Privacy Policy

Updated: 17.05.2021

CW LAB OÜ, referred to herein also as “CW LAB”, “we”, or “Company”, is committed to protecting user (also referred as “you”) privacy as outlined below. This document, along with the Terms of Use document, outlines different ways that CW LAB will interact with user data. This data may be processed, distributed, and/or collected. Our privacy policy was written in accordance with the Personal Data Protection Act 15.01.2019 in Republic of Estonia and General Data Protection Regulation (EU) 2016/679.

We collect data from those who visit our website https://cryptowallet.com, application, or other online Services and Products. CW LAB users acknowledge and give consent to this data collection and to our Privacy Policy as a whole by using our Services and Products.

PERSONAL INFORMATION: GATHERING AND USE

When you visit our website, we may collect information such as your name, home address, email address, IP address, Personal ID code; copies of identity and other documents, Selfie Foto, browser and OS information, geolocation, financial data, e.g. ownership and source of funds and/or wealth, date of birth, transaction data and the nature of using the service, e.g. transaction sums, counter-parties, bank account and card number(s) and account holders and other information which we may request in order to provide our services and comply with regulations. Data may be used to:

1. Authorize users to open an account on our website or application;

2. Respond to user queries or complaints;

3. Contact users;

4. Process and facilitate fiat and crypto transactions;

5. Maintain account security through measures such as 2FA;

6. Analyze user behavior and trends on our website to improve its performance;

7. Comply with regulations such as for anti-money laundering and fraud prevention purposes;

8. Anonymized market research that allows us to improve our services and optimize our performance for user experience. Users may opt for their data to be non-anonymized.

9. Inform users of products and offers that may interest them, including from third-party organizations if users have agreed to allow for this type of information to be sent to them;

10. If we want to sell our business, or our company, we can disclose it to the potential buyer;

11. We may contract with third parties to supply services to you on our behalf. These may include payment processing, search engine facilities, advertising and marketing.

12. Personal data might be used also for development, testing, improvement and implementation of services, products and service environment, service usage statistics, internal data exchange, network and services security control and other commercial information exchange.

User information is collected in two ways. We will often request that users provide information manually, such as by sending copy ID documents or bank statements to our Company. User data may also be gathered from first party and third party cookies, as outlined in our Cookie Policy. Using our services will typically lead to cookies being stored containing personal or financial information.

We may gather user data from publicly available sources such as online search engines, the media, company registers, and electoral registers. We may gather information about our users learned through the course of a user’s time spent interacting with our website, application, and services.

We may receive and gather information from third parties such as government agencies, financial regulators, and financial institutions or payment providers as permitted by the relevant legal regulations.

We may gather information about users from devices and browsers used to interact with our website, application, or services. This includes user devices, IP addresses or telephone numbers, and more, as legally permitted.

Technology used to gather data:

User Submission. Users submit much of the aforementioned data directly by filling out the information forms on site or sending us scanned documents, and users always have the choice of not sending this data and opting out of a service.

Log Files. Files used to keep a record of browser types, IP addresses, time stamps, pattern information such as the number of user clicks, referring pages, and exit pages are called Log Files. These files are typically collected on the majority of website servers. In our case, the files are gathered to analyze user trends, enhance the performance of our website or application, and to prevent fraud and other bad practices.

Cookies. Web servers often send information from a web server to a user’s web browser. This information is called a cookie, and it’s stored on the user’s hard drive. Cookies enable web browsers to remember individual user habits, logins, and other personal information. When your web browser automatically fills in your usernames or passwords for any website, this is due to stored cookies on your hard drive. You can choose to disable cookies in your browser, and this may result in reduced functionality on both CW LAB Website and Application as well as any other sites and applications.

WHO ELSE WILL SEE USER DATA

CW LAB uses personal information gathered from our users in accordance and compliance with legal regulations. We may distribute personal information to third parties such as affiliates, payment service providers, financial institutions, controllers, representatives, legal staff, partners, and contractors.

Data may be shared in the event of a corporate merger or re-organization, or in the event that one of our products or services is sold as an asset to another company. In such cases, we will notify users that their information is being shared.

Information may also be shared with law enforcement or regulatory bodies in accordance with local laws. Third parties are required to protect your personal information and use it only for the purposes stated, such as performing a service for our company. All third parties are bound to comply with our privacy policy, with the exception of law enforcement and regulatory bodies.

CW LAB will make third parties accessing your personal information aware of our privacy policy, and these parties will sign contracts binding them to the terms stated in this policy as well as those outlined in privacy and data protection regulations.

Partners and Other Third Parties. CW LAB is a controller responsible for the processing and legally compliant storage and use of your personal information. Controllers and Partners may include CW LAB representatives or affiliate parties. Payment processors, financial institutions, and services responsible for verifying your identification for security purposes are examples of other possible controllers involved in our personal data storage system. CW LAB also uses Ondato UAB (https://ondato.com/) and Jumio (https://www.jumio.com)for KYC/AML verification procedure, ClearHouse (https://www.clearhaus.com/) for credit and debit card processing and acquiring, and CCSPrepay CreditCard Solutions UK Ltd. (https://ccsprepay.com/), Clear Junction (https//clearjunction.com/), Twilio (https://www.twilio.com) for phone number verification, UAB Pyrros Lithuania (https://www.pyrrosgroup.com/) for issuing prepaid cards and other financial services.

These partners and third party representatives may equally have their own privacy, liability policies and terms and conditions that CW LAB users should read. We reserve the right to change our list of partners, affiliates and other third parties without notice.

By using the services provided by CW LAB, you agree with this Privacy Policy, CW LAB Terms of Use and also Partners Privacy Policies, their Terms and Conditions and other relevant conditions.

LEGAL RIGHTS OF USERS

CW LAB users may request access to their personal data which we store. You may request that we make accurate adjustments to your data, or that we erase your data. You have the right to object to us processing your data or to change your mind regarding the permissions we have to interact with your data.

You can contact us at [email protected] for any of the above. In some cases, we may charge a small fee to make these adjustments to data or agreements with specific customers, depending on the nature of the request.

SECURITY

CW LAB protects user data using encryption as well as restricting access to authorized employees and storing data in secure buildings and systems. We use Secure Sockets Layered (SSL) encryption among other features, such as firewalls, virus detection, and PCI DDS encryption which guards payment card and password info. We offer two-factor authentication for users for added security, sending a code to your mobile device for access to your funds.

We have taken all steps within our means to protect user data. Total protection is never possible under any company, including CW LAB. Data submission is at your own risk. We are committed to protecting that data, and we will notify users should any malpractice or damages towards user data occur.

Users are responsible for their own data, including choosing a safe password or agreeing to submit data to third parties companies including CW LAB. We work with affiliate organizations and partners, and they may receive your data overseas depending on our own operations. Data will remain in the EEA unless the European Commission has agreed to authorize another country outside of the EEA to receive data, or if we have entered a contract with a third party to ensure your safety.

RETENTION AND STORAGE OF DATA

CW LAB creates and keeps information records regarding customer accounts, activities, and transactions. These records may be stored digitally or on paper, and in most cases, digital methods are used. These records are necessary to allow us to offer our services and handle user queries, as well as for the purposes of legal compliance. If you terminate your account in CW LAB, we will mark your account in our database as “Terminated”, but we will keep your account information in our database at least for five to seven years. This is necessary to prevent fraud and prevent people who try to commit fraud from being able to avoid their detection by merely terminating their account and opening another one. We keep data for this period to comply with international and local laws and regulations around money laundering.

We may keep data for over ten years in some cases for tax, bookkeeping and regulatory purposes.

CW LAB will not attempt to collect sensitive data not necessary for our operations, and we will not process information belonging to minors under the age of 18.

FRAUD, PHISHING AND EMAIL SCAMS

Please be notified that CW LAB is not in any partnership with entities who represent themselves as customer support agents, providing customer support services via phone and/or social media and promise to help solve your issues for money. If you discovered what you believe is a fraud, phishing, or scam which impersonates CW LAB, please contact us as soon as possible

LINKS TO OTHER SITES

CW LAB websites and applications may link to other sites and online third-party tools and resources. Our privacy policy does not apply to these third-party entities, but to our websites and applications only. Third-party sites and resources are not under our control, and we accept no liability for the use of these sites and resources including losses, technical failures, damages, or any other undesirable outcomes. Users are advised to familiarize themselves with the terms of use and privacy policies for third party sites and resources.

CHANGES AND QUERIES

This Privacy Policy is subject to change at the sole discretion of CW LAB. Users will be informed of any major changes to the policy, and we encourage users to check the policy from time to time for minor changes as they see fit. Changes will typically be due to operational, legal, or regulatory circumstances. To make an inquiry about any of the information listed within this privacy policy, please contact [email protected].