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Walbi is compliant with the applicable St. Vincent and the Grenadines and international laws for the Prevention of Money Laundering and TerroristFinancing, as well as other legislation applicable in the Republic of St.Vincent and the Grenadines.
1.1. “Walbi” means WALBI LLC, company number: 3001 LLC 2023, jurisdiction: Saint Vincent and the Grenadines, registered office: Euro House, Richmond Hill Rd, Kingstown, St. Vincent and the Grenadines.
1.2. “Controller” means a person who or public body which, alone or jointly with others, determines the purposes and means of the processing of personal data and has decision making power with respect to the processing.
1.3. “Consent” means any freely given specific, informed and unambiguous indication of the wishes of a data subject, either by a statement or a clear affirmative action, by which he signifies his agreement to personal data relating to him being processed;
1.4. “Data subject” means an identified or identifiable individual (hereinafter referred to as “users” “your “or “you”), 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 individual;
1.5. “Personal data” means any information relating to a data subject;
1.6. “Processing” means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
1.7. “Processor” means a person who, or public body which, processes personal data on behalf of a controller;
1.8. “Third party” means a person or public body other than a data subject, a controller, a processor or a person who, under the direct authority of a controller or processor, who or which is authorized to process personal data.
2. PURPOSES FOR WHICH WE USE YOUR PERSONAL DATA
2.1. Performance of contractual obligations.
The personal data collected from users is used to manage user’s account on the platform, to process user’s transactions, to provide users with post-transaction information, to inform users of additional products and/or services relevant to the user’s profile, to produce analysis and statistical data which will help the Walbi improve its products and services, and improve the platform.
2.2. Compliance with legal obligations.
There are a number of legal obligations arising from the relevant laws to which Walbi is subject, as well as other statutory requirements. Such obligations and requirements impose on Walbi the necessity to perform personal data processing activities for credit checks, compliance with court orders, tax law or other reporting obligations.
2.3. Purposes of safeguarding legitimate interests.
Walbi processes personal data to safeguard legitimate interests pursued by Walbi or by a third party. A legitimate interest is when Walbi has a business or commercial reason to use the user’s information. Even then, it must not unfairly go against what is right and best for the user. For example:
· initiating court proceedings and preparing our defence in litigation procedures;
· measures and processes we undertake to provide the Walbi’s IT and system security, preventing potential crime, asset security, admittance controls and anti-trespassing measures;
· measures to manage business and further develop the Walbi’s products and services;
· the transfer, assignment (whether outright or as security for obligations) and/or sale to one or more persons and/or charge and/or encumbrance over, any or all of the Walbi’s benefits, rights, title or interest under any agreement between the user and Walbi.
2.4. Marketing purposes.
Walbi may use user data, such as location or transaction history to deliver any news, analysis, research, reports, campaigns or training opportunities that may interest the user, to their registered email address.User always has the right to change the option if they no longer wish to receive such information.
3. SHARING YOUR DATA
3.2. We may transfer or disclose personal data to our subsidiaries, and other affiliated companies, and/or business introducers to provide the services you have requested and to fulfil our contractual obligations to you, and to fulfil legal and regulatory requirements.
3.3. We may share your data with third parties who process data on our behalf to provide you or us with products or services for the purposes outlined above. Walbi has a regulatory obligation to supervise and effectively oversee the outsourced functions and to act appropriately when it determines that the third party is not performing the said functions effectively and in accordance with applicable legislation. These third parties include:
· Professional advisers, including lawyers, insurers, auditors, translating agencies and tax advisers;
· Screening services provider and external compliance companies, including due diligence and financial crime screening databases providers;
· IT consultants and service providers, including hosting and cloud services providers;
· CardProcessing companies, and payment service providers, cloud storage companies;
· Other suppliers and providers of services to us, including banks, our sub-contractors’ agents.
3.4. We may disclose personal data, or any information you submitted via the services of we have a good faith belief that disclosure of such information is helpful or reasonability necessary to
· Comply with any applicable law, regulation, legal process, or governmental departments request;
· Enforce our policies (including our agreement), including investigations of potential violations thereof;
· When we consider disclosure to be necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal purpose;
· For the prevention, detection, investigate or take action regarding of any fraud or illegal activities or other criminal activity;
· To establish or exercise our rights to defend against legal claims;
· Prevent harm to the rights, property or safety of us, our users, yourself or any third party; or
· For the purpose of collaborating with law enforcement agencies and/or in case we find it necessary in order to enforce intellectual property or other legal rights.
3.5 When Walbi is required or permitted to disclose information without consent, Walbi will not disclose more information than necessary to fulfil the disclosure purpose.
4. MARKETING DATA
4.1. Walbi may process user’s personal data to inform users about products, services or offers that may be of interest to them. The personal data that Walbi processes for this purpose consists of information users provide to Walbi and data Walbi collects and/or infers when users use the services on the platform, such as information on user’s transactions. Walbi studies all such information to form a view of what is needed or what may be of interest to the users.
4.2. In some cases, profiling may be used.Profiling is a process where user’s data is automatically processed with the aim of evaluating certain personal aspects and further providing the user with targeted marketing information on products. Walbi can only use user’s personal data to promote its products and services if Walbi has the user’s explicit consent to do so or, in certain cases, if Walbi considers that it is in the user’s legitimate interest to do so.
4.3. Users have the right to object at any time to the processing of user’s personal data for marketing purposes or unsubscribe from receiving marketing-related emails from Walbi by contacting the company’s privacy department at firstname.lastname@example.org.
5. RETENTION OF YOUR PERSONAL DATA
5.1. It is our obligation to retain your personal data for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some personal data for a longer time, taking into account factors including:
· legal obligation(s) under applicable law to retain records for a certain period of time;
· maintain business records for analysis and/or audit purposes;
· defend or bring any existing or potential legal claims;
· deal with any complaints regarding the services; and
· guidelines issued by relevant data protection authorities.
5.2. When the company no longer needs to keep user’s personal data, it will securely delete or destroy it.
6. YOUR RIGHTS
6.1. You have a number of rights in relation to the personal data that we hold about you and you can exercise your rights by contacting us using the details is contact us section.
6.2. Right to access. You have the right to request copies of your personal data. Information must be provided without delay and within one month of receipt of request at the latest. Walbi may extend the period of compliance by a further two months where requests are complex or numerous. If this is the case, it will inform users within one month of the receipt of request and explain why the extension is necessary. Walbi must provide a copy of the information free of charge.However, Walbi can charge a “reasonable fee” when a request is manifestly unfounded or excessive, particularly if it is repetitive. The fee, if applied, will be based on the administrative cost of providing the information and on delivery expenses if the user requests that the information be delivered in hard copy. If at any time Walbi refuses to respond to a request, it will explain why to the user, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and within one month at the latest. Walbi will verify the identity of the person making the request, using reasonable means and will only provide the information to verified customers within a reasonable period.
6.3. Right to rectification. Individuals are entitled to have personal data rectified if it is inaccurate or incomplete.Users can make a request for rectification verbally or in writing. If Walbi has disclosed the personal data in question to others, it must contact each recipient and inform them of the rectification, unless this proves impossible or involves disproportionate effort. If asked to, the company must also inform the individuals about these recipients. Walbi must respond within one month.This can be extended by two months where the request for rectification is complex. Where the company does not take action in response to a request for rectification, Walbi must explain to the individual why this is not done, informing them of their right to complain to the supervisory authority and to a judicial remedy.
6.4. Right to erasure. The right to erasure does not provide an absolute ‘right to be forgotten’.Individuals have a right to have personal data erased and to prevent processing in specific circumstances: (1) where the personal data is no longer necessary in relation to the purpose for which it was originally collected/processed; (2) when the individual withdraws consent; (3) when the individual objects to the processing and there is no overriding legitimate interest to continue the processing; (4) when the personal data was unlawfully processed; (5) when the personal data has to be erased in order to comply with a legal obligation; (6) when the personal data is processed in connection with the offer of information society services to a child. There are some specific circumstances where the right to erasure does not apply and the company can refuse to execute the request. Walbi can refuse to comply with a request for erasure where the personal data is processed for the following reasons: (1) to comply with a legal obligation for the performance of a public interest task or exercise of official authority; (2) the exercise or defence of legal claims.
6.5. Right to restrict. The company will be required to restrict the processing of personal data in the following circumstances: (1) where an individual contests the accuracy of the personal data, the company should restrict its processing until the individual has verified its accuracy; (2) where an individual has objected to the processing (where it was necessary for the performance of a public interest task or purpose of legitimate interests), and the company is considering whether the organisation’s legitimate grounds override those of the individual;(3) when processing is unlawful, and the individual opposes erasure and requests restriction instead; (4) if the company no longer needs the personal data but the individual requires the data to establish, exercise or defend a legal claim. The company may need to review procedures to ensure it is able to determine when it may be required to restrict processing of personal data. If the company has disclosed personal data in question to others, it must contact each recipient and inform them of the restriction on processing the personal data, unless this proves impossible or involves disproportionate effort. If asked to, Walbi must also inform the individuals about these recipients.
6.6. The right to data portability allows individuals to obtain and reuse their personal data for their own purposes across different services. It allows them to move, copy or transfer personal data easily from one IT environment to another in a safe and secure way, without hindrance to usability. It enables consumers to take advantage of applications and services, which can use this data to find them a better deal or help them understand their spending habits. Walbi will respond without undue delay, and within one month. This can be extended by two months where the request is complex or where the company may receive a number of requests. Walbi will inform the individual within one month of receipt of the request and explain why the extension is necessary, if applicable. Where the company does not take action in response to a request, it will explain why to the individual, informing them of their right to complain to the supervisory authority and to a judicial remedy without undue delay and within one month at the latest.
6.7. Users have the right to object to: (1) processing based on legitimate interests or the performance of a task in the public interest/exercise of official authority (including profiling); (2) direct marketing (including profiling); (3) processing for purposes of scientific/historical research and statistics. Walbi will stop processing personal data unless: (1) Walbi can demonstrate compelling legitimate grounds for such processing, which override the interests, rights and freedoms of the individual; or (2) the processing is for establishment, exercise or defence of legal claims.
6.8. Withdrawal of consent: users have the right to withdraw his/her consent at any point in time, although in certain circumstances it may be lawful for us to continue processing without user’s consent if we have another legitimate reason (other than consent) for doing so.Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.9. The user has the right go to court or to escalate their complaint to the data protection regulator in their jurisdiction for the protection of rights, unless applicable laws prescribe a different procedure for handling such claims.
7. AUTOMATED DECISION-MAKING
7.1. In establishing and carrying out a business relationship, Walbi generally does not use any automated decision-making. Walbi may process some of the user’s data automatically, with the goal of assessing certain personal aspects (profiling), in order to enter in to or perform a contract with users for data assessments (including on payment transactions), which are carried out in the context of combating money laundering and fraud. An account may be detected as being used in a way that is unusual for a user or user’s business. These measures may also serve to protect users and their assets or private data.
8. CROSS BORDER TRANSFERS OF YOUR PERSONAL DATA
8.1. Where we transfer your personal data outside of the St. Vincent and the Grenadines, we will ensure that it is protected and transferred in a manner consistent with legal requirements applicable to the data and where required, with your consent.
8.2. We may put in place appropriate safeguards(such as contractual commitments) in accordance with applicable data protections laws to ensure that your personal data is adequately protected.
8.3. You can request further details about the safeguards that we have in place in respect of transfers of personal data outside the St. Vincent and the Grenadines.
9. PROTECTION OF YOUR PERSONAL DATA
9.1. Walbi uses appropriate technical, organisational and administrative security measures to protect any information it holds in its records from loss, misuse, unauthorised access, disclosure, alteration or destruction. Unfortunately, no company or service can guarantee complete security. Unauthorised entry or use, hardware or software failure and other factors may compromise the security of user information at any time.
9.2. We take the security of our physical premises, our servers, the website, and the application seriously and we will take all appropriate technical measures using recognized security procedure sand tools in accordance with good industry practice to protect your personal data across all of these platforms.
9.3. Users must prevent unauthorised access to user’s account and personal data by selecting and protecting user’s password carefully and limiting access to user’s computer or device and browser by signing off after finishing accessing the user’s account. Transmission of information via regular email exchange is not always completely secure. Walbi, however, exercises all possible means to protect users’ personal data; yet it cannot guarantee the security of user data that is transmitted via email; any transmission is at the users’ own risk. Once Walbi has received user information it will use procedures and security features in an attempt to prevent unauthorised access. When users email Walbi a person may be requested to provide some additional personal data, like their name or email address.Such data will be used to respond to their query and verify their identity.
10.2. Walbi will monitor the effectiveness of this policy on a regular basis and, in particular, the quality of execution of the procedures explained in the policy and, where appropriate, it reserves the right to correct any deficiencies. In addition, Walbi will review the policy at least annually. A review will also be carried out whenever a material change occurs that affects the ability of Walbi to continue to the best possible result for the execution of its users’ orders on a consistent basis using the venues included in this policy.
11.1. The Walbi’s website and application use small files known as cookies to enhance its functionality and improve user’s experience. A "cookie" is a small piece of information that a website assign to your device while you are viewing a website. Cookies are very helpful and can be used for various different purposes.
11.2. These purposes include allowing you to navigate between pages efficiently, enable automatic activation of certain features, remembering your preferences and making the interaction between you and our services quicker and easier. Cookies are also used to help ensure that the advertisements you see are relevant to you and your interests and to compile statistical data on your use of our services.
11.3. The Walbi’s website and application use the following types of cookies:
· ‘Session cookies’ which are stored only temporarily during a browsing session in order to allow normal use of the system and are deleted from your device when the browser is closed;
· ‘Persistent cookies’ which are read only by our website, saved on your computer for a fixed period and are not deleted when the browser is closed. Such cookies are used where we need to know who you are for repeat visits, for example to allow us to store your preferences for the next sign-in;
· ‘Third party cookies’ which are set by other online services who run content on the page you are viewing, for example by third party analytics companies who monitor and analyze our web access. We use the following third parties for analytics and communication purposes: Google Analytics, Intercom, Facebook, Hotjar.
11.4. Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visit www.aboutcookies.org or www.allaboutcookies.org. Find out how to manage cookies on popular browsers:
11.5. To opt out of being tracked by GoogleAnalytics across all websites, visit http://tools.google.com/dlpage/gaoptout.
12. CONTACT US
If you have questions, complaints or concerns regarding the way in which your personal data has been used, please contact:
Company name: Walbi LLC
Company number: 3001 LLC 2023
Jurisdiction: Saint Vincent and the Grenadines
Registered office: Euro House, Richmond Hill Rd, Kingstown, St. Vincent and the Grenadines