property Finder Ltd, Nicosia, Cyprus, is the controller of the personal data in the 21myWallet sandbox. Contact for any privacy question: paris@21finder.com.
2. What we collect
- From your 21 ID: your name, e-mail address and 21 ID number (and your mobile number, if you gave it to 21 ID).
- In the sandbox: your simulated account number and card number, every simulated movement (amount, date and time, the other member's name, your note), the date you accepted the terms, and a one-way hash of your PIN — never the PIN itself.
- For security: an audit log of actions with your IP address and browser type.
- Cookies: one session cookie that keeps you signed in and one cookie that remembers your language. Both are necessary for the service. We use no advertising or tracking cookies.
3. Identity verification data
If you verify your identity we process: your name as on the document, date of birth, nationality, issuing country, document type, expiry date and the last four characters of the document number plus a keyed one-way hash of the full number (used only to detect the same document being used twice).
Test mode: the check is simulated, no document image is requested or kept, and you must use sample data.
Real mode: the photo of the document and the selfie are encrypted when stored, can be opened only by an authorised administrator (each opening is logged), and are deleted when the decision is made. If a law requires us to keep identity records in a licensed service, we will tell you before that begins.
We ask for your explicit consent before you submit identity details.
4. Why we use it, and on what basis
- To run the sandbox you asked to use (performance of the service you requested).
- To keep it secure, prevent abuse and investigate faults (our legitimate interest).
- To verify your identity (your consent).
- To improve the software from what testers do and tell us (our legitimate interest).
5. Who sees it
- Other members see only your name (and e-mail address or account number if you share it) on a transfer between you.
- Authorised administrators of the 21 Group see accounts, movements and the audit log to run and secure the sandbox.
- Our hosting provider stores the data for us. We do not sell your data and do not use it for advertising.
6. How long we keep it
Sandbox data is kept while the sandbox runs and is then deleted or anonymised. You can ask for deletion earlier at any time. Security logs are kept only for a limited period. Identity document images are deleted at the decision (see section 3).
7. Security
Sign-in goes only through 21 ID; PINs are stored as one-way hashes; documents are encrypted when stored; connections use HTTPS; money movements are protected by tokens, limits and an audit trail.
8. Your rights
You have the right to access your data, correct it, have it deleted, restrict or object to its use, receive a copy in a common format, and withdraw your consent at any time (without affecting what was done before). Write to paris@21finder.com and we will answer within one month.
You may also complain to the supervisory authority: the Office of the Commissioner for Personal Data Protection, Cyprus — dataprotection.gov.cy.
9. Changes
We will update this notice when our use of data changes. Version 1.0, 04/10/2026.