1.1 Wallet and Payments OÜ
(“Company,” or “we,” or “us,” or “our”) is committed to safeguarding the privacy of our website, https://credits.com, and service users (“users” or “you”).
1.2 This policy applies where we are acting as a data controller with respect to your personal data, in other words, where we determine the purposes and means of the processing of that personal data.
1.3 This Policy defines the procedure of processing and protection of information on individuals and legal entities (further – the Customers) which can be obtained by the Company when the Customers use of:
services and facilities provided by the website https://credits.com (hereinafter – the Website);
the Company App (“App”) once you have downloaded a copy of the App onto your mobile telephone or handheld device (“Device”); and
any of the services accessible through the App or the Website (the “Services”).
1.4 The purpose of this Policy is a provision of appropriate protection of information about Customers, including personal data from illegal access and disclosure.
1.5 Relations associated with the collection, storage, sharing and protection of information provided by the Customers are governed by this Policy, other official documents of the Company and the acting legislation of Estonia.
1.6 Making registration on the Website and using the services, the Customers agree with the terms of this Policy. In the case of the Customer’s disagreement with the terms of this Policy, the use of the Site and/or any services and facilities available on the Site should be immediately stopped.
1.8 So that we’re clear and there’s no misunderstanding about how we handle your personal data, we will:
always keep your data safe and private;
never sell your data;
allow you to manage and review your marketing choices.
2. Types and uses of collected information
Company collects two types of information about you:
2.1 Personally Identifiable Information. This is information that identifies a specific person. When you engage in certain activities via the Services by creating an account for the purpose of using our Services or otherwise participating in the Services (collectively, “Identification Activities”), we may ask you to provide certain information about yourself. If you elect to engage in an Identification Activity we may ask you to provide us with certain personal information about yourself, including, but not limited to:
Information, you provide – during registration as a Customer and by filling in forms on the Website and/or the App, or by corresponding with us (for example, by e-mail or via the chat functions on the Website and/or the App), enter into any transaction on the Website or the App (such as Add funds, Send, Exchange) we ask you to inform certain information we need to identify the party in the framework of agreements with the Company. Also If you contact us for participating in discussion boards or other social media functions on the Website or the App, we will keep a record of that correspondence. The information you give us may include your name, address, date of birth, e-mail address, phone number, the Device’s phone number, username, password and other registration information, financial, details of your bank account including the bank account number, bank sort code, IBAN, details of your debit and credit cards including the masked PAN data, relevant expiry dates, identification document numbers, copies of identification documents (for example, passport, driving license, national id card and utility bill) personal description and photograph and any other information you provide us in order to prove your eligibility to use our services.
Cookies – for collection of information Company can use markers cookies are small pieces of information stored by your browser on the hard drive of your computer at the request of the web site. Our Company cookies do not contain any personal information and are used as follows:
to monitor temporary information. For example, marker cookies allow us to track what pictures you upload and download;
to register you in special programs. Cookies allow us to remember you when you log in our Website;
to remember your preferences concerning country and language;
to help us understand the scope of your audience and the traffic distribution;
to collect and record information about what you viewed on our Website and what viewed in our email latter.
to manage information of the Website and its presentation and to understand which images can be displayed on your computer; to present information according to your interests.
Information about your device and visits – when you access the Website https://credits.com (and its subdomains) via a browser, App or others our servers automatically record certain information. These server logs may include information such as a web request, date and time of the request, IP-address used to connect your computer to the Internet, your login information, browser type, version and language, time zone setting, browser plug-in types and versions, operating system and platform, device information and the type of mobile device you use, a unique device identifier (for example, Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
Location information – we use GPS technology and your IP address to determine your location – this may be used when you log in to the Website or when the App is running in the foreground and the background of your Device. This is used to prevent fraud when your location and device type is different from what you normally use. Our fraud-prevention measures require this personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling location permission for the Company Website or App within your device settings.
The custom message – when you send some messages (email or otherwise), we can save these messages for processing requests, answers the questions and for further development of our services. To contact you regarding our services may use your e-mail address.
Depending on the Identification Activity, some of the information we ask you to provide may be identified as mandatory and some identified as voluntary. If you do not provide the mandatory information for an Identification Activity, you will not be permitted to engage in that Identification Activity with the Company Service. Depending on the Identification Activity, Company might not re-ask you for Personally Identifiable Information if such are already stored with us. I
2.2 Non-Personally Identifiable Information. This is information that does not identify a specific person. Most of the information we collect for mobile, such as your mobile device identification and mobile device type, the request type, your mobile carrier, your mobile carrier user identification, and the content of your request, does not by itself identify you to Company, though it may be unique or consist of or contain information that you consider personal. We use Non-Personally Identifiable Information to troubleshoot, administer the Company Service, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also use this information to measure the overall effectiveness of our products and services.
3. How we obtain information
Your information is made up of all the financial and personal information we collect and hold about you, which may include, but not be limited to:
information you give to us;
information that we receive from third parties who provide services to you or us;
credit reference, fraud prevention or government agencies and other financial institutions (where permitted by law);
information that we learn about you through our relationship with you and the way you operate your accounts and/or services, such as the payments made to and from your accounts;
information that we gather from the technology which you use to access our services (for example location data from your mobile phone, or an IP address or telephone number) and how you use it (for example pattern recognition); and
information that we gather from publicly available sources, such as the press, the electoral register, company registers and online search engines.
4. How we use your personal data
4.1 In this section we have set out:
the general categories of personal data that we may process;
the purposes for which we may process personal data; and
the legal bases of the transactions and transfers processing.
4.2 We may process your personal information to carry out our obligations arising from any transactions you enter into with us, for example, Add funds, Send funds, Exchanges, Withdrawals and to provide you with the information, products and services that you request from us
4.3 We may process data about your use of our website and services. The usage data may include your IP address, geographical location, browser type and version, operating system. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analyzing the use of the website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.4 We may process your account data. The account data may include your name and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.5 We may process your information included in your personal profile on our website. The profile data may include your name, address, telephone number, email address, profile pictures, gender, date of birth, relationship status, imployment details. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.6 We may process information that you post for publication on our website or through our services. The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.7 We may process information contained in any inquiry you submit to us regarding the Services. The inquiry data may be processed for the purposes of offering, marketing and selling relevant services to you. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.7 We may process your personal information to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services
4.8. Personal data such as email will be used for the authentication process, access control to your account, analytics data collection, actions logging and marketing purposes.
4.9 We may process information relating to transactions, transfers, exchange, and purchase of cryptocurrency, that you enter into with us and/or through our Website or the App. The transaction data may include first and last names, an email address to be used as a login, billing contact information, credit card number, banking information and/or cryptocurrency account information, and a password. The transaction data may be processed for the purpose of processing transfer, payment, and currency exchanges and keeping proper records of those transactions and for determining compliance with Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) regulations, policies and law. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests.
4.10 We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters. The notification data may be processed [for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.11 We may process information contained in or relating to any communication that you send to us. The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is your consent or our legitimate interests, namely monitoring and improving our website and services.
4.12 We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
4.13 In addition to the specific purposes for which we may process your personal data set out in this section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
4.14 Please do not supply any other person’s personal data to us, unless we prompt you to do so and/or we have agreed in writing prior to receiving the data from you. Any information that we receive that is not identified shall be notified to you and destroyed immediately.
5. Providing your personal data to others
5.1 Financial transactions relating to our website and services may be handled by our payment services providers (IPSP or acquirer bank). We will share transaction data with our payment services providers only to the extent necessary for the purposes of executing such transactions as you wish to process via the Services and dealing with complaints and queries relating to such payments and refunds.
5.3 In addition to the specific disclosures of personal data set out in this section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
9. Information security
9.1 You can access your Personally Identifiable Information via the Company Service with your password and username. This password is encrypted. We advise against sharing your password with anyone. If you access your account via a third-party site or service, you may have additional or different sign-in protections via that third-party site or service. You need to prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-in mechanisms appropriately and limiting access to your computer, browser, or mobile device by signing off after you have finished accessing your account. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of user information at any time. If we believe that the security of your information may have been compromised, we may seek to notify you of that development.
9.3 Please be aware that no data transmission over the Internet or via e-mail is completely secure and therefore we cannot guarantee the protection of all personal information in all cases. For example, we cannot guarantee protection against interception, misappropriation, misuse, or alteration, or that your information will not be disclosed or accessed by the unauthorized acts of others. Consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk. If you provide us with your credit card number, you should not send it electronically unless the email is encrypted, or your browser indicates that the access to our website is secure. Materials posted to online forums such as bulletin boards or chat rooms are public, not secure, and may be viewed by anyone. Any personal information you post may be collected and used by anyone and may result in unsolicited messages from other parties.
10. Your legal rights
10.1 In this section we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
10.2 Your principal rights under data protection law are:
the right to access;
the right to rectification;
the right to erasure;
the right to restrict processing;
the right to object to processing;
the right to data portability;
the right to complain to a supervisory authority; and
the right to withdraw consent.
10.3 You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you a copy of your personal data. You can access your personal data by visiting your profile when logged in.
10.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
10.5 In some circumstances you have the right to the erasure of your personal data without undue delay, and at the latest within one month of receiving your valid request. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processing. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
10.6 In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
10.7 You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
10.8 You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
10.9 You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
10.10 To the extent that the legal basis for our processing of your personal data is:
that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
10.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
10.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
11. Automated decision-making and profiling
The Company does not engage in any profiling or automated decision-making in respects of its Customers or individuals whose data it processes.
The Company’s Service is not directed to people under the age of eighteen (18). If you become aware that your child has provided us with personal information without your consent, please contact us at the email address listed below. If we become aware that a child under eighteen (18) has provided us with personal information, we take steps to remove such information and terminate the child’s account.
13. Retaining personal data
13.1 This section sets out information about our data retention policies, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
13.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
13.3 We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person, or in connection with any legal claim.
13.4 The Company is obligated under the Money Laundering and Terrorist Financing Prevention Act 2017 to retain personal data about you and your transactions for a period of five years. We, therefore, use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 5 years after the termination of our business relationship.
14. Access to personal data
The company provides access to personal information only those employees of the Company to whom this information is necessary to ensure the functioning of the Website, providing services to the Customers and only under the following circumstances:
We have enough reason to believe that access, use, storage or disclosure of such information is necessary to (a) compliance with any applicable laws, resolutions , requirements of legal process or the a valid request from public authorities, (b) compliance with applicable terms of service, including investigation of potential violations, (c) detection and prevention of fraud actions and decision of the security issues and resolve technical problems or (d) protection from the threat of damage to the rights, property, or safety of the Website https://credits.com (and its subdomains), its Customers or the public as are required or permitted by law.
15. Personal data protection
We take all necessary measures to protect the data against unauthorized access, modify, disclosure or destruction. These measures are internal review processes and conditions of collection, storage and processing of data and security measures, including appropriate encryption and measures to ensure physical data security to prevent unauthorized access to the system in which we store personal data.
We protect your personal information by using data security technology and using tools such as firewalls and data encryption.
All your personal data is stored on our secure servers in accordance with our Data Protection Policy. In order to provide the highest quality services and due to the technical features of the performance of certain functions of the Website, some personal data, such as email, can be stored on our servers in the open data storage but using the same security standards and access restriction as to the other personal data.
16. Working with personal data and their update
Before processing requests, we ask Customers to identify its own identity and the information, which they want to receive, correct or delete. The Customer when using the Website, confirms and agree that:
has all the necessary rights, allowing him to register (create an account) and use the services of the Website;
indicates true information about yourself in the volumes necessary to use the services of the Website, mandatory fields for further provision of services of the Website marked the special way, all other information provided by the Customer at his own discretion;
familiar with this Policy agrees with it and assumes the specified rights and obligations. Familiarization with the terms of this Policy is the written consent of the Customer for the collection, storage and processing personal data provided by the Customer;
the Company does not verify the authenticity of received (collected) information about Customers, except for cases when such check is necessary to fulfill obligations to the Customer.
If a privacy complaint or dispute cannot be resolved through Company’s internal processes you have the right to make a complaint at any time to the Data Protection Inspectorate, the Estonian supervisory authority for data protection issues (https://www.aki.ee/en/inspectorate). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
19. Contact us