1.3. Company, we, us or our mean Wallet Solutions OÜ, a company duly registered and acting under the laws of Estonia, with registered number 14676729, located in Tallinn, Estonia. Contact email - [email protected]
1.4. Please read the following carefully to understand our practices regarding your personal data and how we treat it. Your privacy is important to us.
1.5. This document can be published in different languages for localization purposes, but in case of any discrepancies between the English version and the version in a language other than English, the English version shall always prevail.
2.1. In the event that we do process your personal data, we become the controller of it. In certain cases, we may also be processors or recipients of personal data.
2.2. Users or other persons have the right to directly contact us with problems or questions concerning personal data processing.
2.3. You have the right to make a complaint at any time to the supervisory authority for data protection issues of your country. We would, however, appreciate the chance to deal with your concerns before you approach the authority, so please contact us in the first instance, whenever you are experiencing an issue concerning your personal data.3. The data we collect about you
3.1. We will collect and process the following personal and other data about you:
● When you fulfill KYC (Know You Customer) procedures to use our services, we will collect personal data as necessary to offer and provide the services you request and meet regulatory requirements. We will require you to provide us, where necessary, with your full name, date of birth, ID number, date and place of issue and expiration date, marital status, title, gender, residential address, nationality, telephone number, email address, and other identification information. We may require you to provide us with a photograph of yourself with your ID or other additional personal data as you use our services (place of work, salary and financial status, source of income, source of wealth etc.).
● When you purchase a Security card you need to provide us information such as your name (first name, last name), your email address, phone number, your postal address and other contact information to execute your order and ship the Security card. Some countries may apply customs duties or other import taxes and other import obligations and you will be required to provide us your ID document, tax identification number (TIN) and other requested information.
● When you use our services, for example in Surf app, to buy, sell, exchange or transfer digital assets or order Security card, we collect information about transactions, as well as other information associated with the transaction such as amount sent or requested, amount transferred, your positions in fiat and digital assets, merchant information, including bank account and payment card details.
● We can collect information about the device you use, your account, including the hardware model, operating system and version, and unique device identifiers.
● We can log technical information about your use of the services, including the type of browser and version you use, last access time, the Internet Protocol (IP) address used to create the account, and the most recent IP address used to access.
● When you use or ask for our services, we collect personal data you provide us with the other participants associated with the transaction or account.
7.1. In order to comply with legislation we also reserve the right to collect, purchase or otherwise acquire personal data from third party data suppliers.
7.3. You can also provide us other personal data in your sole and absolute discretion associated with the provided information, but we are asking you not to submit it to us without the need. If you contact us, we will keep a record of that correspondence with all the details.
7.4. We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions (except PEP, politically exposed person, classification), information about your health, genetic and biometric data).4. Retention of personal data
4.1. We retain personal data in an identifiable format for the least amount of time necessary to fulfill our legal or regulatory obligations and for our business purposes (in general, for up to 5 years after the termination of the relationship).
4.3. When using our service, you should understand that your personal data can be kept on a blockchain platform, and this information in an encrypted format or anonymized will be kept in blockchain without limitation. The Company has no physical, technical, and legal ability to delete or change any information in blockchain.
4.4. Because the anonymized information about your transaction can be kept on blockchain, anyone has access to this information. The Company has no possibility to restrict this access or encrypt this data.5. How we use your personal data
5.1. We will only use your personal data when the law allows us to do so, and/or you agree with it. Most commonly, we will use your personal data in the following circumstances:
● Where we need to perform agreements we are about to enter or have entered with you, e.g., the Security card Terms and Conditions, Terms and Conditions for virtual currency service and others.
● Where you have consented before the processing.
● Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
● Where we need to fulfill legal obligations that we are subject to.
5.2. Using our service you give us a consent to send you direct marketing advertisements by email, Telegram, Surf or other alternative communications infrastructure. You have the right to withdraw that consent at any time by contacting us.6. Third-parties
6.1. To use or ask to use our service, including to process your transactions or ship Security cards, we may disclose your personal data to third-parties such as financial institutions, third party reference agencies, data verification service providers, shipping and logistics couriers, warehouses and/or other partners in due course of fulfillment of our agreement with you or on order to comply with our legal or regulatory obligations.
6.2. We will also disclose your personal data to other third parties including: regulatory authorities and law enforcement agencies, non-affiliated third parties for payments processing, payments, sales, data analysis, research and surveys, and/or professional advisors such as tax or legal advisors, consultants and accountants.
6.3. We also may disclose your personal data to affiliated parties including EverX® (EverX Labs) for the purposes of developing, supporting, marketing and other services. 6.4. We use third-party service and using our service you grant us an additional consent to transfer your personal data and KYC checks to specific third-party.7. International transfers
7.1. We are an Estonia-based company. Your personal data may be processed, transferred to, and maintained on servers and databases located within Estonia, EU and elsewhere where the privacy laws may not be as protective as your jurisdiction.
7.3. Using or asking to use our service, you should understand that your personal data can be kept on blockchain decentralized platforms, and the Company cannot manage the footprint.8. Automatic processing
8.1. We can make a decision to provide service and/or send any marketing information based on automatic processing, including profiling.
8.3. You may request the reviewing of the decision which is based on automated processing if you do not agree with the offer or the data it is based on. You may also request not to be subject to a decision based solely on automated processing unless such decision is necessary for the performance of a Contract between us or if you have given us consent to make such decisions.9. Your legal rights
9.1. Under certain circumstances, you have the following rights under data protection laws in relation to your personal data. You have the right to:
● Request access to your personal data (commonly known as a data subject access request). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
● Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
● Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information without compelling legal grounds, or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical (see about the blockchain restrictions) reasons, which will be notified to you, if applicable, at the time of your request.
● Object to processing your personal data where we are relying on a legitimate interest (or those of a third party), and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information, which override your rights and freedoms.
● Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is without compelling legal grounds but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it; (e) you may prohibit the processing of the personal data for direct marketing purposes as well as to refuse the advertisements and offers at any time by informing us thereof.
● Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information, which you initially provided consent for us to use or where we used the information to perform a contract with you.
● Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
9.2. You can exercise any of these rights at any time by contacting us.
9.3. We reserve the right to decline your request to exercise any of the rights under this section if we are not legally obligated to provide such rights under the laws of the jurisdiction of your residence. 9.4. You have a right to lodge a complaint to the Estonian Data Protection Inspectorate (e-mail address: [email protected]
; telephone: +372 5620 2341 or +372 627 4135; address: Tatari 39, Tallinn 10134, Estonia) if you consider that processing of your personal data infringes your rights and interests under the law.10. Cookies
10.1. We do not track your use of the website. We do not collect any analytical data on the website. We do not save and read cookies on the website.
10.2. If you see any cookies in the website you need to clear it and refresh your browser.
10.3. Most browsers allow you to change your cookie settings and delete cookies. These settings will typically be found in the “options” or “preferences” menu of your browser. In order to understand these settings, the following links may be helpful.
Otherwise, you should use the “Help” option in your browser for more details.Cookie settings in ChromeCookie settings in Safari web
and iOSCookie settings in Internet ExplorerCookie settings in Microsoft EdgeCookie settings in Firefox