Updated 2 May 2019
NOTICE FOR JAPANESE RESIDENTS
NOTICE RE: EUROPEAN ECONOMIC AREA
As we are a global company, we may collect Personal Data from individuals and institutions located within the European Economic Area (“EEA”) or the Channel Islands. We are required to protect Personal Data processed in the EEA and the Channel Islands in accordance with the General Data Protection Regulation (“GDPR”) and equivalent local legislation. To understand more about how we protect the data we collect from individuals and institutions located within the EEA or the Channel Islands, please see the ‘Privacy Statement for Data Subjects Whose Personal Data May Be Collected in or from the EEA or the Channel Islands’ section below.
Personal Data as defined by the Personal Data Protection Act 2012 (“PDPA”) means data, whether true or not, about an individual who can be identified from the data or from that data and other information to which the organization has or is likely to have access. Wowoo Exchange values your privacy and is PDPA compliant.
The governing language of this Policy is English. Any other language translation is provided for convenience only.
“Personal Data” In addition to the definition of Personal Data as defined by the PDPA above, Personal Data also means any information that directly or indirectly can be used to identify a natural person, such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, economic, cultural or social identity of you as a natural person.
“Data Privacy Laws” means data protection laws applicable to Wowoo Exchange, including without limitation the Singapore Personal Data Protection Act 2012 and the EU General Data Protection Regulation 2016/679 and its respective successors.
“Services” has the meaning given to it in our Terms and Conditions.
3. COLLECTION OF PERSONAL DATA
We want you to understand the types of information we collect when you register for and use Wowoo Exchange. You decide whether or not to provide us with the information, however we may not be able to offer you some or all of our Services if you choose not to share certain information with us.
Personal Data and information we may collect from you include but are not limited to the following:
(i) Identification Information - full name, home address, email address, date of birth, age, nationality, gender, signature, photographs, tax identification number, passport number, driver license details, national identity card details, immigration visa information;
(ii) Account Information - username, password, account settings and preferences;
(iii) Financial Information - bank account numbers, bank statement, virtual currency wallet addresses, trading data;
(iv) Verification Information - utility bills, phone bills, bank statements, tax returns;
(v) Information relating to usage of our Services - device identification, operating system, browser type, IP address, domain name, access date and time via server logs;
(vi) Transaction Information - trading activity, order activity, deposits, withdrawals and account balances;
4. HOW WE USE YOUR PERSONAL INFORMATION
We may use and process your Personal Data to communicate with you and to administer, deliver, improve and personalize our Services and also for loss prevention and anti-fraud purposes. We may also generate data from any Personal Data we collect from you and use it for our own purposes. We may also use such data to communicate with you in relation to other products or services offered by us and/or our partners. Some purposes for which we use your Personal Data, including but not limited to:
Legal and Compliance Regulations
We are required by law to collect and use your Personal Data in connection with our Services - E.g. we need to identify and verify customers using our Services in order to comply with anti-money laundering and terrorist financing laws across different jurisdictions. In addition, we use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records. If you do not provide this Personal Data, you will not be allowed to use our Services.
Enforcement of our Terms and Conditions
Due to the nature of sensitive information we handle, it is important for us and for the benefit of our customers that we are actively monitoring, investigating, preventing and mitigating any potentially prohibited or illegal activities, enforcing our agreements with third parties, and/or violations of our Terms and Conditions or agreements related to other services. We may use any of your Personal Data collected on our Services for these purposes. The consequences of not processing your personal information for such purposes is the termination of your account as we cannot perform our Services in accordance with our Terms and Conditions.
Performance of our Obligations and Provision of our Services
We process your Personal Data in order to provide the Services to you. For example, when you want to buy Digital Currency, we require certain information such as your identification, contact information, and payment information. We cannot provide you with Services without such information.
We send administrative or account-related information to you to keep you updated about our Services, inform you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our Services.
We process your Personal Data to provide a personalised experience, and implement the preferences you request. Without such processing, we may not be able to ensure your continued enjoyment of part or all of our Services.
We process your Personal Data when you contact us to resolve any questions, disputes, collect fees, or to troubleshoot problems. We may process your information in response to another customer’s request, as relevant. Without processing your Personal Data for such purposes, we cannot respond to your requests and ensure your uninterrupted use of the Services.
We process your Personal Data for quality control and staff training to make sure we continue to provide you with accurate information. If we do not process Personal Data for quality control purposes, you may experience issues on the Services such as inaccurate transaction records or other interruptions. Our basis for such processing is based on the necessity of performing our contractual obligations with you.
Network and Information Security
We process your Personal Data in order to enhance security, monitor and verify identity or service access, combat spam or other malware or security risks and to comply with applicable securities laws and regulations. The threat landscape on the internet is constantly evolving, which makes it more important than ever that we have accurate and up-to-date information about your use of our Services. Without processing your Personal Data, we may not be able to ensure the security of our Services.
To further improve our Services
We process your Personal Data to better understand the way you use and interact with our Services. In addition, we use such information to customise, measure, and improve our Services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our Services.
Marketing and Communications
Based on your communication preferences, we may send you marketing communications to inform you about our events or our partner events; to deliver targeted marketing; and to provide you with promotional offers based on your communication preferences. We use information about your usage of our Services and your contact information to provide marketing communications. We may also share your Personal Data with third parties to help us with our marketing and promotional projects or sending marketing communications.
You may opt out of our marketing activities by contacting us at firstname.lastname@example.org.
5. THIRD PARTY INFORMATION WE RECEIVE
As required and/or permitted by applicable law, we may obtain information about you from third party sources, such as public databases, credit bureaus and identification verification partners for purposes of verifying your identity. E.g. Identification verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.
6. PERSONAL DATA WE MAY SHARE WITH OTHER PARTIES
We take care to allow your Personal Data to be accessed only by those who really need to in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. We will generally only share your Personal Data in the following circumstances:
(i) We share your Personal Data with third party identity verification services and transaction monitoring services to prevent fraud and other illegal activities. This allows us to confirm your identity by comparing the information you provide us to public records and other third party databases. These service providers may create derivative data based on your Personal Data that can be used solely in connection with the provision of identity verification and fraud prevention services.
(ii) We share your Personal Data with financial institutions and payment services providers with which we partner to process payments you have authorised.
(iii) We share your Personal Data with service providers under contract who help with parts of our business operations such as payment, marketing, and technology services. Our contracts provide for binding enforceable requirements on our service providers in compliance with applicable laws.
(iv) We may share your information with companies or other entities that purchase our assets pursuant to a court-approved sale under applicable bankruptcy laws and / or where we are required to share your information pursuant to applicable insolvency law;
(v) We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our User Agreement or any other applicable policies.
7. INFORMATION SECURITY
We use our best endeavours to ensure confidentiality and protection of your Personal Data, however, we cannot guarantee absolute security. We work hard to protect your Personal Data from unauthorized access to or unauthorized alteration, disclosure, or destruction of your Personal Data. E.g. we use data encryption and firewalls and we restrict access to your Personal Data on a need to know basis for our employees, contractors and agents who require the information to fulfil their job responsibilities.
Further, we cannot ensure the security or confidentiality of Personal Data that you transmit to us or receive from us via the internet or wireless connection.
If you have reason to believe that your data is no longer secure, or if you become aware of any unauthorised access to or use of your account, please contact us at the email address email@example.com.
8. RETENTION OF PERSONAL DATA
We take reasonable and practicable steps to ensure that we retain your Personal Data is not kept longer than is necessary for the fulfillment of the purpose for which it is to be used, which is when your business relationship with us ends, unless the further retention of your Personal Information is otherwise permitted or required by applicable laws and regulations.
9. UNDER-AGE PERSONAL DATA
We do not knowingly request to collect Personal Data from any person under the age of 18. If a user submitting Personal Data is suspected of being younger than 18 years of age, we will require the user to close his or her account and will not allow the user to continue buying or selling digital currencies. We will also take steps to delete the information as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can take action to prevent access to our Services.
10. EUROPEAN ECONOMIC AREA & CHANNEL ISLANDS PRIVACY STATEMENT
While customers who are located in the EEA or the Channel Islands are customers of our Singapore entity, we recognize and, to the extent applicable to us, adhere to relevant EEA or the Channel Islands data protection laws.
We may collect Personal Information from users located in the EEA or the Channel Islands. To facilitate the services we provide to customers located in the EEA or the Channel Islands, we request explicit consent for the transfer of Personal Information from the EEA or the Channel Islands to Singapore. If you are an individual located in the EEA or the Channel Islands and you decline to consent to such transfer, you will no longer be able to use Wowoo Exchange and our services. You will have the ability to withdraw Digital Assets and fiat currency; however, all other functionality will be disabled.
Lawful Grounds to Process and Obtain Consent
We process the Personal Data of users who are located in the EEA or the Channel Islands for one or more of several lawful purposes, including:
(i) To provide you with our Services, including customer service support;
(ii) To optimize and enhance our Services for all customers or for you specifically;
(iii) To comply with legal obligations, including to conduct anti-fraud and identity verification and authentication checks (you authorize us to share your Personal Data with our third-party service providers, who may also conduct their own searches of publicly available Personal Data about you);
(iv) To monitor the usage of our Services, conduct automated and manual security checks of our service, to protect our rights and perform our lawful obligations.
Users in the EEA or the Channel Islands may withdraw consent at any time where consent is the lawful basis for processing their Personal Data. Should a user withdraw consent for processing or otherwise object to processing that impedes our ability to comply with applicable laws and regulations, a user may be unable to avail him or herself of the Services we provide.
We do not engage in automated decision-making.
Non-Disclosure of Personal Data
Our employees are prohibited, either during or after their employment, from disclosing Personal Data to any person or entity outside of our company, including family members, except under the circumstances described above. An employee is only permitted to disclose the Personal Data of a user to such other employees who need access to such information in order to deliver our services to that user.
If, as an EEA or Channel Islands Citizen, you believe that we have not adequately resolved any such issues, you have the right to contact your local supervisory authority.