October 28, 2020
privacy-policy on Wallebi
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PRIVACY POLICY

Users are required to read, review, understand and then agree to the terms hereunder for using or availing of the WALLEBI LTD., before clicking the “ accept & continue” option on the app. By using the website and WALLEBI app, you consent to the data practices described in this privacy policy. On occasion, WALLEBI may revise this privacy policy to reflect changes in law or our personal data collection and use practices. If material changes are made to this privacy policy, the changes will be announced by posting on the site or through other means of communication like in app message, email, etc. We will ask for your consent before using your information for any purpose that is not covered in this privacy policy. WALLEBI shall mean and include below:

WALLEBI LTD, incorporated in United Kingdom and having its registered address at 20-22 Wenlock Road, London, N1 7GU, (hereinafter referred to as “WALLEBI”, which term shall refer to and include its owners, its subsidiaries and affiliated companies, directors, investors, employees, officers, representatives, affiliates, or other related parties). Persons availing of the WALLEBI LTD., directly or indirectly, are referred to herein, as “Users”.

This Privacy Policy describes our information handling practices when you access content we own or operate on the websites or app of WALLEBI or any other websites, pages, features, or content we own or operate (collectively, the “Site(s)”).

This is an agreement between WALLEBI and User, which is binding and requires mandatory compliance by User. Integrity, honesty and ethical business practices are some of the core values for WALLEBI.

WALLEBI strongly condemns any and all activities related to money laundering and such other illegal actions. In order to prevent misuse of the WALLEBI LTD., Users are required to strictly comply with the terms contained herein, which forms part and parcel of the User Terms of Service. Terms not defined herein shall carry the same interpretation, as in the User Agreement and in the absence thereof to general usage and parlance.

This terms and conditions of privacy supersedes and replaces any and all prior oral or written understandings or agreements between WALLEBI and the user with respect to the privacy policy.

 

DEFINITIONS

“Applicable Law” means the law in force for the time being within the territory of United Kingdom.

“WALLEBI” shall mean and include WALLEBI Android App, WALLEBI iOS App (collectively, “WALLEBI App”) or Zeb Web app (“Web version”) and WALLEBI website “www.WALLEBI.com” (“WALLEBI Website”). Collectively along with the WALLEBI Developer Portal, Public APIs and secure authentication for WALLEBI Users is referred to as the “WALLEBI ACCESSES”.

 

PRIVACY POLICY

– WALLEBI is committed to ensuring the safety and protection of all data and information shared with WALLEBI by its Users subject to Applicable Laws and the terms and conditions set out hereunder and processes established by WALLEBI in compliance with the applicable reasonable security practices and procedures, prescribed by Government or Regulatory authorities, as the case may be.

– WALLEBI shall not be liable for any breach or violation of its systems or policies due to malicious attacks, errors, commissions or omissions not wilfully initiated by WALLEBI, leading to breach of data or information of User.

 

PERSONAL INFORMATION AND DATA WE COLLECT

– Personal information is data that can be used to identify you directly or indirectly, or to contact you. Our Privacy Policy covers all personal information that you voluntarily submit to us and that we obtain from our partners. This Privacy Policy does not apply to anonymized data, as it cannot be used to identify you.

– We can ask you to provide personal information anytime you are in contact or consuming WALLEBI LTD. You hereby acknowledge that WALLEBI companies may share your personal information with each other and use it consistently with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, and content. Except as described in this Privacy Policy, WALLEBI will not sell, rent or loan any personal information to any third party.

 

PERSONAL INFORMATION OR DATA COLLECTE

– WALLEBI may collect required personal data and information of the User including sensitive personal information. Use of the WALLEBI services is contingent on acceptance of the terms contained herein. User shall be deemed to have volunteered the data and information collected, retained, used and disseminated by WALLEBI, upon accepting the terms herein and those contained in the Terms of Service of WALLEBI.

– User hereby consents that when personal data is shared with WALLEBI, User hereby agrees and acknowledges WALLEBI’s right to use or disseminate such data or information including transfer of the personal and sensitive personal information of the User from current location to external sources including and third parties.

– WALLEBI collects your personal information to provide our Services. When we require certain personal information from users, it is because we are required by law to collect this information or it is relevant for specified purposes. Any information you provide to us that is not required is voluntary. You are free to choose whether to provide us with the types of personal information requested, but we may not be able to serve you as effectively or offer you all of our Services when you do choose not to share certain information with us. We may collect the following types of information provided / shared by the User as applicable:

o Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, national ID proof, home address, and/or email.

o Recognized Identification Information: Tax ID number, passport number, driver’s license details, national identity card details, photograph identification cards, and/or visa information.

o Monetary Information: Bank account information, Permanent account Number, Credit or Debit Card No, transaction history, trading data, and/or tax identification.

o Transaction Information: Information about the transactions by using WALLEBI services, such as the name of the recipient, digital currency address, your name, the amount, and/or timestamp, etc.

o Employment or Business Information: Office location, job title, and/or description of Business, role, etc.

o Online Identifiers: User’s device information including but not limited to IMEI or equipment identification number, IMSI or subscriber identification, UUID, MAC address, OS version, device details, network operator, contact list information, Wi-Fi / Data Network connectivity. Cookies Information generated by the User’s use of the app and the website, including cookies and IP addresses. Geolocation of a User’s device or such or other automatically collated data or information of User.

o Access to User’s Photo Gallery / Media / Files / Camera: for using WALLEBI services more efficiently.

o Access to User’s other apps and services: including messaging through SMS, usage data, device details

o Any other information to provide services

 

PURPOSE & USE OF DATA COLLECTED

– To Provide Services – In order to provide service, we process information or Data collected from Users.

– To enhance website or app experience for users.

– To facilitate transactions of users.

– To enforce our Terms of Use agreement and other agreements with users.

– To maintain legal and regulatory compliance of local jurisdictions.

– To provide service and customer service.

– To ensure network and information security.

– To engage in marketing activities.

– For research and development purposes.

 

WALLEBI will never sell the data collected from the Users.

 

COLLECTION OF AUTOMATIC DATA

Cookies: WALLEBI uses cookies on its App and website to collect data about user. For a detailed policy on use and collection of Cookies.

 

DATA RETENTION AND PROTECTION

– WALLEBI shall retain the User’s information for as long as the account is active or as needed to provide services in accordance with applicable laws. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

– The retention period may be extended to comply with legal obligations, resolve disputes, and enforce agreements for a period of ten years after termination of the account or such period, under applicable laws. WALLEBI may retain data for further periods but is not obligated to do so in all instances. WALLEBI shall not be liable or responsible for non – availability or non – retention of data or information beyond the termination of the User account.

– The retention period may extend beyond the end of User account, but it will be only as long as it is necessary for WALLEBI to have sufficient information to respond to any issues that may arise later, including but not limited to retention for the purpose of investigations or on-going prosecutions or in case of Suspicious transactions or if WALLEBI requires the information for its

records or to support legal proceedings, or if WALLEBI believes in good faith that a law, regulation, rule or guideline requires it.

– Please note WALLEBI cannot guarantee that loss, misuse, unauthorized acquisition, or alteration of your data will not occur and you play a vital role in protecting your own personal information.

– users while registering with WALLEBI LTD., it is important to choose a password or PIN of sufficient length and complexity, to not reveal this password to any third-parties, and to immediately notify us if you become aware of any unauthorized access to or use of your account.

– Subsequently, WALLEBI cannot ensure or warrant the security or confidentiality of information you transmit to us or receive from us by Internet or wireless connection, including email, phone, or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at privacy@WALLEBI.com

 

UPDATION OF USER DATA AND WITHDRAWAL OF USER CONSENT

– The User shall ensure that all data and information shared with WALLEBI is accurate, correct and complete. User shall ensure that change of the User’s address or any change in circumstances impacting use of the WALLEBI LTD., is promptly communicated to WALLEBI.

– WALLEBI will not be held liable or responsible for any incorrect information provided by the User to WALLEBI.

– User may, upon termination of the use of the WALLEBI LTD., as provided in the Terms of Service, withdraw consent granted herein to WALLEBI. The same shall however not affect actions undertaken or data and information collated or technological processes initiated prior to such withdrawal of consent. Such withdrawal of consent shall also not affect retention of data and information collected prior to such withdrawal.

 

SHARING OF INFORMATION WITH THIRD-PARTIES

The User agrees and consents to WALLEBI sharing the following anonymized data or to otherwise gives WALLEBI permission to share its Data with third-parties for the following:

– For referral, operations, additional services and technology services (such as hosting providers, identity verification, support, payment, and email service providers).

– If required by applicable law or legal process, or if WALLEBI believes that it is in accordance with applicable law or legal process.

– To protect the rights, property and safety of WALLEBI, its users and the public, including but not limited to usage in court proceedings, or to detect or prevent criminal activity, fraud, material misrepresentation, or to establish its rights or defend against legal claims, or

– In connection with selling, merging, acquiring, transferring, or reorganizing all or parts of WALLEBI’s business.

 

Users Right

Users have the following rights, which can be exercised by contacting us privacy@WALLEBI.com so that we may consider your request under applicable law.

Right to withdraw consent: You have the right to withdraw your consent to the processing of your personal information collected on the basis of your consent at any time. Your withdrawal will not affect the lawfulness of WALLEBI’s data processing based on consent before your withdrawal.

Right of access to and rectification of your personal information: You have a right to request that we provide you a copy of your personal information held by us. This information will be provided without undue delay subject to some fee associated (if applicable) with gathering of the information (as permitted by law), unless such provision adversely affects the rights and freedoms of others. You may also request us to rectify or update any of your personal information held by WALLEBI that is inaccurate.

Right to erasure: You have the right to request erasure of your personal information that:

o is no longer necessary in relation to the purposes for which it was collected or otherwise processed

o Was collected in relation to processing that you previously consented, but later withdraw such consent; or

o Was collected in relation to processing activities to which you object, and there are no overriding legitimate grounds for our processing. The above is subject to limitations by relevant data protection laws.

Right to data portability: If we process your personal information based on a contract with you or based on your consent, or the processing is carried out by automated means, you may request to receive your personal information in a structured, commonly used and machine-readable format, and to have us transfer your personal information directly to another “controller”, where technically feasible, unless exercise of this right adversely affects the rights and freedoms of others. A “controller” is a natural or legal person, public authority, agency or other body which,

alone or jointly with others, determines the purposes and means of the processing of your personal information.

Right to restriction of or processing : You have the right to restrict or object to us processing your personal information where one of the following applies:

o You contest the accuracy of your personal information that we processed. In such instances, we will restrict processing during the period necessary for us to verify the accuracy of your personal information.

o The processing is unlawful and you oppose the erasure of your personal information and request the restriction of its use instead.

o We no longer need your personal information for the purposes of the processing, but it is required by you to establish, exercise or defense of legal claims.

o You have objected to processing, pending the verification whether the legitimate grounds of WALLEBI’s processing override your rights.

o Restricted personal information shall only be processed with your consent or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest. We will inform you if the restriction is lifted.

Notification of erasure, rectification and restriction: We will communicate any rectification or erasure of your personal information or restriction of processing to each recipient to whom your personal information have been disclosed, unless this proves impossible or involves disproportionate effort. We will inform you about those recipients if you request this information.

Right to object to processing: Where the processing of your personal information is based on consent, contract or legitimate interests you may restrict or object, at any time, to the processing of your personal information as permitted by applicable law. We can continue to process your personal information if it is necessary for the defense of legal claims, or for any other exceptions permitted by applicable law.

Automated individual decision-making, including profiling: You have the right not to be subject to a decision based solely on automated processing of your personal information, including profiling, which produces legal or similarly significant effects on you, save for the exceptions applicable under relevant data protection laws.

Right to lodge a complaint: If you believe that we have infringed your rights, we encourage you to contact us first at privacy@WALLEBI.com, so that we can try to resolve the issue or dispute informally.

Your rights to personal information are not absolute. Access may be denied when:

o Denial of access is required or authorized by law.

o Granting access would have a negative impact on other’s privacy.

o Granting access would have a negative impact on other’s privacy.

o To protect our rights and properties; and

o Where the request is frivolous or vexatious.

 

REASONABLE SECURITY PRACTICES

– Protection of the User’s personal information is of utmost importance to WALLEBI and it takes all reasonable steps to secure data and information pertaining to its Users, including those prescribed under applicable laws and Rules framed thereunder

– WALLEBI takes appropriate legal, administrative, physical, and reasonable electronic measures designed to protect the information that Users share with WALLEBI.

– WALLEBI however does not extend any warranties with respect to the security or safety of data and information transmitted through digital platforms or online, both of which are susceptible to malicious attacks.

 

MODIFICATIONS

These terms may be periodically reviewed and revised. User will be notified through an update of the App. The revised draft will be uploaded on the WALLEBI website and will reflect the modified date of the terms. User is required to periodically visit the website and review terms and any changes thereto. Continued use of the WALLEBI LTD. constitutes agreement of User to the terms contained herein and any amendments thereto. WALLEBI may for any important changes in the policy would send an email to user’s registered email id.

 

MISCELLANEOUS

All other provisions of the WALLEBI Terms of Service shall be read into this policy and shall form part hereof, including Governing Laws and jurisdiction, notices, severability, assignment and such or other provisions.

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