Global PRIVACY NOTICE
This Privacy Notice explains how we collect, use, process, disclose, share, transfer, and protect personal information obtained through us and our partners. This Privacy Notice 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. It is primarily based on Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR).
This Privacy Notice serves as the main source of information about your privacy. However, we may share more details on some aspects of specific cases in separate notices.
WOOTECH Limited is a controller of your personal data and uses them as you use its exchange WOO X or interact with WOO otherwise. WOO collects and uses information about you based on contractual necessity to offer you services or legitimate interest to run its AML program, marketing initiatives or to defend against claims.
For more details please read the whole Privacy Notice below.
|The Controller of Data
The controller of your personal data is WOOTECH Limited, a company incorporated in the Republic of Seychelles (“WOO”). It means that WOO makes decisions about what information about you is collected and how it is used.
In matters concerning your personal data, including the execution of your rights, you may contact WOO at the e-mail address: firstname.lastname@example.org
WOO has appointed a representative for its customers in the European Economic Area. For all matters under the GDPR, you can reach out to our representative, for example, to execute your rights under the GDPR.
Our representative is:
Kronos Tech Europe sp. z o.o.
Inflancka 4 B, piętro 1
00-189 Warszawa (Warsaw)
WOO uses your personal data for the following purposes:
- Decide if we will provide you with our services. Due to local legal requirements, we have a list of unsupported countries, where we do not provide all or some of our services. We verify your country of residence to avoid serving you some of all services if you are in such an unsupported country. For the complete list of unsupported countries please go to https://support.woo.org/hc/en-001/articles/4403838052761-List-of-unsupported-countries.
We do it on the grounds of legitimate interest - Article 6(1)(f) of the GDPR. Our legitimate interest here is our right to decide where we offer our services.
- Direct marketing via Weekly WOO if you decide to subscribe. Our legal basis is your consent (Article 6(1)a of the GDPR)
- Providing services of our centralised exchange (WOO X). Our legal base is a contractual necessity as we need your personal data to provide our services to you (Article 6(1)b of the GDPR).
- Running our AML program. We do it on the grounds of legitimate interest - Article 6(1)(f) of the GDPR. Our legitimate interest here is counteracting illicit activities, especially money laundering, terrorism financing, breaching sanctions and committing fraud. Within the AML program we may inter alias:
- Perform the Know Your Customer (KYC) process which is an identity verification procedure,
- Monitor your transactions
- Cross-check you with sanction lists
- Ensuring the security of WOO, mainly by performing automated and manual security checks; doing backups of data etc. We do it on the ground of legitimate interest - Article 6(1)(f) of the GDPR. Our legitimate interest here is the integrity of data and continuity of services.
- Address any complaints or other communication from you to us. We do it on the ground of legitimate interest - Article 6(1)(f) of the GDPR. Our legitimate interest here is addressing any communication from customer.
|Source of data
|In majority of cases we collect personal data directly from you. However, we may collect your personal data from other sources as well in following cases:
- AML program - our source will be there data bases run by third parties or governmental agencies i.e. PEP (Politically Exposed Person) database, sanction lists etc.
- When you decide to connect third party solutions with your account we may get some of your personal data from that source, for example, when you register via Google or Apple.
|Right to object
|Whenever we use legitimate interest as the legal ground, you can object to the processing of your personal data based on your particular situation by contacting WOO.
|WOO stores your personal data for period which is related to how you interact with us. Our general periods for storing data are:
- 1 year in case of direct marketing
- 10 years for all transactional data, since transaction was made
- 5 years for AML data since you end relation with us
- 10 years for other data, from the moment you closed your account on WOOX
|Under the GDPR you have following rights in relations with us, concering your personal data. However, applicability of each of these rights depends on circumstances of our relation.
- withdraw consent - Whenever we ask for your consent to process your personal data, you may opt out. However, withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
- access your personal data and receive a copy of it - You are entitled to demand from us detail information about what personal data we process as well as other information.
- rectify (amend) your personal data - you can execute this right whenever your personal data are inaccurate
- have the processing of your personal data restricted - in specific scenarios you may demand from us to restrict further processing
- erasure of your personal data
- object to the processing of your personal data (for processing based on legitimate interest - Article 6(1)(f) of the GDPR),
- data portability - you may demand from us to provide you with a copy of your personal data in machinereadible format or to transfer those data to other company. This right is restricted to specific scenarios under the law.
- to lodge a complaint to the supervisory authority (privacy regulator) - you are entitled to lodge complaint to regulatory body, established under article 51 of the GDPR, which is competent for your complaint based on the country you live in.
WOO process your personal data in various countries - Poland, Taiwan, Japan and the United States.
If your are resident of the European Economic Areas, please be informed that your personal data are transferred to recipients located outside the EEA.
- Taiwan - there is no adequacy decision for this country, hence we utilize Standard Contractual Clauses as a safeguard.
- Japan - for this country European Commission issued adequacy decision.
- The United States - for this country European Commission issued adequacy decision we use processors which are listed in EU-U.S. Data Privacy Framework
|We do share your personal data with various recipients which may be:
- IT services providers like maintenance, cloud services, hosting etc.;
- AML vendors i.e. verification services
- Support companies in the scope of customer support, IT development etc.
- Law firms
- Marketing platforms
- Analytics service providers
|Do I have to share my data with you?
In order to utilise our services, you have to provide your personal data with us. This is necessary under the contract, but there is no statutory obligation to do so.
If you deny to provide data or provide inaccurate data you will not be able to use our services at all or will be granted access only to limited features of WOOX.