This Privacy Statement describes how WeDeFi Inc. collects, uses, and shares your Personal Data that we receive from you when you visit our website or app or which we otherwise receive or collect from you in the course of, or in connection with, the provision of our products and services and our business operations. It answers the following questions:
- How do we collect Personal Data about you?
- What Personal Data do we collect?
- How do we use your Personal Data, and on what legal basis do we collect your Personal Data?
- How do we keep your Personal Data safe?
- How do we share your Personal Data?
- Do we transfer your Personal Data outside of the European Union?
- What are your legal data privacy rights?
- How long do we retain your Personal Data?
- How do we protect children’s privacy?
- How do we use your Personal Data to inform you and market to you?
- How do we make changes to this Privacy Statement?
- Where does this Privacy Statement apply?
- Who can you contact if you have further questions or requests about your privacy?
This privacy statement is issued on behalf of the WeDeFi Inc. so when we mention “WeDeFi,” "we," "us" or "our" in this privacy statement, we are referring to the WeDeFi Inc.
It is important that you read this Privacy Statement together with any other privacy statement or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Statement supplements the other notices and is not intended to override them.
How do we collect Personal Data about you?
We collect information from and about you when you register with us or use our products, services or apps (our “Service”) or use our website or software applications, or access or use third-party services that use our Application Programming Interface (“API”).
- When registering with us as a customer, we ask you for detailed information, which we will use to verify your identity and protect against fraud, among other reasons discussed below.
- We gather Personal Data at other times when managing your WeDeFi account, such as from surveys, during support or customer care or during investigations.
- We automatically collect information sent to us by your computer, mobile phone or other device so improve your experience.
- When you use a location-enabled device with our Service, we may collect geographical location data or use various means to determine your location, such as sensor data from your device that may, for instance, provide data on nearby cell towers and Wi-Fi access spots.
As you interact with our website or software applications, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs, and other similar technologies. Cookies are small data files stored on your hard drive by a website. Cookies help us make our website and Service and your use of them better by allowing us to recognize your browser and capture and remember certain information. You can also adjust your browser settings to disable cookies, but it may affect your ability to use the Service and our website.
We may receive data from third parties about you. This may include technical data from analytics and advertising partners like Google, from identity verification providers, as well as from other financial institutions.
What Personal Data do we collect?
WeDeFi only collects the Personal Data we need in order to offer and support our Service and meet our legal and regulatory obligations, which may vary depending on our relationship with you.
Here is an overview of the Personal Data we collect from or about you:
- Identity verification data: To verify your identity, we collect your name, address, phone, email, and other similar information. We may also require you to provide additional Personal Data for verification purposes, including your date of birth, taxpayer or government identification number, or a copy of your government-issued identification. We may obtain information from affiliated and non-affiliated third parties, such as credit bureaus, identity verification services, and other screening services to verify that you are eligible to use our Services, and will associate that information with the information we collected from you.
- Account activity data: We collect information about your transactions, payments from or to you, and your other activities on our site or Service and other details of products and services you have purchased from us.
- Application use data: We may collect data on your interaction and use our Service. This includes visits to our website or app, sign-up activity, your bank account, credit card , other payment details to enable you to enter into transactions on the Service, along with any additional information you may disclose to our user support team in order to resolve problems you report.
- Your device data: We collect and process your internet protocol (IP) addresses, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or any of our software applications.
- Marketing data: We collect and process your preferences in receiving marketing from us, your email address, including hashed identifiers derived from email addresses for the purposes of cross-device tracking for targeted advertising, and where you may have seen WeDeFi advertisements.
- How do we use your Personal Data, and on what legal basis do we collect your Personal Data?
Listed below are the ways in which we may use and process your Personal Data and the legal grounds we rely on to do so.
- Providing our Service to you: We need your data to make WeDeFi work in the first place. Without your name, banking information and other details, we simply could not offer you our products and services.
- Identity verification: For certain financial services, it is essential that we are able to confirm the true identity of our users. There are rules and regulations across the globe that require we identify our customers, including laws concerning anti-corruption, anti‐bribery, anti‐terrorism, and anti‐money laundering.
- Keeping you informed: It is important for security and financial transparency that we keep you aware of your transactions and related activity at WeDeFi. We will send you emails with confirmations, invoices, technical notices, updates, security alerts, legal and support and administrative messages.
- Investigations: Occasionally, we need to look at your account activity in order to check and protect against fraudulent, unauthorized or illegal behavior.
- Managing and improving our Service: We like to understand how our users engage and use WeDeFi in order to make sure WeDeFi is the best it can be. This process includes combining different account, transactional, marketing and other data to analyze the effectiveness and performance of our Service.
- Behavioral Advertising and Analytics: This process includes combining different account, transactional, marketing, and cross-device tracking. When we apply these techniques we may use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We may also use information from your mobile device, such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier for advanced attribution and analytical purposes including personalized or lookalike advertising. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here. You can opt-out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. Or by visiting any of the links below: http://optout.networkadvertising.org/or http://youronlinechoices.eu/.
- Communicating with you: We want you to be aware of product updates, news, events, and promotions and, if you consent, we will send you information, including regular personalized emails, to keep you up to date with all things WeDeFi.
- Business operations: We may need to use your Personal Data for our business operations, including internal training and administration, legal compliance, to enforce our legal rights, to protect third party rights, and in connection with a business transition such as a merger, acquisition by another company, or sale of all or a portion of our assets.
- Website and software applications: We use data analytics to improve our website and software applications, activities and operations, products/services, events, etc.
- Third parties: If you authorize applications or third party integrations on or using our Service, these parties may receive detailed information about your account, your use of the Service, transaction history or even the ability to take actions on your behalf. When you authorize an application or third party integration via the WeDeFi platform, you will be notified of what Personal Data will be shared with these third parties. Information collected by these applications or third-party integrations are subject to their terms and policies and are required by contract by WeDeFi to maintain the confidentiality and security of your Personal Data.
The primary legal grounds upon which we collect and process your Personal Data are:
- through obtaining your consent at the time of collection,
- due to the necessity of doing so to perform the services as requested,
- in order to comply with our legal obligations, and
- to pursue our legitimate interests (e.g., to improve our services).
Note that we may process your Personal Data for more than one lawful basis depending on the specific purpose for which we are using that data.
How do we keep your Personal Data safe?
We have implemented security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed.
We protect your Personal Data by maintaining physical, electronic, and procedural safeguards, incorporating tested security technologies, in compliance with applicable laws. We may use network safeguards such as firewalls and data encryption, enforce physical access controls, and authorize access to Personal Data only for those people who require access to fulfill their job responsibilities.
In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality. Those with access to your Personal Data are carefully screened, periodically reevaluated, and are required to keep all your Personal Data confidential.
How do we share your Personal Data?
Please note that some of our service providers may be based outside of the European Economic Area (the “EEA”). These service providers may work for us or for one of our suppliers and may be engaged in, among other things, the fulfilment of your request for information, products and services, the processing of your payment details and the provision of support services.
Where we transfer your data to a service provider that is outside of the EEA we seek to ensure that appropriate safeguards are in place to make sure that your personal data is held securely and that your rights as a data subject are upheld. Transfers of personal data are either made:
- to a country recognised by the European Commission as providing an adequate level of protection; or
- to a country which does not offer adequate protection but whose transfer has been governed by the standard contractual clauses of the European Commission or by implementing other appropriate cross-border transfer solutions to provide adequate protection.
By submitting your personal information, you agree to this transfer, storing or processing. If you would like more information about how the mechanism via which your personal data is transferred please contact firstname.lastname@example.org.
We do not sell, trade or otherwise transfer your Personal Data to third parties other than third parties who assist us in operating our Service, maintaining compliance with relevant laws, conducting our business or supporting our users, or providing you with applications or services integrated via our API. We require that those third parties agree to keep this information confidential and secure on the same conditions and protection levels we provide to you as a user, in accordance with relevant privacy laws, including the GDPR.
What are your legal data privacy rights?
You have the right to:
- Access the Personal Data we store about you or to request a copy of it.
- Request that we correct inaccurate data about you.
- Ask us to delete or object to us processing your data, although for legal reasons (e.g. anti-money laundering rules and regulations) we cannot always do this.
- Withdraw your consent to receive marketing communications.
You can exercise this right at any time by writing to us at email@example.com.
How long do we retain your Personal Data?
We will hold your personal information on our systems only for as long as required to provide you with the products and services you have requested, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
In some circumstances you can ask us to delete your data: see “Your Legal Data Privacy Rights” for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Please be aware that we may keep your Personal Data for five years or more from the date you cease to be our customer, depending on applicable law or regulations in the jurisdictions we operate.
How do we protect children’s privacy?
We do not knowingly solicit or collect information from individuals under 18. If we become aware that a child under the age of 18 has provided us with Personal Data, we will close the account and restrict their information. If you believe that we might have collected Personal Data from a child under 18, please contact us at legal@wedefi.
You also have the right to lodge a complaint to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.