WalletWorx – Privacy Notice

Introduction

At WalletWorx we protect the personal information of all users who access our websites or services through any mobile application, platform or device (collectively, the “Services”).

This privacy notice (“Privacy Notice”) explains how WalletWorx, our and licensees collect, share, and use your personal information. You’ll also find information about how you can exercise your privacy rights.

By using our Services you agree to Walletworx using your personal information as described in this Privacy Notice.

The terms “we”, “us” or “our” are each intended as reference to walletworx.app and portal.walletworx.app. The term “you” refers to consumers who request or uses Services, and Merchants, marketplace participants or such like who offers their services to consumers through the use of the Services (collectively “Business Partners”) as may be relevant.

1.Information we collect from you and why

Here are the broad categories of personal information that we may collect about you and the reasons why:

A.Information that you provide voluntarily:

Certain parts of our Services may ask you to provide personal information voluntarily e.g:

1. 1. Registration information: When you create a WalletWorx account, sign-up or fill in forms on the Services, we collect information about you including your name, telephone number, email address and the password you create.

This allows us to-

1. 1. • Create your account so you can utilise the Services;
      • Verify your identify and validate your right to provide the service (where relevant);
      • Identify you when you sign-in to your account;
      • Contact you for your views on our Service or to send marketing and other communications to you; and
      • Notify you of changes or updates to our Services.

We also collect-

1. 1. • Information regarding your marketing preferences: We collect information about your preferences to receive marketing information any time you subscribe or unsubscribe, including whether you want to receive marketing message from third parties.
      • Feedback: When you post messages and reviews of the Services or you contact us, for example with a question, problem or comment, we collect information about you including your name and the content of your query. If you contact our customer support teams we will record and keep a record of your conversation for quality and training purposes and to aid in the resolution of your queries. We will publish reviews that you send to us about the Business Partners on our platform and our Services in general and we also analyse your feedback to improve and develop our Services and in order to enhance your experience.

This allows us to-

1. • 1. Reply to your questions or queries;
     2. Publish reviews you submit to us about our Business Partners and services; and
     3. Conduct analysis and research to improve and develop our Services.
   • Sensitive Information: We collect information that you provide when you contact us via the app. We do not accept sensitive personal information, such as health-related information (allergies or dietary requirements) or information about your religion (such as if you only eat halal food). However, there are some situations where you may nonetheless provide this type of information, for example if you make a complaint and in those circumstances we will only be collecting it with your consent.

B.Information that we collect automatically

When you access our Services, we may collect certain information automatically from your device. In some countries, including countries in Europe, this information may be considered personal information under applicable data protection laws. For instance:

1. 1. Activity information: We collect information about your usage of the Services and information about you from the content you create and the notifications or messages you post or send as well as what you search for, look at and engage with.

We collect Activity Information so that we can:

1. 1. 1. Provide you with an improved experience by analysing your favouriting habits and how you interact with the Service. WalletWorx may use this information to suggest buying options from new Merchants we think you would like to try, and we or a Merchant may use it to send you promotions or personalised services based on your preferences; and
      2. Provide other services at your request.
   2. Cookies and similar technologies: We use cookies and similar tracking technology to collect and use personal information about you (e.g. your Internet Protocol (IP) address, your device ID, your browser type and when, how often and how long you interact with the Services), including to facilitate interest-based advertising.

This allows us to-

1. 1. Measure and analyse the use and effectiveness of our Services;
   2. Customise and optimise the targeting of advertising for our Services across other websites and platforms; and
   3. Provide location services unless you choose not to share your geo-location.

C. Information that we obtain from third party sources.

From time to time, we may receive personal information from third party sources, including advertising networks and social media platforms like Facebook, but only where we have checked that these third parties either have your consent to process the information or are otherwise legally permitted or required to share your personal information with us.

This may include Analytics reports and market research surveys:

• We collect information from our third party affiliates about the way you respond to and engage with our marketing campaigns so that we can customise our marketing and Services accordingly.
• We may also receive aggregated information in the form of audience segments from third party sources in order to display targeted advertising on digital properties operated by organisations like Facebook and Google.

2.Who we share personal information with

We may share your personal information with the following recipients (and whenever we do, we will ensure that we have appropriate security and contractual safeguards in place to protect it):

1. If any part of our business enters into a joint venture, purchases another business or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, or new business partners or owners or their agents and advisors. In these circumstances we will always inform the relevant entities that they must only use your personal information for the purposes disclosed in this Privacy Notice.
2. Any law enforcement or regulatory body, government agency, court or other third party
3. where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person.
4. Any other person provided that you have given your consent to the disclosure. We will not sell, distribute or lease your personal information other than as set out in this Privacy Notice, unless we have your permission or are required by law to do so.

3.Legal basis for processing personal information

WalletWorx will always make sure we have a legal basis to collect and use your personal information. The legal basis we rely on will change depending on the type of information and the context in which we collect it.

Our main reason for collecting and using your personal information is to perform our contract with you (i.e. to make sure you get to use the Service at the level expected), but we may also process it where it is in our legitimate business interests to do so.

4.International data transfers

We may transfer your personal information to countries outside the one in which you are resident to other countries where WalletWorx or our service providers have operations. The data protection laws of these countries may differ from the laws of your country but WalletWorx takes care to implement appropriate safeguards to protect your personal information in those countries in accordance with this Privacy Notice.

Security

5.Security

We place great importance on keeping your personal information safe and secure. As such, we put in place appropriate technical and organisational measures / industry standard technology to protect it

from unauthorised access and unlawful processing, accidental loss, destruction and damage.

The security measures we use are designed to provide a level of protection security appropriate to the risk of processing your personal information. Where you have chosen a password which allows you to access certain parts of the Services, you are responsible for keeping this password confidential. We advise you not to share your password with anyone and to use a unique password for our Services. You will be liable for all transactions processed using your account. We will not be liable for any unauthorised transactions entered into using your name and password.

6.Data retention

WalletWorx will retain your personal information for no longer than is necessary to fulfil the purposes described in this Privacy Notice, and where we have an ongoing legitimate business need to do so (for example, while you hold an account with us or to enable us to meet our legal, tax or accounting obligations). We may also retain certain elements of your personal information for a period after you delete or deactivate your account for our legitimate operations such as record keeping and to comply with our legal obligations. Whenever we retain your information we will do so in compliance with applicable laws.

If you object to us processing certain categories of your personal information (including in relation to receiving marketing communications from us or any third party including a Business Partner), we will retain a record of your objection to the processing of your information so that we can continue to respect your wishes. Should you chose to do so, you acknowledge that the Service may be impacted by your decision to restrict such processing.

We will destroy or permanently anonymise your personal information at the point that we no longer need to process it for our ongoing legitimate business needs or for any legal reason. If this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store it and isolate it from any further processing until deletion is possible.

7.Your data protection rights

You can access your account at any time to review and update your personal information. You can

also contact us to ask us to delete your personal information, restrict its processing or request that it be ported to a third party. You also have the right to unsubscribe from the marketing communications we send you by using the unsubscribe functionality in any marketing communication you receive from us or by amending your profile accordingly.

8.Links to third-party sites

Our website may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates or to any number of websites that may offer useful information to our visitors. We provide these links to you only as a convenience and the inclusion of any link does not imply endorsement of the relevant website by WalletWorx. If you follow a link to any of these websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for these policies or those linked websites. Please check these policies before you submit any personal information to such websites.

9.Updates to this Privacy Notice

We may update this Privacy Notice from time to time in response to changing legal, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Notice changes if and where this is required by applicable data protection laws. We encourage you to periodically review this page for the latest information on our privacy practices.

10.How to contact us

If you have any questions or concerns about this Privacy Notice and WalletWorx’s privacy practices, please contact us on support@walletworx.app.