Effective Date: 01 February 2023
Version: 0.1, Last update: 23 December 2022
When you use our Services, you’re trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
TABLE OF CONTENTS
1. SCOPE OF POLICY
2. INFORMATION WE COLLECT ABOUT YOU
3. USES MADE OF THE INFORMATION
4. RETAINING YOUR INFORMATION
5. STORAGE SECURITY
6. YOUR LEGAL RIGHTS
7. CHILDREN’S INFORMATION
1.This policy applies to your use of:
· our website at https://we53.io/ ("Website") pursuant to the WE53 Public Offer Agreement;
· our services accessible through the WE53 Mobile application ("Mobile application") once you have downloaded a copy of the Mobile application onto your mobile device ("Device").
2. This Policy aims to give you information on how we collect and process your personal data through your use of our Website or the Mobile application, including any data you may provide when you purchase a service, sign up to our newsletter/email, take part in a competition or survey. We may also collect and use information about you that is provided by third parties. Our Website and the Mobile application are not intended for children and we do not knowingly collect data relating to children.
3. If you have any further questions, you can contact our Data Protection Officer (DPO) on [email protected]
For the purpose of the GDPR the data controller is LLP "Chargeup" (“WE53”) a company established under the laws of the Republic of Kazakhstan (company number 220940042409) and with registered address: 050002, Kazakhstan, Almaty city, Zhetysu district, Potanin Street, 47/26.
Data Protection Officer
1. We have appointed a Data Protection Officer, who has a number of important responsibilities including:
· monitoring WE53's compliance with the GDPR and other data protection laws;
· raising awareness of data protection issues, training WE53 staff and conducting internal audits; and
· cooperating with supervisory authorities, such as the “Office of the Commissioner for Personal Data Protection” of the Republic of Cyprus (“Commissioner”) on our behalf.
2. You can contact our DPO at: [email protected] or LLP "Chargeup", 050002, Kazakhstan, Almaty city, Zhetysu district, Potanin Street, 47/26.
1. You have the right to make a complaint at any time to the Commissioner, the Cyprus supervisory authority for data protection issues (https://www.dataprotection.gov.cy/). We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance.
2. 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 at any time.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Submitted Information - information you give us through direct interactions:
This is information you give us about yourself by filling in forms on the Mobile application and/or the Website, or by corresponding with us (for example, by e-mail or via the chat functions on the Mobile application and/or the Website).
It includes information you provide when you register to use the Mobile application, download or register the Mobile application, subscribe to any of our Services, enter into any order or transaction on the Mobile application, participate in discussion boards or other social media functions on the Mobile application or the Website, enter a competition, promotion or survey and when you report a problem with a Mobile application or the services.
The information you give us may include your e-mail address, phone number, transaction information (payment data, payment amount, cardholder name, first 6 and last 4 card digits, bank name, payment processing system).
b) Information we collect about you and your Device.
Device Information - each time you visit the Mobile application or our Website we will automatically collect the following information:
· technical information, including the Internet Protocol (IP) address used to connect your Device to the Internet, your login information, browser type and version, 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, your 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, geolocation data;
· information about your visit, including the full uniform resource locators (URL), clickstream to, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;
· details of your use of our Mobile application or your visits to our Website.
c) Third Party Information: Information to help us deliver our service to you.
· Through the Mobile application we use analytics, marketing analytics and ad service providers, which collect information from identifiers for mobile devices. This is a unique, anonymized, user-resettable ID for advertising and analytics such as an Android Advertising Identifier (provided by Google Play services) and Identifier for Advertisers (IDFA) provided by Apple):
- Amplitude - a service for analyzing user behavior on the mobile applications (For more information about Amplitude’s privacy practices, see https://amplitude.com/privacy);
- Firebase - tools from Google for building app infrastructure, improving app quality (For more information about Firebase’s privacy practices, see https://firebase.google.com/terms/data-processing-terms; You can find and delete your Web & App Activity by visiting My Activity. Learn more about how to delete activity manually or set up automatic deletion.);
- AppsFlyer - attribution and marketing analytics services (For more information about AppsFlyer privacy practices, see https://www.appsflyer.com/legal/services-privacy-policy/; opt out feature here - https://www.appsflyer.com/legal/opt-out/).
To opt of cross-app tracking and using your Device ID:
- If your phone uses Google Play Services, you can manage your Google apps and services in Google Settings here https://support.google.com/android/answer/3118621?hl=en or inside the Device, at Setting section > Security and privacy > Privacy > Other privacy settings > Ads, OR
- If you use an iPhone, go to Settings > Privacy > Tracking. Here, make sure to turn Allow Apps to Request to Track OFF.
1. Below is a summary of the key types of data that we make use of as part of the WE53 services. For more information on how these types of data are used and for which purposes. then please see the table below.
2. We use information held about you in the following ways:
(a) Submitted Information: We will use this information:
· to carry out our obligations arising from any transactions you enter into with us and to provide you with the information and services that you request from us;
· to notify you about changes to our services; and
· to ensure that content from our Website or in the Mobile application is presented in the most effective manner for you and for your Device.
(b) Device Information: We will use this information:
· to administer our Website and the Mobile application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
· to improve our Website and the Mobile application to ensure that content is presented in the most effective manner for you and for your Device;
· to allow you to participate in interactive features of our service, when you choose to do so;
· as part of our efforts to keep our Website and the Mobile application safe and secure;
· to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
(c) Third Party Information: We will use this information:
· making decisions about whether to agree to approve the Mobile application, Website or service.
3. We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4. We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data.
What we use your information for
1. To provide the WE53 services:
To fulfill our obligations in any contract you have entered into or will enter into with us. Including:
To provide you with access to WE53 platform and to enable your interaction with WE53;
To provide customer service;
Processing and delivering your order; and
Collecting and recovering money owed to us.
Type of Information: Submitted Information
Our reasons: Fulfilling contracts; Our legitimate interests; Consent; Legal obligation;
Our legitimate interests: Being efficient about how we fulfill our legal and contractual duties. Our commercial interest in providing you with a good service.
2. To keep the WE53 services up and running:
To administer our Website and the Mobile application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your Device;
To allow you to participate in interactive features of our service (such as prize draw, competition or completing a survey), when you choose to do so;
To notify you about changes to our service and legal binding documents; and as part of our efforts to keep our Website and the Mobile application safe and secure.
Type of Information: Submitted Information; Device Information; Third Party Information
Our reasons: Fulfilling contracts; Our legitimate interests; Consent
Our legitimate interests: Being efficient about how we fulfill our legal and contractual duties.
Our commercial interest in providing you with a good service.
5. What do we mean, when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing WE53 platform to enable us to provide to you the WE53 services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Consent: this means that we will only process your personal data for certain specific purposes if we obtain your consent before such processing, for example, in order to collect and process your location data and/or to send you notifications. We normally ask for your consent the use of your personal data in order to provide our services to you when you download the Mobile application. Please note that if you do not provide your consent for this purpose, or withdraw it at a later stage, we may be unable to provide our services to you.
7. Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
8. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We retain your information for as long as it is necessary for the performance of the contract we have with you. If you no longer want us to use your information, you can send a request to [email protected]. Please note that in this case we may be unable to provide our services to you.
1. The hosting facilities for our Website and the Mobile application infrastructure are situated within the EU.
2. The data that we collect from you will be transferred to, and stored at a destination inside the European Economic Area (EEA).
3. All information you provide to us is stored on our secure servers. Any transmission of information is encrypted using TLS technology, the current standard in secure communications over the Internet. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
4. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
1. You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
The right to access – You have the right to request us for copies of your personal data.
The right to rectification – You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.
The right to erasure – You have the right to request that the Company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the Company’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you.
WE53 does not knowingly collect any personal data from children under the age of 16. If you think that your child provided this kind of information to the Company, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.