-
INTRODUCTION
- 1.1. The Company is committed to
being a
responsible custodian
of the information you provide to us and the information we collect in the course of
operating our business. This Privacy Policy describes how the Company may collect and
process information received by us in relation to the operation of our Website
(walleti.com), our mobile application and generally in the course of the provision of
Services as outlined in the Terms of Service.
- 1.2. Your Personal Data is processed
in
accordance with the
BVI Data Protection Act 2021
, the
General Data Protection Regulation (Regulation EU
2016/679, further - “the GDPR”) and other relevant legislation with respect to the
accepted principles of good information handling (collectively referred to as the “Data
Protection Legislation”).
- 1.3. This Privacy Policy shall be
governed
by the laws of the
British Virgin Islands.
- 1.4. A list of data protection
authorities
in EU jurisdictions
is available here.
- 1.5. For all intents and purposes,
the
English language
version of this Privacy Policy will be the original, governing instrument. In the event
of any conflict between the English language version of this Privacy Policy and any
subsequent translation into any other language, the English language version will govern
and control.
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DEFINITIONS
- 2.1. “Company”
means
WALLETI
LTD., a company incorporated in the British Virgin Islands with company number
2093763, whose registered office address is Craigmuir Chambers, PO Box 71, Road Town,
Tortola, British Virgin Islands, which operates the Website available at walleti.com and
the mobile application (referred to as “we”, “us” and “our” hereinafter);
- 2.2. “Website”
means the website operated by the Company and available at walleti.com;
- 2.3. “Privacy
Policy” means
the latest
version of the Company’s Privacy Policy which describes our policies and procedures
pertaining to the collection, use, and disclosure of your Personal Data;
- 2.4. “Personal
Data” means
any information
“Personal Data” means any information
relating to the User, which identifies or may identify the User;
- 2.5. “User” means
an
individual or a legal
entity that has read and agreed to the Terms of Use and the Privacy Policy and uses the
Services provided by the Company through our Website and our mobile application
(referred to as “you” or “yours” hereinafter);
- 2.6. “Services”
means the
services provided
by the Company and available to Users via the Website and the mobile application as set
out in detail in the Terms of Use.
-
INFORMATION WE COLLECT
- 3.1. When you engage with us, we
collect
and process your
Personal Data, which includes as follows:
- 3.1.1. Personal
identification
information, including
your name, e-mail address, phone number, country, full address and date of
birth;
- 3.1.2. Data collected in
connection
with “Know Your
Customer” (KYC) compliance, “Anti-Money Laundering” (AML) compliance
and “Counter-Terrorist Financing” (CTF) compliance, including but not limited
to:
- 3.1.2.1. Your full
name;
- 3.1.2.2. Your
residential
address;
- 3.1.2.3. Your
contact
details (telephone number,
email address);
- 3.1.2.4. Your date
and
place of birth, gender, place
of citizenship;
- 3.1.2.5. Your bank
account
information and/or credit
card details;
- 3.1.2.6. Your status
as a
politically exposed
person;
- 3.1.2.7. Source of
funds
& proof of address;
- 3.1.2.8. Passport
and/or
national driver’s license
or government-issued identification card to verify your identity.
- 3.1.3 Device and website
usage
data, including: IP
addresses; language preferences and other device identifiers; information
relating to your access to our Website and our mobile application, such as
device characteristics, date and time.
-
HOW WE COLLECT YOUR DATA
- 4.1. We collect Personal Data
directly from
you when you use
our Website and/or our mobile application, communicate with us, or interact directly
with us. For example, direct collection of your Personal Data occurs when you complete
the contact form on our Website and/or our mobile application or when you contact us via
email.
- 4.2. We use industry standards for
automatically collecting
certain information about visitors to our Website and the users of our mobile
application. We collect information about you, or information collected by cookies and
similar technologies, when you use, access, or interact with our Website and/or our
mobile application. We shall ensure that the processing is proportionate and that we
have carried out a legitimate interest impact assessment. To the extent that the use of
cookies or similar technologies requires your consent, we may also process your Personal
Data based on your consent.
- 4.3.
When you create an account with us we perform checks at:
- 4.3.1. Credit reference
agencies to
verify the identity
information you have provided to us, as part of complying with our legal duties.
These checks consist of a ‘soft search’ and do not impact your credit score.
- 4.3.2. KYC (Know Your
Customer) and
AML (Anti Money
Laundering) service providers, as part of complying with our legal duties.
- 4.4.We also may collect information
about
you from
third-party sources, including but not limited to, the following channels:
- 4.4.1. marketing partners
and
resellers;
- 4.4.2. advertising partners
and
analytics providers;
- 4.4.3. public databases,
credit
bureaus and ID
verification partners;
- 4.4.4. social networks (for
example,
Twitter).
- 4.5. We protect the Personal Data
obtained
from third parties
according to the practices described in this Privacy Policy and we also apply additional
restrictions imposed by the source of data.
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THE PURPOSES OF COLLECTING YOUR PERSONAL DATA
- 5.1. The Company collects your
Personal Data
for the following
purposes:
- 5.1.2.To enable you to use
our Website and/or our
mobile application and the Services provided through those, to create an account
or profile, to process information you provide via our Website and/or our mobile
application (including verifying that your email address is active and valid);
- 5.1.3.To detect and prevent
potentially prohibited or
illegal activity relating to the Company’s Services;
- 5.1.4.To tailor content,
recommendations, and
advertisements that we and third parties display to you, both on the Website and
our mobile application and elsewhere online;
- 5.1.5.To contact you in
response to
your inquiries,
comments and suggestions;
- 5.1.6.With your consent, to
provide
you with
information, products, or services that we otherwise believe will interest you,
including special opportunities from us and our third-party partners;
- 5.1.7.To contact you with
administrative communications
and, in our discretion, changes to our Privacy Policy, Terms of Use, or any of
our other policies;
- 5.1.8.For internal business
purposes, such as to
improve our Website and/or our mobile application;
- 5.1.9.To issue invoices and
collect
fees for the use of
our Services;
- 5.1.9.To comply with our
policies
and obligations,
including, but not limited to, disclosures and responses in response to any
requests from law enforcement authorities and/or regulators in accordance with
any applicable law, rule, regulation, judicial or governmental order.
- 5.2.Your Personal Data, whether
public or
private, will not
be sold, exchanged, transferred, or given to any other company for any reason
whatsoever, without your consent, other than for the purpose of delivering the requested
services and improving our services.
-
PROVIDING YOUR PERSONAL DATA TO OTHERS
- 6.1.As a general principle, we
collect and
process Personal
Data in order to facilitate or improve the Company’s services or offers. We do not sell
your Personal Data or share it with third parties, except to the extent stated in this
Privacy Policy.
- 6.2.For behaviour statistics and
business
intelligence we use
the services of Google LLC (“Google Analytics”), a company located in the United States.
Your Personal Data that we may provide to Google Analytics may include your IP address,
and that data is used by Google Analytics to generate information about your usage of
our service.
- 6.3.We may share your Personal Data
with the
following third
parties:
- 6.3.1.Third-party vendors
providing
services on our
behalf, including advertising, analytics, research, customer service, service
support, data storage, validation, security, fraud prevention, and legal
services. Such third-party vendors have access to perform these services but are
prohibited from using your Personal Data for other purposes;
- 6.3.2.Law enforcement bodies
and
other external parties
(including but not limited to authorities that stop financial crime, money
laundering, terrorism and tax evasion; the police, courts or other dispute
resolution bodies; banks and other financial institutions for the purposes of
fraud investigations, etc.) where such disclosure is necessary for compliance
with a legal obligation to which we are subject, or in order to protect your
vital interests and/or the vital interests of a third-party;
- 6.3.3.Other third parties
subject to
your consent.
- 6.4.When we disclose your Personal
Data to a
third party, we
take all reasonable steps to ensure that those third parties are bound by
confidentiality and privacy obligations with respect to the protection of your Personal
Data. The disclosure is conducted in compliance with legal requirements, including
entering into data processing agreements with the relevant third parties, to ensure that
Personal Data is only processed in accordance with our instructions, applicable laws and
regulations and for the purpose specified by us and to ensure adequate security
measures.
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STORAGE AND DELETION OF PERSONAL DATA
- 7.1.The Company will retain your
Personal
Data for as long as
we shall deem it necessary to enable you to use our Website and our mobile
application and to provide Services to you, to comply with applicable laws (including
those regarding document retention), resolve disputes with any parties and otherwise as
necessary to allow us to conduct our business.
- 7.2.The legal basis for retaining
your
Personal Data is the
Company’s legitimate interest to protect our rights in the light of potential legal
disputes during the limitation period under law.
- 7.3.If we have collected your
Personal Data
in relation to
your inquiry to us, we retain your Personal Data for up to three (3) years from
collection, unless the other provided by this Privacy Policy.
- 7.4.Notwithstanding anything to the
contrary
in this Section,
we may retain your Personal Data where such retention is necessary for compliance with a
legal obligation to which we are subject to, or in order to protect your vital interests
or the vital interests of another natural person.
- 7.5.When the Company no longer needs
to keep
your Personal
Data, it will securely delete or destroy it.
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PROTECTION OF PERSONAL DATA
- 8.1.Your Personal data integrity is
of high
concern to us. We
follow the standard practices within the industry to protect the Personal Data that we
collect and maintain, including using Transport Layer Security (TLS) to encrypt
information as it travels over the internet. We have therefore implemented technology
and security policies and procedures intended to reduce the risk of accidental
destruction or loss, or the unauthorized disclosure or access to, such information,
reasonably appropriate to the nature of the data concerned; unfortunately, however, no
data transmission over the Internet can be guaranteed to be 100% secure.
- 8.2.We implemented a number of
additional
security measures
to ensure that your Personal Data is not lost, abused, or altered, including, but not
limited to:
- 8.2.1.Physical measures,
which means
that materials
containing your Personal Data will be stored in a locked place.
- 8.2.2.Electronic measures,
which
means that computer
data containing your Personal Data will be stored in the computer systems and
storage media that are subject to strict log-in restrictions.
- 8.2.3.Management measures,
which
means that only
authorized employees are permitted to come into contact with your Personal Data
and such employees must comply with our internal confidentiality rules for
Personal Data. We have also imposed strict physical access controls to buildings
and files.
- 8.2.4.Technical measures.
- 8.3.If you suspect that your
Personal Data
has been
compromised, please immediately contact our Customer Support Team at
[email protected].
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USER’S RIGHTS
- 9.1.Users residing in certain
countries,
including the EU,
are afforded certain rights regarding their personal information:
- 9.1.1.The right to
access:
you have
the right to confirmation as to whether or not we process your Personal Data
and, where we do, to access the Personal Data. Providing that the rights and
freedoms of others are not affected, we will supply to you a copy of your
Personal Data. The first copy will be provided free of charge, but additional
copies may be subject to a reasonable fee;
- 9.1.2.The right to object to
processing: you have the right to object to us processing your Personal
Data, citing personal reasons; however, understand that we may still process
your Personal Data if we have lawful grounds to do so, but only if our interests
in processing your Personal Data are not overridden by your rights, interests,
or freedoms;
- 9.1.3.The right to
rectification: you
have the right to have any inaccurate Personal Data about you rectified and,
taking into account the purposes of the processing, to have any incomplete
Personal Data about you completed;
- 9.1.4.The right to data
portability:
you have the right to obtain and reuse your Personal Data for your own purposes
across different services. It allows you to move, copy or transfer Personal Data
easily from one IT environment to another in a safe and secure way, without
hindrance to usability;
- 9.1.5.The right to
erasure:
you have
the right to request that the Company erase your Personal Data under certain
conditions. However, this can sometimes be a limited right where our other
duties prevent us from doing so. For example, if you asked us to delete your
identity and transaction data, we would not be able to do this, as we have a
legal duty to keep it under anti-money laundering and counter-terrorism
financing regulations;
- 9.1.6.The right to restrict
processing:
you have the right to request that the Company restrict the processing of your
Personal Data under certain conditions;
- 9.1.7.The right to withdraw
consent:
to the extent that the legal basis for our processing of your Personal Data is
consent, you have the right to withdraw that consent at any time. However,
withdrawal will not affect the lawfulness of processing of your Personal Data
before the withdrawal.
- 9.2.You may exercise any of your
rights in
relation to your
Personal Data by contacting our Customer Support at [email protected].
You must note
that prior to accessing and making changes to your Рersonal Data, we will need to verify
your identity properly.
- 9.3.We will aim to respond to your
requests
regarding your
Personal Data within 1 (one) month of receipt of any such request.
- 9.4.If you believe that your rights
have
been
infringed, you
may lodge a complaint with the supervisory authority in your jurisdiction.
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INTERNATIONAL TRANSFER OF PERSONAL DATA
- 10.1.We may need to transfer your
Рersonal
Data to countries
which are located outside the European Economic Area (“EEA”), for the purpose of
providing the Services to you. You may be located in a country outside of the EEA and
therefore we may have no choice but to transfer your Personal Data outside of the EEA.
- 10.2.Any transfer of your personal
information outside of the
EEA will be subject to a GDPR-compliant guarantee (such a Model Contract Clause approved
by the European Commission) that will safeguard your privacy rights and give you
remedies in the unlikely event of a security breach.
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COOKIES POLICY
-
11.1.We use cookies and similar technologies like
pixels,
tags, and other identifiers in order to remember your preferences, to understand how our
Website and the associated mobile application are used, and to customize our marketing
offerings.
-
11.2.A cookie is a small data file containing a
string of
characters that is sent to your computer when you visit a website. When you visit the
websites again, the cookie allows that site to recognize your browser. The length of
time a cookie will stay on your computer or mobile device depends on whether it is a
“persistent” or “session” cookie. For further information regarding cookies, visit
allaboutcookies.org.
-
11.3.We use the following types of cookies on our
Website and
in our mobile application:
-
11.3.1.Strictly necessary
cookies:
these are essential for you to browse our Website and use its features, and
access and use our mobile application. Without these cookies, some online
services cannot be provided.
-
11.3.2.Performance cookies:
these
collect information about how you use our Website and our mobile application.
This data may be used to help optimize our Website and our mobile application
and make them easier for you to navigate.
-
11.3.3.Functional cookies:
these
allow
our Website and our mobile application to remember the choices you make while
browsing the Website and/or using the mobile application and to personalize your
experience.
-
11.3.4.Third-party cookies:
these
are
placed by websites and/or parties other than us. These cookies may be used on
our Website and in our mobile application to improve our services or to help us
provide more relevant advertising. These cookies are subject to the respective
privacy policies for the relevant external services.
-
11.3.5.Analytics cookies:
these are
offered by services like Google Analytics, to help us understand how long a
visitor stays on our Website and in our mobile application, what pages they find
most useful, and how they arrived at walleti.com.
-
11.4.Most web browsers allow you to control cookies
through
their settings preferences. However, if you limit the ability of our Website or our
mobile application to set cookies, you may impair your overall user experience, as it
will no longer be personalized to you.
-
11.5.In addition to cookies, we sometimes use small
graphic
images known as pixels (also known as web beacons, clear GIFs, or pixel tags). We use
pixels in our email communications to you (if you have selected to receive such
communications) to help us to understand whether our email communication has been
viewed. We also use third-party pixels (such as those from Google, YouTube, and other
networks) to help us provide advertising that is relevant to your interests.
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CHANGES TO THE PRIVACY POLICY
-
12.1.We may update this Privacy Policy from time to
time and
we encourage you to periodically review this page. If we make any material changes in
the way we collect, use, and/or share your Personal Data, we will notify you by posting
notice of the changes in a clear and conspicuous manner on our Website at walleti.com.
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CONTACT INFORMATION
-
13.1.Should you have any questions regarding this
Privacy
Policy, please do not hesitate to contact us at [email protected].
