A.The operative parties referred to in this policy are Company and You, the User of this site.
1. Wowexchange OÜ is the publisher and operator of the website(s) listed at the beginning of this Policy. Hereinafter, Wowexchange OÜ shall be referred to as “Company”. When first-person pronouns are used in this Policy, (Us, We, Our, Ours, etc.) these provisions are referring to Company. Additionally, when the terms “the Site” or “Site” are used, these terms refer to the website(s) listed at the beginning of this Policy, as well as the Services offered via the Site, such as the virtual currency exchange (the “Exchange”) and ancillary services as defined in Our User Terms [A1].
2. You, the User – As the User of this Site, this Policy will refer to the User as “You” or through any applicable second-person pronouns, such as “Yours,” etc. Hereinafter, the User of the Site shall be referred to in applicable second-person pronouns.
2. Revisions to This Policy
We reserve the right to revise, amend, or modify this Policy and Our other policies and agreements at any time and in any manner. You should periodically check for any modifications of this Policy by re-visiting this web page and using the “refresh” button on Your browser prior to Your use of the Site and the Services. You should note the date of last revision to this Policy, which appears at the top of this Policy. If the “last modified” date remains unchanged after You have clicked the “refresh” button on Your browser, you may presume that no changes have been made since the last reading of the Policy. A changed “last modified” dates, indicates that this Policy has been updated or edited, and the updated or edited version supersedes any prior versions immediately upon posting. In a merger or acquisition of the Company, customer personal information will likely form part of the assets to be transferred. Any and all changes to this Policy arising from such merger or acquisition will be posted on the Site and You will be notified of the changes via a news update within Your account(s) settings page
3. Personal Information That We Collect
Visitors to Our Site, and users of Our Services, will have multiple manners of interactivity with Us. Depending upon Your level of interaction, We will collect different information about You. The type of information collected is as follows:
1. Members – Members are those Users who interact with Our services in a way which requires registration, for example, participating in the Exchange or Our user discussion forums, if applicable (“Forums”). As a Member, You may be prompted to provide Your name, Your residence address and mailing address (if different), Your telephone and fax numbers, a valid email address, Your date and place of birth, Your state-issued driver’s license number, a copy of a valid photo ID (such as a driver’s license, passport, armed forces identification card or alien identification card), proof of residence, Your government issued identification number (e.g., Passport number, social security number, employee identification number or taxpayer identification number), other personal information necessary to verify your Identity, Your credit card information, and Your Bitcoin addresses and related information (“personal information”) which may lead to Your identification.
2. Browsers –Browsers are visitors to the Site who never enter into any active data collection pages or use the Services or Exchange. Browsers may, however, view content posted by Members. Any information gathered from Browsers is also gathered from Members. This information is restricted to cookies, IP Addresses and Referral URLs, and other passive information gathering devices. Browsers are also considered Users of the Site.
4. How We Collect Information From You
a) By reading and understanding and by proceeding further to continue access to and use of the Site you have hereby give your consent to the us to: –
a1) store and process your Personal Data;
a2) disclose your Personal Data to the relevant governmental authorities or third parties enforcement agencies where/when required by law or for legal purposes.
1. Passive Collection
2. Active Collection
Active Collection –We collect information from You when You register for an account to use the Services or Exchange and when You use such Services
Continues Collection – We may/will actively collect/request information from you when required to update your personal data for time to time. It is essential for you to update us on any changes on information. Kindy refer to our Terms & Conditions or other User policies;
5. How We Use Your Information
The primary uses for Your information are to provide You with services You have requested and/or paid for, to conduct customer identification and anti-money laundering reviews and compliance and to comply with applicable law. We may also use Your information to deliver customized services to You. Member personal information, login information and e-mail addresses may be disclosed to third parties for the purpose of providing certain features or third-party services associated with the Exchange, including Our Anti-Money Laundering client verification providers for the purpose of complying with applicable laws. The Site may contain links to other third party websites, which are regulated by their own privacy policies. We are not responsible for the privacy policies of these other third party websites even if You accessed them using links from the Site or were linked to the Site from a third party website. We are not responsible for how third parties use your information, and You should become familiar with such third parties’ privacy policies prior to requesting their services. Non-personal and aggregate information, such as that collected passively, is used in order to customize Our marketing efforts or to customize the efficient use of Our Site for an aggregate group of customers. We additionally may use the personal information of Users whose membership has expired or has been cancelled in order to market Our services to these individuals in the future.
We generally will use Your information for the purposes for which You specifically provide it, for example, to ensure payment for subscription services, if applicable. We may also use Your information for market research purposes in the form of aggregate data – in order to increase Your (and other Users’) experience according to tracked interests, to analyze and target potential new markets, and for other marketing purposes. Such general information may be shared with third parties to show general service usage but is however not linked to personally identifiable information.
6. Special Cases
We take the protection of Your personal information very seriously and recognise the need to keep Your personal information registered with the Site secure. Save as expressly provided herein, Your personal information will not be passed on by Us or by Our agents for use by third parties in any form whatsoever unless We have obtained Your consent or are legally required to do so or except for the following purposes. It is Our policy not to use or share the personal information about Browsers or Members in ways unrelated to those described in this Policy without also providing You an opportunity to opt out or otherwise prohibit such unrelated uses. However, We may disclose personal information about Browsers or Members (including all information and documentation provided to us concerning a Member), or information regarding Your use of the services or Site(s) accessible through Our services, for any reason if, in Our sole discretion, We believe that it is reasonable to do so, including but not limited to:
1)To satisfy or/and comply with any laws, such as: –
a) The Electronic Communications Privacy Act and/or other respective regulations, legal requirements or governmental, or legal requests by enforcement agencies and/or Any person to whom disclosure is permitted or required by any statutory provision or law;
b) To any local or foreign regulatory body, government agency, statutory board, ministry, departments or other government bodies and/or its officials; and/ or
- Carrying out due diligence or other screening activities as required by regulators and law.
- Fulfillment of any regulatory / legal requirements / applicable laws;
- To protect Ourselves, Our Members, and the general public, we specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed, is suspected, or if we are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process.
- It is further within Our sole discretion to cooperate with and disclose information to law enforcement, private party litigants and governmental agencies, about Our Users to the extent required by applicable law. Examples of such cooperation include lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process;
- Preventing, detecting and investigating fraud, misconduct, any unlawful action or omission, whether relating to your application or any other matter relating to your account(s), and whether or not there is any suspicion of the aforementioned
- To manage and maintain your account(s) and facility(ies);
- Respond to your inquiries and complaints and to generally resolve disputes
- To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms & Conditions or other User policies;
- To operate Our Site, Services and Exchange properly;
- Anyone who violates Our Anti-Spam Policy, if applicable, may have their personal information made public. If there is any investigation on any unlawful spamming, or any use of bulk e-mail in order to promote Your User profile, or any use of bulk e-mail in any manner that leads back to Our Site, or any one of Our Sites, we may take such steps as we deem appropriate in our discretion to ensure that Your bulk e-mail activities stop
- If we have reason to believe that a Member is not the owner of a credit card (s) or other account(s), even if the credit card (s) or account (s) use is authorized by the owner of the said product, we are required provide information about you to the credit card and/or account holder and/or appropriate authorities.
- In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in India or outside of India, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
7. Transmittals From Us
We may send You periodic announcements including the details of Our existing and new programs. You may opt out of these announcements by contacting email@example.com or by clicking the opt-out link at the bottom of these emails. If You opt-out of these marketing emails, You may still receive system notices and other information that is specifically related to Your account.
If You provide Your information to Us, use the Site, or subscribe to any of Our Services, including the Exchange, You will have created a commercial relationship with Us. In having done so, You understand that even unsolicited commercial email sent from Us or Our affiliates is not SPAM as that term is defined under applicable law.
8. Our Commitment to Data Security
We will retain control of and responsibility for the use of any personal information You disclose to Us. We take measures to protect the transmission of all sensitive User information. We make all reasonable efforts to ensure the integrity and security of Our network and systems by utilizing encrypted software and protective firewalls. All User information is retained in-house for the life of the account and is secured via administrative password protection. Nevertheless, We cannot guarantee that Our security measures will prevent third-party ‘hackers’ from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but You however acknowledge and agree that communications through the internet is not entirely secure and hence, We are unable to guarantee that Our security is one hundred percent (100%) breach-proof. You assume the risk of such breaches to the extent that they occur despite Our reasonable security measures. Our security procedures shall nevertheless continuously be revised based on new technological developments. Whilst We have security measures in place to protect Your personal information, please do not send any other confidential or proprietary information through the Site. You should exercise extreme caution when disclosing such confidential or proprietary information in this way. We shall not be responsible for any loss or damage arising from disclosure of such confidential or proprietary information that is sent through the Site.
9. How to Access or Modify Your Information
Retention of personal data
We will retain your personal data, in compliance with this Anti-Money Laundering/Combating the Financing of Terrorism/ Know Your Customer (AML/CFT /KYC/) Policy, for the duration of your relationship with us, and afterwards for such period as may be necessary for our legitimate business purposes (including compliance with our legal obligations, preventing fraud, resolving disputes and enforcing agreements), to protect the interests of the company and its customers, and as required by law. All transaction and identification records will be maintained for a minimum period of 7 years.
Incomplete personal data
Where indicated (for example in online application forms or account opening forms), it is obligatory to provide your personal data to us to enable us to process your application for our products or services. Should you decline to provide such personal data, we may not be able to process your application/request or provide you with our products or services.
Your right to access, update, or remove your personal data
Most of the data we collect, and the ways in which we use it, are necessary for us to provide and improve the services we provide to you, or to comply with our obligations. In certain situations, we give you the ability to choose how we use your data.
Depending on the country in which you live, you may have certain rights under data protection law, including the right to object to the processing of your personal data or to request that we:
- provide you with a copy of your personal data (including in a format that can be shared with a new provider); or
- correct, delete, or restrict the processing of your personal data. Please feel free to contact us at: (email address to be confirmed) if you would like to exercise or find out more information on any of the above rights. These rights are limited in some situations, such as where we are legally required to process your data and may limit your ability to use our products and services and as well for AML/CFT purposes.
We will notify you and the relevant supervisory authority as soon as we become aware of any data breach that is likely to result in a risk to your rights and freedoms
10. How to Access or Modify Your Information
We may offer our Members the opportunity to access or modify information provided during registration. To access or modify such information, contact our Customer Service via (email address to be confirmed)