Last updated: May 2023
Protecting your personal information is an important priority for Wallex Foundation (referred to as “Wallex Foundation”, “we”, “us” or “our” in this notice). This privacy policy is designed to support this objective and, where applicable, sets out how we will process personal information as a Data Controller. We collect non-public personal information provided by you or your representative on applications or other forms furnished to us or through other interactions that you or your representative have with us. We urge you to read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use, and share personal information and on how to contact us and supervisory authorities in the event you have a complaint. This Privacy Policy applies to websites owned and operated by us and as well as all services provided by Wallex Foundation.
We do not disclose any non-public personal information about you, except as permitted by law. If you decide to close your account, we will continue to adhere to the privacy policies and practices as described in this notice.
How and Why We Obtain Information
We may receive non-public personal information about you (the “Personal Information”) from any of the following sources:
Your applications or forms (for example, name, address, Social Security number, birth date, assets, and income);
Transactional activity in your account (for example, trading history and balances); Information from consumer reporting agencies; Information from other third- party data services (for example, to verify your identity and to better understand your product and service needs);
Other sources with your consent or with the consent of your broker;
We may process the Personal Information for the following purposes:
- Managing and administrating any account you may hold with us on an ongoing basis (the “Services”);
- We will ourself (or through a third party e.g. credit reference agency) process certain information about you or your directors, officers and employees, and your beneficial owners (if applicable) in order to carry out anti-money laundering (AML) checks and related actions which we consider appropriate to meet any legal obligations imposed on us relating to, or the processing in the public interest or to pursue our legitimate interests in relation to, the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an on-going basis, in accordance with our AML procedures;
- to report tax-related information to tax authorities in order to comply with a legal obligation;
- to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation, and prosecution, and to enforce or defend to report tax-related information to tax authorities in order to comply with a legal obligation;
- to monitor and record calls and electronic communications for investigation and fraud prevention purposes, for crime detection, prevention, investigation, and prosecution, and to enforce or defend us and our affiliates’ rights, ourself or through third parties to whom it delegates such responsibilities or rights in order to comply with a legal obligation imposed on us or to pursue our legitimate interests in relation to such matters or the processing in the public interest;
- to monitor and record calls for quality, business analysis, training, and related purposes in order to pursue our legitimate interests to improve our service delivery;
to update and maintain records and for fee billing;
to carry out statistical analysis and market research;
to provide you with information about products and services which may be of interest to you or to the institution you represent, and which processing is necessary to perform a relevant contract with you, comply with legal obligations, and/or which is necessary for our legitimate interests indicated above and/or where the processing is in the public interest; and
- to retain AML and other records of individuals to assist with the subsequent screening of them, including in relation to investment in other funds or the provision of our other services, to pursue our, and (in some circumstances) our clients’ legitimate interests.
- To optimize our platform.In order to optimize your user experience, we may use your personal information to operate, maintain, and improve our Services. We may also use your information to respond to your comments and questions regarding the Services, and to provide you and other users with general customer service.
How We Protect Information About You
We take reasonable security measures consistent with applicable law to protect the security of your Personal Information from being accidentally lost, or used, or accessed in an unauthorized way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality. We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so. We also implement the use of encryption or Secure Socket Layers connections for the transmission of any Personal Information. In so much as personal email is generally not encrypted, we request that no Personal Information be sent to us via email.
We will retain your Personal Information as long as an account is active or as needed to provide you services. You can, at any time, contact our Privacy officer in order to correct, update or change your personal information.
You may, as well, instruct us to remove Personal Information, but you should be aware that it is not technologically possible to remove each and every record of the information you have provided to us from our servers. We will also retain your Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements.
Please keep in mind that it is impossible for us to completely guarantee that the user data will be immune from malicious attack or compromise, therefore you should understand that their transmission of personal data is always on your own risk.
User preferences and opt-out choices
Email, Direct Mail, Telemarketing, and Third-Party Sharing.
You can choose to opt-out of:
Receiving promotional or marketing emails from us at a specific email address;
Receiving direct mail for advertisement purposes;
Receiving calls;
Receiving notifications provided as part of the Services;
Disclosure of your information to third-parties; and
Use of your information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized.
How We Share Information About You
We may share the personal information that we collect about our customers, prospects, or former customers with their brokers or with:
Our corporate affiliates, including internal service providers;
Unaffiliated service providers (for example, printing and mailing companies, liquidity providers, website maintenance, upgrades, new releases and other entities who may provide services at our direction)
Government agencies, other regulatory bodies, and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions)
To credit reference agencies in order to carry out money laundering and identity checks and comply with legal obligations;
To our affiliates and third-party vendors in order to process the data for legitimate purposes;
Other organizations, with your consent or as directed by your broker (for example, if you request personalized performance reporting) or as permitted or required by law (for example, for fraud prevention or to respond to a subpoena)
To competent authorities, courts, and bodies as required by law or requested or to affiliated for internal investigations and reporting. The disclosure of personal information to the affiliates and other third parties set out above may involve the transfer of data to the USA and other jurisdictions outside the European Economic Area (EEA). Such countries may not have the same data protection laws as your jurisdiction. We have put in place the Standard Contractual Clauses approved by the European Union Commission for such transfers of personal data. Please contact Support should you require more information on our international data transfer solution. Our service providers are obligated to keep the personal information we share with them confidential and use it only to provide services specified by us.
Online Privacy
Privacy, security, and service in our online operations are just as critical as in the rest of our business. We use firewall barriers, encryption techniques, and authentication procedures, among others, to maintain the security of your online session and to protect our accounts and systems from unauthorized access.
When you interact with us through online channels (for example, websites and mobile applications) owned and controlled by Wallex Foundation (“Wallex Foundation websites”), we manage personal information in accordance with all of the practices and safeguards described previously.
When you visit our websites, we may collect technical and navigational information, such as device type, browser type, Internet protocol address, pages visited, and average time spent on our websites. We use this information for a variety of purposes, such as maintaining the security of your online session, facilitating site navigation, improving our website design and functionality, and personalizing your experience on our websites. Additionally, the following policies and practices apply when you are online: we provide information to its clients through electronic means only. These include Email, website, and online platform. Kindly note that to receive information electronically from us, a valid Email address is required. We provide information through our website which may not be addressed personally to you.
You should carefully protect the personal information that you submit to us, including your passwords, usernames, location, images and videos, so that third parties cannot manipulate your accounts or assume their identities. We recommend you not to disclose any sensitive information in the public domain.
Cookies and similar technologies
We use cookies and similar technologies to support the operation of our websites. Cookies are small amounts of data that website exchanges with a web browser or application on a visitor’s computer or mobile device.
Cookies help us to collect information about visitors to our websites, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site. Our cookies are also used for security purposes and to personalize your experience, such as customizing your screen layout.
You can refuse or delete cookies. Most browsers and mobile devices offer their own settings to manage cookies. If you refuse a cookie when on our website, or if you delete cookies, you may experience some inconvenience in your use of our websites. For example, you may not be able to sign in and access your account, or we may not be able to recognize you, your device, or your online preferences.
Connecting with us on social media sites
We provide experiences on social media platforms that enable online sharing and collaboration among users who have registered to use them. We may collect the information you provide by interacting with us via social media, such as photographs, opinions, or Twitter handle. Any content you post, such as pictures, information, opinions, or any personal information that you make available to other participants on these social platforms, is also subject to the Terms of Use and Privacy Policies of those platforms. Please refer to them to better understand your rights and obligations with regard to such content.
Wallex Foundation mobile applications
Our mobile applications (“apps”) allow you to access your accounts, trade securities, move money, and access third-party news and research using wireless or mobile devices. Our privacy practices apply to any personal information or other information that we may collect through the apps.
Protecting children’s privacy online
Our websites are not directed to individuals under the age of eighteen (18). We do not intentionally collect information on our websites from those we actually know are under 18, and we request that these individuals do not provide personal information through the sites.
Access to Your Information
You may access and, if necessary, correct your account information through a variety of media offered by your broker and us (e.g., statements or online services). Please contact your broker or support team if you require any additional information.
Data Subject Rights You have the following rights, in certain circumstances, in relation to your personal information:
Right to access your personal information.
Right to rectify your personal information.
Right to restrict the use of your personal information.
Right to request that your personal information is erased.
Right to object to processing of your personal information.
Right to data portability (in certain specific circumstances).
Where you have provided your consent to processing (e.g. to receive information about products and services which may be of interest to you or to the institution you represent), you may withdraw your consent at any time by contacting us by email to the support email. We require your personal information to comply with AML or other legal requirements, failure to provide this information means we may not be able to provide the Services or the service to the institution you represent. You have the right to lodge a complaint with a supervisory authority.
Additional Information
If you are a former customer, your information is treated in the same manner as the information of current customers. We offer several options for accessing and, if necessary, correcting your account information. You can review your information using your statements, or through our automated telephone or Internet services. You may also write or call us with your request for information. If we serve you through an affiliate, please contact them directly.
Changes to the Privacy Policy
We might make changes to this Privacy Policy periodically and we will make effort to notify you of any policy changes. However, we suggest you to revisit this Privacy Policy periodically for any updates.
How To Complain
We hope that we can resolve any query or concern you raise about our use of your information. Those in Designated Countries (being the European Union, European Economic Area or Switzerland) may contact our Privacy officer by contacting us via Intercom chat.
NOTICE TO EU DATA SUBJECTS
Personal Information
With respect to EU data subjects, “personal information,” as used in this Privacy Policy, is equivalent to “personal data” as defined in the European Union General Data Protection Regulation (GDPR).
Legal Bases for Processing
We only use your personal information as permitted by law. We are required to inform you of the legal bases of our processing of your personal information, which are described in the table below. If you have questions about the legal bases under which we process your personal information, contact us via the intercom chat in the app or on our website.
Processing Purpose
Legal Basis
To provide our service
Our processing of your personal information is necessary to perform the contract governing our provision of the Services or to take steps that you request prior to signing up for the Service.
To communicate with you
To optimize our platform
For compliance, fraud prevention, and safety
To provide our service
These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).
To comply with law
We use your personal information to comply with applicable laws and our legal obligations, including anti-money laundering (AML) laws and know-your-customer (KYC) requirements.
With your consent
Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us via in app chat.
Use for New Purposes
We may use your personal information for reasons not described in this Privacy Policy, where we are permitted by law to do so and where the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis for that use. If we have relied upon your consent for a particular use of your personal information, we will seek your consent for any unrelated purpose.
Your Rights
Under the GDPR, you have certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests via the in app chat. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us via the in app chat or submit a complaint to the data protection regulator in your jurisdiction.
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