Privacy Policy

Updated: 20.04.2022

CW LAB OÜ, referred to herein also as “CryptoWallet”, “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 CryptoWallet 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 the Republic of Estonia and General Data Protection Regulation (EU)
2016/679.

We collect data from those who visit our website https://cryptowallet.com, applications and other
products. CryptoWallet 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 financial transactions and services;
  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.

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
CryptoWallet Website and Application as well as any other sites and applications.

WHO ELSE WILL SEE USER DATA

CryptoWallet 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.

CryptoWallet 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. CryptoWallet is a controller responsible for the processing and legally
compliant storage and use of your personal information. Controllers and Partners may include
CryptoWallet 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. CryptoWallet 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/) for fiat transactions.

These partners and third party representatives may equally have their own privacy, liability policies and
terms and conditions that CryptoWallet 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 CryptoWallet, you agree with this Privacy Policy, CryptoWallet Terms
of Use and also Partners Privacy Policies, their Terms and Conditions and other relevant conditions.

SOCIAL NETWORK SERVICES

The user may register CW Account via the CryptoWallet Website, Application or by logging into his
account with a third party social networking service via our Website or Application (e.g., Facebook,
Linkedin, Google or other third party services that let users sign in using their existing credentials with
those services).

In case user chooses to register via an social networking service, or to later link CW account to his
account with a social networking service, CryptoWallet will use the Personal Information user has
provided to the social networking service (e.g., name, date of birth, email address, ip location, gender and
other information he makes publicly available via the social networking service) to create his account.

The user should be aware that the information CryptoWallet collects from and through a social
networking service may depend on the privacy settings user has set with the social networking service and
the permissions he grants to CryptoWallet in connection with linking his account with CW Account to his
account with a social networking service. The Personal Information a social networking service has about
a user is obtained by the social networking service independent of our Service, and CryptoWallet is not
responsible for it.

CryptoWallet also may permit additional interactions or data sharing between it and a third party website,
service, or other content provider. User’s interactions with third parties through a social networking
service or similar features are governed by the respective privacy policies of those third parties. The user
represents that he is entitled to use his social networking service account for the purposes described herein
without breach by user of any of the terms and conditions that govern the social networking service, and
without obligating CryptoWallet to pay any fees or making CryptoWallet subject to any usage limitations
imposed by such social networking service. The user has the ability to disable the connection between his
CW Account and his third party account at any time.

LEGAL RIGHTS OF USERS

CryptoWallet 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

CryptoWallet 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 CryptoWallet. 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 CryptoWallet. 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

CryptoWallet 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 CryptoWallet, we will mark your
account in our database as “Terminated”, but we will keep your account information in our database for at
least 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.
CryptoWallet 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 CryptoWallet 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
promising to help solve your issues for money. If you discovered what you believe is a fraud, phishing, or
scam which impersonates CryptoWallet, please contact us as soon as possible

LINKS TO OTHER SITES

CryptoWallet 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 CryptoWallet. 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].

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