▶ Privacy Policy

WOOTECH Limited and our affiliated companies (”Company”, “we,” or “us”) are very concerned about the proper data processing rules and adjusting our principles to the law, especially the General Data Protection Regulation of 27 April 2016 (GDPR) and the laws and regulations in different countries. 

This Privacy Policy explains how we collect, use, process, disclose, share, transfer, and protect personal information obtained through us and our partners. This Privacy Policy also describes how we  comply with our legal obligations to you, and how we respect your ability to know, access, correct, transfer, restrict the processing of, and delete, your personal data.

When we ask for certain personal information from users, it is because we are required by applicable laws or government orders to collect such information or it is relevant for our specified purposes.

It is important to point out that we may amend the Policy from time to time. Please just visit this page if you want to stay up to date, as we will post any changes here.

This Privacy Policy constitutes a part of Terms of Use （the “TOU”). The terms used in this Privacy Policy shall have the same meanings as in the TOU except as otherwise provided herein.

Below you will find details on how we process your personal data, how we secure it and who it is shared with. If you have any further questions, please contact: support@woo.network .If you are dissatisfied with any aspect of our Privacy Policy, you may have legal rights and, where relevant, we have described these as well.

The Policy applies in relevant countries throughout our international network. We control your personal data depending on where you live. Different countries may approach different kinds of privacy policy or regulation in different ways. We also have country-specific parts to the Policy. This allows us to ensure that we're complying with all applicable data privacy protections, no matter where you are.

A. HOW WE COLLECTS INFORMATION ABOUT YOU

We process your personal data whenever you use WOO Network,  WOO X, any API or third party applications relying on such an API, or any other services (collectively, the “Services”). When you use the Services, we collect information or data sent to us through your computer, mobile phone, or other access device for the purposes as set forth hereunder.

We do not target our websites, mobile apps, API, or any of the Services at children. We do not intentionally collect information from children. If we become aware that we have inadvertently received personal data from a user under the age of 18 (or any lower age pursuant to applicable law), we will delete such information from our records.

If you create an account or use the Services, we, or our affiliates or Vendors (as defined hereunder) acting on our behalf may collect the following types of information for the purpose as set forth hereunder:

• Account Information – your email address and password;
• Contact Information – your name, birth of date, address, phone number;
• Identity Verification Information - our ID number, image of your government issued ID, passport, national ID card, driving license, your selfie along with the above mentioned ID documents, and related information;
• Financial Information - withdrawal address, source of fund, source of wealth, and image of bank statement or similar information;
• Nationality/Residence Verification Information - your address, nationality, country of residence, and utility bill or similar information; and/or
• Survey Information - certain personally identifiable information you provide in response to our survey. This may include details about your education history, income and your employment;
• Technical information - IP, login information, browser information, time zone setting , operating system and platform;
• Information about your visit - full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page. We also use (or may use) cookies and web beacons when you visit our Site. For more information on our use of cookies and web beacons, please refer to our Cookie Policy;
• Information about geo-location - real-time location based information from your device at any time while you download or use our services. We may use this information to optimize your experience;
• Information we receive from other sources - We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

As of the time of this version of Privacy Policy, we have engaged certain vendors for the following services that may collect your personal information (the “Vendors” or “Service Providers”)

(1) Internet infrastructure - cloud storage and cloud computing;

(2) Communication tools and platforms - SMS services, email services, and push notification, and customer support tool;

(3) Error collection tools - web page error message collection, APP crash tracking, web and APP experiment (A/B testing), and APP statistics;

(4) User behavior analysis - user behavior tracking tool and bot prevention tool; and

(5) Anti-money laundering tools - such as AML database.

Please note that the above information is only used for compliance and AML/CFT procedures. We will NOT use the above information for advertising or will NOT provide it to third-party advertising vendors.

If you seek permissions to raise cryptocurrency buy and sell limits associated with your WOO X account, we may require you to provide additional information to verify your identity or address, and/or to manage risk. This information may include your date of birth, taxpayer or government identification number, a copy of your government-issued identification, or other personal data. We may also obtain information about you from third parties such as credit bureaus and identity verification services.

When you use the Services, we collect information about your transactions and/or your other activities on our website and we may continuously collect name and type of your computer, mobile device, or other access device, such as the name and device of your operating system, for fraud prevention purposes, to monitor for possible breach of your WOO X account, and to identify any malicious software or other activity that may harm WOO X or its users.

You may choose to provide us with access to certain personal information stored by third parties such as social media sites (such as Facebook, Google, Twitter and any other Third Party). The information we have access to varies by site and is controlled by your privacy settings on that site and your authorization. If you associate an account managed by a third party with your WOO X account and authorizing WOO X to have access to this information, we may request your consent that WOO X may collect, store, and use this information in accordance with this Privacy Policy.

Finally, we collect additional information that you provide voluntarily to our customer success team.

B. HOW WOO X PROTECTS AND STORES PERSONAL DATA

Throughout this Privacy Policy, we use the term “personal data” to describe information relating to an identified or identifiable natural person (“Data Subject”); an identifiable natural person is one who can be identified, directly or indirectly, 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 natural person. This Privacy Policy does not apply to personal data that has been anonymized so that it does not and cannot be used to identify a specific individual or be de-identified.

We will use a number of IT and organisational solutions that aim to minimise the risk of data leakage, its destruction or disintegration, such as: firewall system, antivirus, internal access regulations and data processing provisions. Please, however, bear in mind that using the Internet increases the risk of safety-breaching incidents. We strive to assure that those risks are limited to the minimum. 

If you suspect any misuse or loss of or unauthorised access to your personal information please let us know immediately.

We store your personal data securely throughout the life of your account or any your experience or navigation in  WOO X, unless otherwise for a shorter period required by this Privacy Policy. We Will retain your personal data for a maximum of ten years or as necessary to comply with our legal obligations or to resolve disputes.

We store and process your personal and transactional data, including certain payment information, where our facilities or our service providers are located in Japan.

We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, or unauthorised access.That's why we put in place appropriate measures that are designed to prevent unauthorised access to, and misuse of, your personal data.

C. HOW WOO X  USES THE PERSONAL DATA WE COLLECT

Our primary purpose in collecting personal data is to provide you with a secure, smooth, efficient, and customized experience. We use your personal data to:

• Provide the Services and requested customer support;
• Process transactions and send notices about your transactions;
• Resolve disputes, collect fees, and troubleshoot problems;
• Prevent and investigate potentially prohibited or illegal activities, and/or violations of our posted user terms;
• Customize, measure, and improve our Services and the content and layout of our website and applications;
• Deliver targeted marketing, service update notices, and promotional offers based on your communication preferences, which may include but not limited to, the service or products of our business partners; and/or
• Verify your identity by comparing your personal data against third-party databases.

We process your personal data on one or more of the following legal bases in accordance with applicable rules and regulations, including the General Data Protection Regulation (GDPR) in EU:

With the consent from you, we may provide you with WOO X and our Services. On the same basis, we may also optimize and enhance WOO X for all customers, or for you specifically;

For our legitimate business purposes, we may monitor the usage of WOO X, conduct automated and manual security checks of our Service, to protect our rights and perform our lawful obligations; and/or

In order to comply with legal obligations under applicable rules and regulations, we may conduct AML/CFT procedure, anti-fraud procedure, identity verification and authentication checks.

We will not use your personal data for purposes other than those purposes we have disclosed to you, without your consent. From time to time we may request your consent to allow us to share your personal data with third parties for the purpose of providing the Services. You may refuse to provide or may withdraw your consent at any time without adverse consequence. Your refusal and withdrawal of consent will have no effect on the services we provide hereunder, provided that such consent is not necessary for our performance of the Services hereunder.

We do not engage in individual automated decision-making.

Any communications we send to you will either be related to your account or will be related to WOO X services or products. In the event WOO X sends any communication to you which is not related specifically to your account, WOO X will provide you with an “unsubscribe” mechanism through which you may opt out of receiving other similar messages in the future.

D. HOW WOO X SHARES PERSONAL INFORMATION WITH OTHER PARTIES

We may share your personal data with the following parties for the following reasons.

1. Various service providers. 
   The vendors or service providers, as set forth in this Privacy Policy, are those under contract to help with parts of our business operations, such as know-your-customer procedure, bill collection, marketing, and technology services. Our contracts require these service providers to only use your personal data in connection with the services they perform for us and prohibit them from selling your information to anyone else.
2. Authorized Third Party Applications. 
   If you authorize one or more third-party applications to access your account, the information you have provided to us may be shared with those third parties. Unless you provide further authorization, these third parties are not allowed to use this information for any purpose other than to facilitate your transactions made during your use of the Services.
3. Prospective M&A Partners. 
   Our business plans may entail discussions with companies or other entities that we plan to merge with or be acquired by, or companies intending to acquire certain portions of our business. Should such a merger or acquisition occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal data. You will receive prior notice of any change in the applicable policy.
4. Law enforcement, government officials, or other third parties. 
   We may be required to disclose personal data if and when compelled to do so by a subpoena, court order, or similar legal procedure.
5. Miscellaneous.
   We may also make disclosures of personal data if we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of our terms and conditions of use.

Before we share your personal data with any third party, we will, to the extent permitted by applicable laws, rules, or regulations, enter into a written agreement or seek other safeguards requiring that the third party provide at least the same level of privacy and data protection as set out hereunder.

If you establish a WOO X account indirectly on a third-party website or via a third-party application, any information that you enter on that website or application (and not directly on a WOO X website) will be shared with the owner of the third-party website or application and your information may be subject to their privacy policies.

E. COOKIES POLICIES

Cookies are small text files or data placed in your computer browsers and hard drive  to collect standard internet log information, to store your preferences, and your behavior information. When you visit our website, we can automatically collect information from you through cookies or similar technologies. We may use cookies to help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

1. How do we use cookies?
   
   We  use cookies to track your use of our website. This allows us to understand how you use our website and track any patterns that emerge individually or from larger groups. This helps us to develop and improve our website and services in response to what our visitors want and need; and
   
   
2. We  categorise Cookies as follows:
   
   1) Session cookies: 
   these are only stored on your computer during your web session and are automatically deleted when you close your browser –  they usually store an anonymous session ID allowing you to browse a website without having to log in to each page but they do not collect any information from your computer; or
   
   2) Persistent cookies:
   a persistent cookie is stored as a file on your computer and it remains there when you close your web browser. The cookie can be read by the website that created it when you visit that website again.
   
   
3. We also categorise cookies  as follows
   
   1) Strictly necessary cookies: 
   Without these cookies, Our Services available to you on our website cannot be provided. These cookies are essential to enable you to browse around our websites effectively and therefore cannot be turned off.
   
   2) Functionality cookies: 
   We use such cookies to help us identify you and remember your previous preferences and settings, which may include your device, your operating system, your preferred language, your user name, or the region you are in, and other session data. These cookies allow our website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced features. These cookies can also be used to remember changes you have made to text size, font and other parts of web pages that you can customise. They may also be used to provide services you have requested such as viewing a video or commenting on a blog. The information these cookies collect is usually anonymised. By doing so, cookies enable us to monitor and improve the performance of our website.
   
   3) Performance Cookies
   These cookies collect information about how you use our websites — for example, which pages you go to most to see which sites are most popular, or allow us to count your visits and. This data may be used to help optimize our websites and make them easier for you to navigate. These cookies don’t collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous.
   
   4) Marketing Cookies
   We use these cookies to collect information about your visit to our website, the content you view, the links you follow, your IP addresses and referral URLs, and other information about your browsers, device. We may also share online data collected through cookies with our marketing partners. This means that when you visit another website, you may also be shown advertisements based on your browsing patterns on WOO X.
   
   If you would prefer the above cookies were not collected and want to disable cookies. You may choose to opt-out by changing your browser settings. You can choose to accept all or some, or reject cookies in your browser's privacy settings. Each browser is different, so check the "Help" menu of your browser to learn how to change your cookie preferences.

F. SPECIFIC CONSENT BY USERS IN THE EUROPEAN ECONOMIC AREA

If you are located in, or a resident of, the European Economic Area (“EEA”), we, with your specific and voluntary consent, may transfer your personal data to our affiliates and Vendors, for the specific purposes of performing identity verification or checking, to enable us to prevent fraud and comply with our legal obligations.

The United States may not have protections in place for personal data as extensive as those within the EEA and may not provide adequate protection for personal data within the meaning of the GDPR. Although we rely on your explicit consent to the transfer rather than an alternative data transfer mechanism, we require our service providers to treat your personal data in strict confidence and use appropriate security measures to protect it.

You may refuse to give or revoke your consent to this international transfer of your personal data at any time by emailing support@woo.network with the subject line “Revoke EEA data consent”. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use WOO X and our services. You will have the ability to withdraw Digital Assets; however, all other functionality will be disabled.

G. HOW YOU CAN CONTACT US ABOUT PRIVACY QUESTIONS AND EXERCISE YOUR DATA SUBJECT RIGHTS

If you have questions or concerns regarding this policy, or if you have a complaint, you should first contact us on our support page by emailing support@woo.network.You have the following rights:

• Right of access: You can request information about your personal data and request a copy of that data.

• Right of rectification: You can request that we correct or update your personal data if they are incomplete or incorrect by WOO X at any time by submitting a request to: support@woo.network with the subject line “Revise Personal Information”.

• Right to restriction: You can request that we restrict the processing of your personal data.

• Right to erasure: You can request erasure of your personal data, if the data are inaccurate or processed in a way which is incompatible with the purpose(s) pursued by us.

• Right to data portability: If we process your personal data on the basis of a contract with you or based on your consent, you can request to receive your personal data in a structured, commonly used and machine-readable format, and ask us to transfer such data to a third party, where technically feasible.

• Right to objection: You can object to the processing of your personal data for direct marketing purposes at any time.

• Right to lodge a complaint: You can lodge a complaint.

• Right to refuse or withdraw your consent: You can refuse to give and withdraw your consent to data processing at any time. You can also oppose processing of your personal data, based on our legitimate interests, including profiling based on this provision, on compelling grounds relating to your particular situation at any time.

• Right not to be subject to automated individual decision-making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
• Right to deactivate/delete your account: If you no longer wish to use our Services, you have the right to deactivate/delete your WOO X account by submitting a request to support@woo.network with the subject line “Deactivate/Delete Account”. Please note, however, that we may need to retain certain information for record keeping or regulation compliance purposes on a necessary basis.

If you want to exercise these rights, you can contact us at support@woo.network  .We may ask you for proof of identity when making a request to exercise any of these rights. We do this to ensure we only disclose information when we know we are dealing with the right person.

We will not charge you for any of these requests unless we think your request is unfounded, repetitive or excessive. Where a fee is necessary, we will inform you before we proceed with your request.

We will respond to all valid requests within 30 days. It may however take us longer if the request is particularly complicated or you have made several requests. We will always let you know if we think a response will take longer than one month. To speed up our response, we may ask you to provide more detail about what you want to receive or are concerned about.