Privacy Policy

Version dated 11 November 2026.

Who we are

WEB3 DIGITAL WALLET, a French SAS, SIREN 910 399 435, registered with the Chartres Trade and Companies Register, operates Wallet Connectors. Its registered office is at 112 rue des Tuileries, 28260 Saint-Ouen-Marchefroy, France. For personal data enquiries: contact@talao.io.

This policy is for site visitors, customer contacts and representatives, and people using issuance or verification journeys. It supplements the Terms and Conditions.

Responsibilities and purposes

WEB3 DIGITAL WALLET processes data necessary to provide, administer and secure Wallet Connectors. Customers determine the purposes of the operations they request and inform the individuals concerned.

Processing on customer instructions is governed by a data processing agreement meeting Article 28 GDPR. WEB3 DIGITAL WALLET acts as controller for its own customer relationship management and security purposes. An EUDI intermediary role does not, by itself, determine the GDPR role for each processing activity. [7]

Data processed

Depending on the service, data includes:

• professional contact details and information needed for the customer relationship;
• information required to issue the EAA requested by the customer;
• attributes presented for verification and check results;
• sign-in references needed for the service and, where applicable, a verified email;
• technical information necessary for operation, security and handling rights requests.

Information requested depends on the purpose. An age proof does not require the same data as identity verification or another attestation. Approval to present data in a wallet does not automatically provide a legal basis for every subsequent customer use.

Selective disclosure and data minimisation

Selective disclosure makes it possible to present particular attributes from an attestation without sharing all the information it contains. For example, an “18 or over” proof can answer an age-threshold request without transmitting a name or date of birth. The exact options depend on the attestation, its format and the wallet used. [1, 9]

Example: checking that someone is an adult. In the dedicated “18 or over” journey, the user authorises their wallet to transmit only confirmation that they meet this age threshold, together with the information necessary to verify that proof. WEB3 DIGITAL WALLET receives neither the user's date of birth nor their name or other identity attributes in this presentation and has no access to those details remaining in the wallet. The company verifies the authenticity of the age proof without needing to know the person's identity.

This limitation concerns the age presentation: technical information needed to operate and secure the service is processed separately. The customer application may also know its user through its own account; this does not mean that the wallet has disclosed their identity to Wallet Connectors.

Wallet Connectors supports limiting requests to information necessary for the customer's service. Customers must justify each requested item and choose a less detailed proof where it meets their purpose. Undisclosed information is not communicated to Wallet Connectors in the presentation; authenticity can be checked without receiving the other attributes where the format supports this. This protection reduces data exposure; it does not mean that every presentation is anonymous or cannot be linked to an account or other operations.

Authorising sharing in the wallet

The wallet provider manages how a request is displayed, how attestations are selected and how the user authorises or declines their presentation. To understand the information displayed, available choices, authentication methods and arrangements for obtaining agreement, users should consult their wallet provider's user documentation, Privacy Policy and terms, available through the wallet or the provider's official website.

This authorisation journey within the wallet is supplied and managed by its provider and is outside the verification service provided by WEB3 DIGITAL WALLET. Wallet Connectors does not choose for the user and cannot authorise a presentation on their behalf. Agreement in the wallet concerns the sharing shown to the user; it is not general consent to subsequent uses or a waiver of personal data rights.

Our role in verification

In this journey, Wallet Connectors acts as a technical intermediary to verify presentations and transmit the authorised result to the customer application. Checks concern cryptographic signatures, integrity, validity and attestation provenance, together with applicable trust and registration information for issuers and organisations requesting data, depending on the attestation type and supported service. Certificates and register information help identify the participants and declared purposes. [2–6]

Registration checks depend on the applicable framework and availability of the relevant registers and trust services. A successful result must not be interpreted as a general guarantee that every participant is registered in all registers or as certification of the entire journey. Wallet providers remain responsible for their own journey; customers remain responsible for their requests and use of results. WEB3 DIGITAL WALLET remains responsible for security and protection of the data it processes within its own scope.

Artificial intelligence connectors and assistants

Minimal results and user protection

Age connectors give the AI application a status and, only after success, age_over_18=true. The application also receives the temporary references and private link needed to start the journey where it initiates verification. The result contains no name, date of birth, complete credential or OIDC token. The private link must not be published. These data can nevertheless be linked to an account, conversation or action and are not necessarily anonymous.

Local MCP connector: Claude Desktop, Codex and local models

The connector runs on the user's computer and communicates with an MCP-compatible host application. It does not itself send conversation history to a model provider. The host may use a remote model and process tool results under its own rules. Running a model locally does not make the Wallet journey offline: sign-in and verification services still require network access.

Local connector references and state remain in process memory. A request can be used for at most five minutes and a result no later than its expiry. Cleanup takes place on connector access; closing the process clears that in-memory state, but not copies retained in the host application's conversation.

Remote MCP server intended for ChatGPT

The prepared remote service uses OAuth authentication separate from age proof. Account and application references isolate users; verification state is encrypted. Authenticating the AI account does not establish that its user is the Wallet holder. This description announces neither deployment nor validation in ChatGPT nor directory approval.

Retention and erasure arrangements for this journey will be specified before it is made available. This description does not change the retention commitments applicable to services already offered.

Talao Events demonstration: conversation sent to OpenAI

Talao Events is separate from the generic MCP connector. After explicit agreement, conversation messages and replies, minimal verification status and the successful age result are sent to the OpenAI API to suggest fictional events and explain age verification. No ticket, purchase or reservation is made. The service sends OpenAI no Wallet credential, identity attribute, OIDC token, private verification link or verification reference. Do not enter personal data, identity documents or secrets in the conversation: information you type is transmitted.

WEB3 DIGITAL WALLET processes the conversation to provide the demonstration; OpenAI receives the data needed for the AI response under the terms applicable to the API used. Our conversation state is encrypted and expires fifteen minutes after its last save. “Start over” clears current conversation state; it does not delete data already sent to providers or all other Wallet journey records. Conversation expiry does not delete other verification journey records, which follow the retention periods stated in this policy. Abuse-prevention counters have windows ranging from one minute to twenty-four hours. Logs and backups follow the separate arrangements in this policy.

The API's response non-storage option (store=False) does not mean zero retention. OpenAI's rules include abuse-monitoring logs retained by default for up to thirty days, subject to applicable exceptions and controls. This option does not guarantee activation of Zero Data Retention. [13]

Our Paris hosting does not guarantee that AI-provider processing stays in France or the EEA. No European residency, special retention period or specific contractual guarantee is claimed for OpenAI without confirmation of its configuration and applicable transfer safeguards. Official OpenAI API data controls describe the available controls; availability does not establish activation. Conversation sharing is optional: without agreement, this demo sends no message to OpenAI. To stop, cease sending messages and start over; rights requests remain available at contact@talao.io.

AI application rules and limits of age proof

Each AI application applies its own retention and processing rules to received conversations and results. Consult its policy and account settings, including Claude connector documentation and Anthropic's information on data use. Rules may differ by offering and user choices. WEB3 DIGITAL WALLET's commitment not to use data for training is not a general guarantee covering all AI providers. [14]

Age proof does not establish that the Wallet holder authored the conversation. Assistant text, age assertions or screenshots do not replace verification. Customer applications must enforce access decisions server-side. EUDI obligations and restrictions on storing transaction content remain unchanged.

Shopify app: service-specific data and journeys

The EUDI Wallet Age Verification app has a service-specific privacy notice and a merchant data processing agreement, version 2026-10-30-v1. They detail the commitments applicable to this service and supplement this policy; this page replaces neither those texts nor their acceptance by each merchant.

The connector processes the store domain and identifier, Shopify customer identifier, configuration, technical tokens and credentials needed for the connection, temporary browser/sign-in bindings, the 18+ authorisation and its validity date. Tokens and credentials remain server-side. Rights requests sent by Shopify may include additional data contained in their payload. Where human review is available and enabled by the merchant, the service also processes review cases: customer identifier, optional explanation, status, response and dates. Acceptance receipts record information including the store, version, accepted texts, digest, language, date and merchant-session type.

The absence of a name and date of birth concerns the presentation from the wallet. It does not mean the app processes no personal data: Shopify identifiers and technical data are also processed. An age check does not establish that the wallet holder legally owns the Shopify account. Declining a new presentation does not automatically revoke an earlier authorisation that remains valid.

Shopify app retention periods

The general seven-day maximum must not be interpreted as universal deletion of every record and copy in the Shopify journey. The specific rules in the approved notice remain applicable:

Transaction expiry does not delete verification history. Technical logs, older shared records and other components' backups have separate arrangements; the above measures do not guarantee their erasure within seven days. Missed or failed cleanup runs may delay deletion and require follow-up. Shopify's copies follow its own rules. EUDI intermediary obligations concerning transaction content continue to apply.

Requests received from Shopify: thirty-day commitment

Actions following Shopify compliance notifications requesting data access or erasure are completed within thirty days of receipt. Where a legal obligation requires retention and prevents erasure, the affected data is not erased, in accordance with Shopify's exception. [11]

Technical acknowledgement does not establish completion. Requests requiring intervention are tracked until the actions are performed and checked. This Shopify commitment is separate from the general GDPR deadlines below and does not automatically benefit from their possible extensions.

Decisions and human review in a store

Merchants choose restricted products and are responsible for access-to-sale decisions. Without valid authorisation, checkout for restricted products is blocked. Integrated human review is optional: it must be made available for the service and expressly enabled by each merchant, who commits to checking requests each business day and providing a personal, reasoned answer after verification. It is not offered in every store and no automatic email alert is promised.

WEB3 DIGITAL WALLET provides the form and case tracking; merchants perform the review. A request alone does not allow checkout and approval is not guaranteed. Approval creates a daily merchant authorisation, not a cryptographic wallet proof. Disabling new requests does not remove the duty to handle existing cases.

Where automated decisions may have legal or significant effects, Shopify requires customers to be able to opt out and have their data manually processed. Merchants and the provider must ensure the applicable safeguards are actually available for the use concerned. The ability to decline the wallet, or merchant responsibility alone, does not establish compliance with this requirement. [10]

Moodle plugins: authentication and issuance

The auth_eudiwallet and local_eudiissuer plugins serve separate purposes. The institution operating Moodle determines its site's uses, access permissions, information and retention periods. The hosted Wallet Connectors service acts within the scope agreed with that institution. Applicable processing terms must be established with the institution where WEB3 DIGITAL WALLET processes data on its behalf; installing a plugin does not itself establish that such an agreement has been concluded.

Signing in to Moodle with a wallet

The authentication plugin uses the external sign-in service configured by the institution. Its administrator registers the application and configures its credentials and callback address. The service receives application references and technical information needed for a secure sign-in. The plugin does not send it Moodle passwords, courses or grades.

After PID presentation and, where requested, separate email verification, Moodle receives authorised information: a sign-in identifier and authorised profile attributes, including first name, last name and verified email. The PID issuer does not certify the email. The plugin stores neither a copy of the PID credential nor a date of birth. Moodle may retain received attributes in the created profile and a binding to the account under the institution's rules. Temporary sign-in state expires after fifteen minutes and is cleaned by Moodle scheduled tasks.

Wallet Connectors' retention of the verified email follows the “Additional email verification” section. This is separate from its presence in the Moodle profile, whose retention period is determined by the institution.

Issuing badge attestations

The issuance plugin directly uses the issuance service configured by the institution. Authorised service access and an issuer configuration are required; sign-in plugin credentials do not replace them. At the learner's request, the plugin sends first and last name from the Moodle profile, an award reference and badge information: identifier, title, description, criteria, organisation and award date. It sends neither email, Moodle user identifier nor detailed grades. Names come from the institutional profile: this journey is not a new PID identity verification.

The retrieval offer is valid for five minutes. Moodle temporarily stores the encrypted offer and cleans it after expiry or confirmed issuance; tracking references and statuses remain subject to the institution's retention rules. The wallet receives the attestation; the wallet provider's and issuer's rules respectively govern its storage and validity. Issuance concerns non-qualified EAAs.

Rights, erasure and revocation

Requests concerning accounts, profiles and information held in Moodle should be addressed to the institution. Requests concerning data processed by Wallet Connectors may be sent to contact@talao.io and are coordinated with the institution where it is the controller. Deleting a Moodle account or reference does not automatically erase provider-held data, remove an attestation from a wallet or revoke it. Revocation is the issuer's responsibility under the applicable status mechanism; deletion of a wallet copy is handled by its holder and provider.

Additional email verification

In a PID-based identity journey, the customer application may request additional email verification. A one-time code verifies control of the address. This check is separate from the PID: the identity issuer does not certify the email.

The email address and associated verification data are retained for no more than seven days from verification, without extending this period on reuse. The verification code has its own short validity period. The receiving application explains its own retention and uses.

Retention

Shopify-specific periods are detailed in the “Shopify app” section and its approved notice; rights and human-review cases are not subject to universal seven-day deletion.

Information processed as an intermediary that may lawfully be retained is kept for no more than seven days; information no longer needed is deleted sooner. This maximum does not authorise storage of transaction content where Article 5b(10) eIDAS prohibits it. The data concerned may only be processed in compliance with that restriction. [1]

Customer administration, billing and registration information serves separate purposes and follows the periods needed for those purposes and applicable legal obligations. Service-specific arrangements specify applicable retention periods, including backups. Deletion by Wallet Connectors does not erase information already received and independently retained by a customer application.

Hosting and recipients

The platform is hosted by Amazon Web Services (AWS) in Paris, France. Access is restricted to authorised persons and providers necessary for service delivery. Customer applications receive only information provided for their authorised use.

Professional information needed for regulatory registration may be sent to competent bodies. Some registration information is public under the rules governing the relevant registers. [2–3]

Hosting in France does not, by itself, exclude international transfers involving other providers. Any relevant transfer must have applicable safeguards and be described in the information for the service. [7]

Data protection by design and by default

Under Article 25 GDPR, WEB3 DIGITAL WALLET integrates data protection into service design and operation. Measures limit the information collected, its uses, retention and accessibility. They are appropriate to risks and reassessed when the service changes. [7–8]

Security includes confidentiality, protection of communications, access controls and deletion measures. Customers receive the assistance provided for in their contract to meet their own obligations.

Choices, rights and contact

Users may decline a presentation. Declining prevents a new verification result and may prevent access to a service requiring it. Customers explain these consequences and the applicable opportunities to challenge decisions or obtain human review.

Subject to legal conditions, individuals have rights of access, rectification, erasure, restriction, objection and portability, and may withdraw consent where processing relies on it. Requests about customer purposes should be addressed to the customer. WEB3 DIGITAL WALLET can be contacted at contact@talao.io for its own processing or help directing a request. Complaints may be lodged with the CNIL or another competent supervisory authority. [7]

Legal bases and required information

For its own processing, WEB3 DIGITAL WALLET relies, as applicable, on performance of a contract where the individual is a party, its legitimate interests in managing professional relationships, responding to enquiries and protecting the service, or legal obligations, including accounting obligations. Where processing relies on consent, its purpose and withdrawal arrangements are explained when consent is sought. Customers determine the legal basis for processing entrusted to us. [7]

Without necessary information, it may be impossible to answer an enquiry, create professional access or perform issuance or verification. Optional fields are identified in the relevant journeys.

Limited use and no sale

Journey data is not sold or used by WEB3 DIGITAL WALLET for advertising or training artificial intelligence models. Use is limited to the stated purposes and customer instructions where the customer is controller.

Website, preferences and external services

The website uses a language-preference cookie. Sign-in and administration journeys use the means necessary for session continuity and security. Servers receive information including IP address, request time, requested resource and technical browser information necessary to provide and protect the service.

The website offers YouTube-hosted videos and links to Typeform forms. Using these services involves processing by their providers. An embedded video player may communicate technical information to its provider even before playback. For general offerings outside the Shopify app, where payment through Stripe is offered, Stripe processes information necessary for billing and payment; wallet-presented attributes are not sent to it for billing.

Consult the notices of YouTube and Google, Typeform and Stripe when using these services. Platforms integrated with Wallet Connectors, including Shopify, and wallet providers separately explain their own processing.

Payment data for general offerings

For payments through Stripe, we send it the professional billing email and an application reference needed to associate the subscription. Stripe collects payment details, the billing address and any required tax information. We retain the references and status needed for billing administration without storing full card numbers in the platform. Wallet attestations and their attributes are not sent to Stripe for payment. Consult Stripe's Privacy Policy for its own purposes, recipients, retention and transfer safeguards; the seven-day verification-data maximum does not apply to all payment data.

Where another payment method is agreed, only information necessary to execute and reconcile payment and meet accounting obligations is processed. Customers are informed of any recipient provider and the conditions applicable to the chosen method. These payment options are not an external billing mechanism for the Shopify app.

Decisions and remedies

Wallet Connectors supplies a verification result; the customer application determines its consequences. Where the result conditions a decision with legal or similarly significant effects, the customer must provide the safeguards and remedies required by law. Human review, where offered, is carried out by the organisation responsible for the decision. Declining a presentation is not, by itself, a request for human review. [7]

Responding to requests and updates

Rights requests are handled within GDPR deadlines, normally within one month of receipt. An extension may be needed where legally permitted; the person is informed. Only information necessary to verify the requester is required.

Material policy changes are communicated to the individuals concerned by appropriate means. The update date identifies the applicable version.

References

1. Regulation (EU) 2024/1183 amending eIDAS, including Article 5b.
2. Implementing Regulation (EU) 2025/848, registration of wallet-relying parties, as amended.
3. Implementing Regulation (EU) 2026/1730, amending Regulation 2025/848.
4. ETSI TS 119 411-8 V1.1.1, EUDI wallet-relying party access certificates.
5. ETSI TS 119 475 V1.2.1, wallet-relying party registration information and certificates.
6. ETSI TS 119 472-2 V1.3.1, attestation and person identification data presentations.
7. General Data Protection Regulation, including Articles 5, 6, 12–22, 25, 28 and 32.
8. EDPB: final Guidelines 4/2019 on Article 25.

9. Implementing Regulation (EU) 2024/2982, as amended notably by Regulation (EU) 2026/1731, EUDI wallet protocols and interfaces, including selective disclosure.

10. Shopify: protected customer data, including automated decisions and merchant agreements.

11. Shopify: compliance notifications and thirty-day deadline.

12. Shopify: privacy requirements.

13. OpenAI API data controls.

14. Claude connectors, consumer data use / commercial data use.