While using the Website and/or the Services You agree for the Personal Data Processing in accordance with the Policy and affirms that. In a case You do not agree with the Policy partially or fully, You must stop using the Services.
The Services are not directed to people under the age of 18. If You become aware that any individual under the age of 18 has provided WIEX with Personal Data please notify WIEX. If WIEX becomes aware that an individual under 18 has provided WIEX with Personal Data, WIEX will take steps to remove such information and/or terminate the account.
WIEX is the Data Controller within the meaning of the General Data Protection Regulation (GDPR) and determines the purposes and means of Processing the Personal Data.
’Data Controller’ means a company which determines purposes and means of Personal Data Processing.
’Data Processor’ means a company which Processes Personal Data on behalf and upon instructions of the Data Controller.
‘Personal Data’ means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
‘Processing’ means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
3. Personal data WIEX collects
WIEX collects certain Personal Data about You and Your use of the Services. This information falls into three primary categories:
- information You provide to Us;
- information We collect from You automatically;
- and information We collect from third parties.
3.1. Information You provide to Us
This information is either required by law necessary for Us to provide You with the requested Services or are relevant for Our legitimate interests. The nature of the Services You are requesting will determine the kind of Personal Data We might ask for, but may include:
(a) Identification data: information for conducting KYC and KYT procedures, such as Your full name, date of birth, address, contact details, photo of an ID document, proof of address document proof of legal formation and/or any other information deemed necessary to comply with Our legal obligations under the applicable anti-money laundering laws.
(b) Financial data: including Cryptocurrency wallet addresses information, bank account information.
(c) Transactions data: information about the transactions you make using the Services, such as the name of the Cryptocurrency, the amount, and/or timestamp.
(d) Correspondence data: including, survey responses, information provided to Our support team or user research team.
3.2. Information We collect from You automatically
This information is collected automatically by the virtue of You accessing and/or using the Website and/or the Services and helps Us to improve the Website and Services, address any customer support issues, provide You with a streamlined and personalized experience, and protect You from fraud by detecting unauthorized access. This information may include:
(a) Identifiers: geo location/tracking details, operating system, browser type, and/or personal IP addresses.
(b) Usage data: information about how You use the Website and/or the Services, such as Your web request, pages viewed, authentication data and other data collected via cookies and similar technologies. Please read the Cookies policy for more information.
3.3. Information We collect from third parties
This includes information We may obtain about You from third party sources. The main types of third parties We receive Personal Data from are:
(a) Public databases, credit bureaus & id verification partners: information in order to verify Your identity in accordance with applicable law. ID verification partners use a combination of government records and publicly available information about You to verify Your identity. Such information may include your name, address, job role, public employment profile, credit history, status on any sanction’s lists maintained by public authorities, and other relevant data.
(b) Blockchain data: information to ensure that persons using the Services are not engaged in any illegal or prohibited activities and to analyze transaction patterns for analysis and development purposes.
(c) Marketing partners & resellers: information to better understand which of the Services may be of interest to You.
4. Purposes and legal bases for Personal Data Processing
We rely on legal bases for Processing Personal Data under the relevant data protection legislation. This means We will only Process Personal Data where We are legally required to; where Processing is necessary to perform any contracts we entered with You or to take steps at Your request prior to entering into a contract with You; where Processing is in Our legitimate interests to operate our business and not overridden by your data protection interests or fundamental rights and freedoms; or where we have obtained Your consent to do so.
WIEX may Process Personal Data for the following purposes:
(a) Compliance with legal obligations: WIEX needs to Process Personal Data in order to comply with relevant applicable laws, such as, anti-money laundering and privacy laws. For example, We Process Personal Data to identify and verify Users using the Services to manage risk as required under applicable law. We also Process Personal Data in order to help detect, prevent, and mitigate fraud and abuse of the Services and to protect You against account compromise or funds loss. If you do not provide Personal Data required by law, We cannot provide You the Services.
(b) To provide the Services: WIEX Processes Personal Data to provide the Services. As WIEX handles sensitive data, such as Your identification and financial data, it is very important to actively monitor, investigate, prevent, and mitigate any potentially prohibited or illegal activities, enforce Our agreements with third parties, and/or prevent and detect violations of our Terms of Service. We collect information about Your usage of and closely monitor Your interactions with the Services. Third parties that We use such as for identity verification services and/or fraud prevention services may also access and/or collect Personal Data when providing the services. The consequences of not Processing Personal Data for such purposes is the termination of Your account.
(c) To provide communications and support services: According to your preferences and in compliance with applicable law, we may send You marketing communications that We believe may be of interest to You. We only Process Personal Data for this purpose with Your consent and You may opt out from receiving marketing communication when registering an account with Us. If you do not want Us to send You marketing communications, You can opt-out by clicking the unsubscribe button contained in a marketing communications email.
We may send administrative, account and/or transaction related communications to you to keep you updated about the Services, inform You of relevant security issues, or provide other information related to your transactions. You cannot opt-out of receiving critical service communications.
We also Process Personal Data when you contact Us to investigate and settle any questions and disputes, collect fees, or to troubleshoot problems. Without Processing Personal Data for such purposes, We cannot respond to Your requests and ensure Your uninterrupted use of the Services.
(d) Our legitimate business interests: Sometimes the Processing of Personal Data is necessary for Our legitimate business interests, such as:
- quality control and staff training;
- to enhance security, monitor and verify identity or service access, and to combat spam or other malware or security risks;
- research and development of the Services;
- to personalize Your experience; or
- to facilitate corporate acquisitions, mergers, and transactions.
5. Disclosing Personal Data
WIEX will not rent or sell Your Personal Data to anyone.
WIEX only shares the Personal Data when WIEX has a valid reason for it, namely, to provide the Services to You and when WIEX is legally permitted to do so, including:
(a) WIEX may share Personal Data between and among subsidiaries and affiliated companies of WIEX for purposes of KYC and KYT processes, fraud detections, decision making, customer support, and other business purposes.
(b) WIEX may disclose Personal Data to third parties that WIEX uses to provide the Services. These parties have been rigorously assessed and offer a guarantee of compliance with the legislation on the Processing of Personal Data. These parties have been designated as Data Processors and carry out their activities according to the instructions given by us and under our control. Such third parties include providers of support services such as secure website hosting, cloud storage, information technology maintenance, network infrastructure, payment processing, security, fraud detections, elements of KYC and KYT processes, customer support and analytics.
(c) WIEX may be required to share Personal Data with various financial institutions and/or enforcement or court authorities to comply with applicable laws, prevent fraud, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others.
(d) WIEX may also disclose Personal Data to third parties:
- if You request or authorize it;
- to address emergencies or acts of God;
- in the process of provision of banking, legal, compliance, and other consulting services by professional advisors in order to complete required legal audits of our operations, or otherwise comply with our legal obligations;
- as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties (acquirer, successor, or assignee) as one of Our business assets to. In such case, WIEX makes sure that the Your rights and conditions as a data subject shall not be decreased;
- to protect Our legal rights;
- to address disputes, claims, or to persons demonstrating legal authority to act on Your behalf.
6. Your rights
To the extent required by applicable data protection law, You have all the rights of a data subject as regards to own Personal Data. Such rights include the following:
(a) request an access Personal Data;
(b) request corrections in Personal Data;
(c) request erasure of Personal Data;
(d) request that we restrict Our processing of Personal Data;
(e) withdraw Your consent to the Processing of Personal Data collected on the basis of Your consent;
(f) request to receive Personal Data We hold about You;
(g) request not to be subject to a decision based solely on automated processing of Personal Data;
(h) submit objections to the Personal Data processing on any grounds.
If you would like to exercise Your rights, please contact Us using the contact details listed below.
We may limit these privacy rights requests:
(a) when denial of access is required or authorized by law; when granting access would have a negative impact on another's privacy;
(b) to protect Our rights and properties;
(c) where the request is frivolous or burdensome.
You do not need to pay a fee to access information or other rights, but WIEX may charge a reasonable fee if Your request is clearly unfounded, repetitive, or excessive or refuse to comply with Your request in these circumstances.
In case of Your rights violation, the You have the right to ask State Data Protection Inspectorate or court to protect Your rights. The State Data Protection Inspectorate can be contacted as follows:
Phones: +370 5 271 2804 / 279 1445
Fax: +370 261 9494
E-mail [email protected]
Address: L. Sapiegos str. 17 (Left-hand entrance), LT-10312 Vilnius
7. Personal Data retention
The Personal Data retention period will vary. The retention period will be determined by the following criteria:
(a) the business purpose for which We are using Personal Data – We will need to keep the information for as long as is necessary for that purpose; and
(b) legal obligations – laws or regulation may set a minimum period for which We have to keep Personal Data.
We will cease to retain Personal Data, or remove the means by which the data can be associated with You, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
For more information on Personal Data retention please contact Us using the contact details listed below.
8. Security and international transfers
Although generally the Personal Data is processed within the European Economic Area, certain activities may result in the transferring of Personal Data to third countries, meaning countries located outside the EU/EEA. WIEX takes all necessary measures to protect the data against unauthorized access, modify, disclosure or destruction. WIEX has implemented various technical and organizational measures to be compliant with applicable Personal Data, privacy, and data security legislation in the countries where WIEX operates or where the applicable law applies to WIEX.
WIEX has put in place procedures to deal with any suspected Personal Data breach and will notify You and any relevant regulator of a breach where WIEX is required to do so by law.
WIEX is not responsible for the Personal Data protection measures violations if such violations caused by actions performed by You or a third person.
If you have a reason to believe that Your Personal Data is no longer secure, please contact Us immediately using the contact details listed below.
9. Third-party links
10. Policy changing
The Policy can be changed to comply with changes in law, Personal Data processing or under instructions of supervisory authorities. WIEX will make available the updated Policy on the Website.
11. Contact details and questions
Any questions about this Policy, the processing of Personal Data or data subject’s requests please contact WIEX via email [email protected].