Privacy Policy
INTRODUCTION
We recommend reading this policy carefully to understand our privacy and data protection policies and processes regarding your personal information and how we will handle it. Please do not hesitate to contact us for further information.
This Privacy Policy applies to Wedo Ventures Ltd. (Wedo) and its subsidiaries and operation companies. Whenever this policy says “we”, this refers to Wedo. Whenever this policy says “you”, this refers to users and members of the Wedo platforms as individuals to which this Privacy Policy applies.
Wedo is committed to protecting your privacy and will take all appropriate steps to ensure that your personal information is treated securely and will be collected, used, stored, and disclosed in accordance with this policy and the applicable regulations. This Privacy Policy applies:
- to the Wedo apps and platforms;
- all services provided by Wedo;
- all communication between you and Wedo.
Wedo provides services to individuals and businesses. This policy applies to both, including individuals who are interacting with the Wedo platforms on behalf of a business or registered legal entity.
Wedo services are not intended for children, and we do not knowingly collect data relating to children.
INFORMATION WE COLLECT FROM YOU
Personally Identifiable Information
Wedo is obligated to uniquely identify each member of its services and store proof of this validation. In case you decide to apply for the payment services of the Wedo platforms, Wedo is obligated to share this information with its payment service providers.
For the United Kingdom and European Economic Area, the payment service provider is Accomplish Financial Limited.
Wedo is also obligated to store details about each transaction made by you on the Wedo platforms, including identification of the Internet Protocol (IP) address and unique device identificatory from which the transaction was initiated.
Wedo may share information with Fraud Prevention Service Providers to protect you and Wedo against malicious usage of its services and platforms.
The information we are obligated to store to enable you to use the financial services by Wedo as a full member of its platforms and services include:
- Name including first name and family name;
- Date of birth and age;
- Email address, shipping address, and billing address;
- Username and encrypted password;
- Photographs and biometric information;
- Address, occupation, nationality and country of residence;
- A digital copy of your identification, such as your driver’s license, identity card, or passport
- Your social security number, tax identification number, and other government identification or registration data;
- Credit or Debit Card primary account number, card expiry date, CVC details (card security code), account numbers, bank or issuer details;
- Information relating to any items purchased or offered through the Wedo platforms and services, including the location of the purchase, the value, the time and any feedback that is given in relation to such purchase;
- Information about your use of the Services, such as information about how frequently you transact with us, your average transaction volume, account balances, and the people and Wedo members to whom you send money and from whom you receive money;
- Any other information that you or your customer provide or is generated in the context of using the Services.
Wedo does not collect any Special Categories of personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Non-Personally Identifiable Information
Wedo also collects non-personally identifiable information or may anonymize personal information to ensure it is non-personally identifiable. By using the Wedo platforms and services, you permit Wedo to use this information for commercial purposes within the terms of service and your rights as determined by the General Data Protection Regulation.
Automatically collected Information
Wedo automatically collects information when you interact with the Wedo platforms and services, even when you do not have a Wedo account. This can be done by using technology like cookies and link-tracking, or through information received from our partners.
Wedo also automatically collects information when you interact with Wedo’s social media posts and profiles, or with advertisement by Wedo or its partners.
Collecting this information helps us to better understand our audience and users which enables Wedo to further improve its platforms and services.
If you fail to provide data
Where we need to collect personally identifiable information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
HOW WE USE YOUR INFORMATION
Wedo uses your personally identifiable information to fulfill its obligations towards our financial service providers and authorities to be able to provide you and your business with the services you use through the Wedo platforms and services.
Wedo uses your non- personally identifiable information to analyze the usage of our platforms and services to further improve our offerings.
Wedo uses both your personally identifiable information and non- personally identifiable information to fulfill our risk management and fraud prevention obligations to protect you and Wedo against malicious usage of our platforms and services.
Wedo uses both your personally identifiable information and non- personally identifiable information to inform you about changes and new features of our platforms and services.
Wedo may share your non- personally identifiable information with our marketing and advertisement partners to further improve our marketing strategies.
Wedo will use both your personally identifiable information and non- personally identifiable information to comply with local, national, and international laws and regulations to be able to provide you with our platforms and services.
DISCLOSURE OF YOUR INFORMATION
Wede does not disclose information which could identify you personally, to anyone except as described in this Privacy Policy, as permitted or required by law, especially the General Data Protection Regulation, and for the purposes described in this Privacy Policy.
With your consent, your personally identifiable information may also be used for other purposes for which you give your specific permission.
MONITORING OF COMMUNICATION
Wedo may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, quality assurance or training purposes. Wedo may also use Artificial Intelligence to automatically generate transcripts of telephone calls and meetings.
WHERE WE STORE YOUR PERSONALLY IDENTIFIABLE INFORMATION
Wedo processes and stores your personally identifiable information and non- personally identifiable information within the European Economic Area (EEA). Wedo staff members might be located outside the EEA. By the terms of their employment by Wedo, these staff members act as if located within the EEA and process your information accordingly.
Our service providers may be located outside the EEA and store and process your information according to their local data protection and privacy regulations. Whenever we transfer your personally identifiable information out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personally identifiable information to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we may use specific contracts approved for use in the EEA which give personally identifiable information the same protection it has in the EEA.
HOW WE KEEP YOUR PERSONALLY IDENTIFIABLE INFORMATION SECURE
We have implemented technical, physical, organisational, and administrative measures designed to secure your personally identifiable information from accidental loss and from unauthorised access, use, alteration and disclosure. These measures include:
- A detailed Information Security and Data Protection Process;
- A detailed Incident Response Process;
- Ongoing risk evaluation and mitigation processes;
- A designated Chief Information Security Officer;
- A designated Data Protection Officer;
- An Access Control and Identification process that ensures proper authentication of authorized users and their permissions;
- Zero-Trust processes throughout the organization;
- Secured and encrypted storages and processing of all personally identifiable information throughout all processes and exchanges;
- An ongoing security and privacy training process for all Wedo staff members.
HOW LONG WE RETAIN YOUR PERSONALLY IDENTIFIABLE INFORMATION
The periods during which Wedo retains your personally identifiable information are determined by the nature and type of information, the Wedo platforms and services you use, and the country in which they are provided as well as any applicable local legal or regulatory provisions and requirements. In general, once your information is no longer needed for a legitimate business purpose or reason or to comply with the applicable regulations, your information will be deleted, or Wedo may anonymise or aggregate it with other information to make it non-personal.
The data retention period may also depend on the legal and regulatory requirements of the country where you are located. Wedo will retain personally identifiable information as evidence of our dealings with you, including whether there were any or no financial transactions, to manage any queries or disputes, including to defend or initiate any legal claims.
Wedo can also continue its marketing by sending you direct marketing information, subject to local laws when you provide your consent to receive such marketing. You are always entitled to retract your consent.
YOUR DATA PROTECTION RIGHTS
You have many rights that you may be able to exercise in relation to your personal information. These rights may apply under a number of different regulations, for example, the General Data Protection Regulation (GDPR) which is generally applicable to EEA and UK residents, and the California Consumer Protection Act (CCPA) which is generally applicable to California residents. If you wish you can access, correct, or update your personal information.
In certain circumstances, you can also ask us to delete your personal information (“Right to be forgotten”), object to its processing or temporarily restrict its processing while exercising your other rights. In addition, you can request to transfer certain of your personal information to another service provider (so called, data portability). You may also have the right to “opt out” of certain uses of your personal information, including asking us to limit the sharing of your personal information with affiliated and non-affiliated third parties. Privacy laws continue to develop and if you think or are unsure as to whether any right may apply to you, please also contact us, so we can assess and advise.
To the extent that GDPR applies, when you give us consent to use your personal information, you can withdraw it any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Please consider that, depending on the country from where you use the Wedo platforms and services, not all the above rights may be available to you. Also, there might be cases where these rights cannot be enforced: for example, you cannot object to Wedo using your information when it is required by law, or to manage a complaint; similarly you cannot ask us to delete your information if you want to continue using the Wedo platforms and services, or where such information is necessary to record our contractual dealings, required by law (for example, the retention of anti-fraud or “know your customer” identify and verification requirements), or for the purpose of defending or asserting legal rights and legal actions.
You always have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority. Also, you can commence a court action to claim compensation for damage or distress caused by our failure to comply with data protection legislation.
If you want to know more about your rights, or you want to exercise them, you can reach us at the details provided in the Contact Us section.
LEGAL BASIS FOR PROCESSING
Wedo will only process your personally identifiable information in compliance with the applicable laws in the countries where Wedo operates and the country where you have residence. Such laws vary across different territories and further specific information is available on request. In general, Wedo will either process your personally identifiable information:
- On the basis of your consent, for example to send you marketing messages about products and services in accordance with your interests and preferences, where such consent is required by law;
- Where necessary for the performance of, or entry into, any contract we have with you, for example, in order to provide you with the Wedo platforms and services you have subscribed to;
- Where Wedo has a legitimate interest to process data, subject to such processing not overriding your own rights and freedoms in objecting to such processing.
- Where Wedo has a legal obligation to collect, use and disclose your personally identifiable information or otherwise needs your personally identifiable information to protect your vital interests or those of another person.
If you have questions about or need further information concerning the legal basis on which we collect and use your personal information for any specific processing activity, please contact us via the Contact Us section below.
CHANGES TO OUR PRIVACY POLICY
Wedo may, from time to time, change our privacy policy. When we make material changes to how we treat your personally identifiable information, we will notify you through a notice on our website and apps, and when possible, we will inform you by email. When we are required by law to give you advance notice of any changes to this privacy policy and seek your consent to changes in our uses of your personally identifiable information, we will do so.
GLOBAL POLICY
This policy is global in scope and applies to all platforms and services provided by Wedo but is not intended to override any legal rights or prohibitions in any territory where such rights or prohibitions prevail. In such event, the rights and obligations set out in this policy will apply, subject only to amendment under any applicable local law having precedence.
EU REPRESENTATIVE
The companies of the Wedo group that are based outside the EEA have elected as their EU representative the following entity: Wedo Ventures Ltd., 20-22 Wenlock Road, London, England, N1 7GU. You can reach the EU representative using the contact details provided under the Contact Us section below.
UK REPRESENTATIVE
The companies of the Wedo group that are based outside the UK have elected as their UK representative the following entity: Wedo Ventures Ltd., 20-22 Wenlock Road, London, England, N1 7GU. You can reach the UK representative using the contact details provided under the Contact Us section below.
CONTACT US
We appreciate your comments, feedback and queries related to the usage of your personally identifiable information and your privacy rights. You can contact us as follows:
Wedo Ventures Limited
20-22 Wenlock Road
London, England, N1 7GU
Data Protection Officer:
Dr. ir Johannes Drooghaag – Johannes at wedo.ventures