PRIVACY POLICY

This Privacy Policy (“Policy”) between Rewire holding Limited, rewireholding.com, subsidiaries, affiliates, agents, service providers, and assigns (“Company”, “us”, “we”, “our”) and you (“you”, “your”), the end user websites such as but not limited to (www.rewireholding.com) or any such other websites from us (the “Site”), our mobile apps including our SDK encrypted black box feature software for apps (the “App”), and our online infrastructure or potentially in future payment gateway or any such other physical products such as but not limited to potentially in future any such other hardware (“Product”) govern the Privacy of your use of our products and services we may offer through this Site(s), our App(s) or our Product(s) from time to time, which we refer to collectively as our “Service” or “Services”. You can use our Services only if you can lawfully enter into and form contracts under applicable law. However, we may permit you to designate another person as an authorized user (“Authorized User”) of your own branded Company Account(s) and our Services, as described below. If you use our Services, you must do so in compliance with this Privacy Policy and with applicable law in all countries where you onboard your own end-users to our services and products and you are responsible for ensuring that you comply with the same. If you do not want this Policy to apply, please do not use our Services.

This Policy applies to information we collect from you or any such users of our Sites such as but not limited from www.rewireholding.com, our online services, our apps users with our or 3^rd party brands using our apps, our Products users, recipients of our emails or our notifications, or when you otherwise interact with us (the “Services”). This Policy sets out the basis on which any personal data we collect from you or your end-users using our Products or Services, or that you or your end-users provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your or your end-user’s personal data and how we will treat it.

When you or your end-users use our Services, you or your end-users will share some information with us that could be used to identify you or your end-users or that is associated with information that identifies you or your end-users (“Personal Information”). So, we want to be clear about the information we collect, how we use it, and whom we share it with. This Privacy Policy applies to Personal Information that we gather or collect via our “Services” and Products. It does not apply to any Personal Information collected by third party websites or products which are not operated by Company or our parent company or any of our subsidiaries.

By using our Services and Products, you are accepting and consenting to the practices described in this Policy. If you do not agree to this Policy, please do not use the Services nor Products and move away from any and all of our Services and Products.

For the purposes of the Data Protection Act 2004 and the EU General Data Protection Regulation (the “Act”), the data controller is Frinwo S.L., Company registered in Spain with company ID: B93520922.

If after reading this Privacy Policy you still have questions about anything in it, please contact us at contact@rewireholding.com

The information we collect 

There are three basic categories of information we collect:

• Personal Information you or your end-users provide to us
• Automatically-collected data
• Information we get from third parties

Information we collect from you or your end-users:

This is information about you or your end-users (“You”, “Your”) that You give us by filling in forms on our site www.rewireholding.com or any such other websites that may be owned by Company, its parent company or its subsidiaries (our sites), when you use our Products or Services from our site or our APPs, or our infrastructure/servers/ledgers or by corresponding with us through our app, by phone, e-mail, through social media or otherwise. It includes information you provide when you register to use our site or our app, subscribe to our Services and/or Products, search for a product, use any of our services in our site or our APPs, participate in discussion boards or other social media functions on our site or our social media channels, enter a competition, promotion or survey and when You report a problem with our site, our service or APPs.

The information You give us may include your name, address, e-mail addresses, date of birth, your wallet addresses, bank account details, phone numbers, financial and credit or debit card (“Card”) information, personal description or photograph, driver’s license, national ID card, Passport and any such other KYC & AML (know your customer & anti money laundry) or anti-terrorism finance detection information such as but not limited to Your service access IP address, GPS country location, SIM network and country code as well as any compliance documentation.

Information we collect about You:

With regard to each of Your visits to our site we will automatically collect the following information:

• technical information, including the Internet protocol (IP) address used to connect Your computer or mobile device to the Internet, your login information, browser type and version, device type and version, time zone setting, blockchain identifiers, browser plug-in types and versions and operating system and platform;
• information about Your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products or things 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, and any phone number used to call our customer service.
• Your GPS country location,
• SIM network and country code

• Name and Surname

Enter the name you want to use on any of Company products or websites or any such other. When you receive an email or interact with other user(s) of our Services or 3^rd party providers, your name will show up with it.

• Password

To help keep your account safe, choose a strong password that’s at least 6 alphanumerical characters.

Have a mix of letters, capital letters, lower case letters and numbers.

Avoid personal info or common words that are easy to guess, like your street or pet’s name.

Don’t use a password you’ve used for other accounts or websites. Likewise, don’t use this password anywhere else.

• Username – email address

Enter an email address that you’ll use to sign in to your Company account, like myname@gmail.com. This email address can be used for a few reasons, including to:

Help you get back in, if you can’t sign in, like if you forget your password.

Get future notifications from any of our Services

• Change this info later

After you create a Company account, you can change some of this info, except for those Services where a username is used, username once created will not be changeable.

• Country

To assure you can use certain Company Services or Products we need to check you are not a USA citizen. Also, to comply with United Kingdom and European guidelines we need to check if you are a European territory User or not, in which case the European data protection law requires such users´ data from European users to be stored on server(s) within a country of the European Union.

When you create a Company account, you provide us with personal information that includes your name, country and a password and other information. Even if you aren’t signed in to a Company account, you might choose to provide us with information — like an email address to receive updates about our Services.

• Your apps & devices

We collect information about the apps, browsers, and devices you use to access our Services, which helps us provide features like automatic product updates and potentially in future dimming your screen if your battery runs low.

The information we collect includes unique identifiers, device type and settings, operating system, device type/model and application version number. We also collect information about the interaction of your apps and devices with our services, including IP address, crash reports, system activity, and the date, time, and referrer URL of your request.

We collect this information when a Company service on your device contacts our servers/ledgers or our apps — for example, when you install our app from the Play Store or Google Play.

You can visit your Company account to find and manage activity information that’s saved in your account, however limiting certain information will not limit Company accessing any such information that we deem necessary, at our sole discretion, to provide any and all of our current and future Services as well as any such information we collect for KYC (know your customer), AML (anti money laundry) and Compliance purposes.

• Your location information

We collect information about your location when You use our Services or Products, which helps us offer features dedicated to nearby devices or Wi-Fi hotspots locations and it helps us to comply with the United Kingdom and European regulations by checking if you are a European territory User or not, in which case the European data protection law requires us to store such European users´ data to be stored on server(s) within a country of the European Union.

Your location can be determined with varying degrees of accuracy by:

GPS

Country of SIM, connected Mobile service provider (home or roaming).

IP address

Sensors data from your devices, i.e. pressure data to calculate estimated altitude.

Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices.

The types of location data we collect depends in part on your device and account settings. For example, you can turn your Android device’s location on or off using the device’s settings which is independent of our app(s).

• Your privacy controls

You have choices regarding the information we collect and how it’s used. You can login to your Company App settings and review and update your personal information.

Personal Information you provide to us

When You interact with our Site or mobile app, we collect Personal Information that you choose to share with us. For example, when You set up an account with us, we need to collect a few important details about you, such as but not limited to Your name, in certain cases a unique username you would like to go by, a phone number, your email address, and your date of birth. We may also collect other information such as a copy of your government-issued identification and in certain cases a selfie image for verification purposes. Please ensure that you only send us an image of yourself. Do not include any images of others in the same selfie. When you contact customer support or communicate with us in any other way, we’ll collect whatever information You volunteer, in addition to Your name and email address.

Automatically-collected data

When you visit our Site, app or use our Services or Products, we collect information about which of the Services You’ve used and how You’ve used them. Examples, but not limited to, of this information include:

• Usage information on our Site or mobile app (e.g., pages you visit on the Site, webpage from which you linked to our Site);
• Time and date of your activities;
• Location from which you browsed the Site or app;
• Device ID;
• Your IP address;
• The kind of browser or app and the type of computer or mobile device you use;
• Name of your internet service provider or SIM provider or country code or roaming country code of the mobile operator SIM in your device; and
• Operating system version.

Information we get from third parties

These 3^rd party information that we receive about you if you use any of the other websites we operate or the other services we provide. In this case we or they will have informed you when we collected that data if we intend to share those data internally and combine it with data collected on our site. We or they will also have told you for what purpose we will share and combine your data. We are working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies). We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

We may collect Personal Information about you from other users, our affiliates, and third parties, as permitted by law. For example, we may collect information from third-party verification services, credit bureaus, financial institutions, mailing list providers, and publicly or otherwise available sources to verify your identity or fiscal residence. We may also collect information about you from third parties in connection with any identity or account verification process, fraud detection process, compliance process, or collection procedure, or as may otherwise be required by applicable law.

EXCLUSION OF RIGHT OF USE

If you are a USA resident or a USA citizen living abroad, please move away from any and all of our Services and Products, through our websites or apps or products, as they exclude any and all USA citizens. If you are a USA citizen and you ignore our explicit warning herewith that you have no right of use of any of our Services or Products but still you use our Services or browse any of our websites or download any of our apps than these terms and conditions apply as for the rights of Company but none of the users rights apply to You at all, meaning you have no rights and any of your personal and other information will be extracted as described herein automatically. If you do not agree with any of our Terms & Conditions or Privacy Policy then simply move away from our Site(s) and App(s) and do not use any of our Product(s) and Service(s). If you have used it by mistake or if a minor (under 18 years) of your family used any of our website(s), app(s), product(s) or any of our Service(s) by mistake or receives consequently any communications from Company by app notification, by email or any such other means, than please contact us and request to delete from our database all such minor user info and/or your own user info and corresponding account if any, by emailing such request to contact@rewireholding.com

How we use your information

• Personal Information

To provide the Services: Company may use your Personal Information to fulfill requests for Products, Services, or information, including information about potential or future Services, including but not limited to:

• Manage individual information and accounts;
• Respond to questions, comments, and other requests;
• Verify an individual’s identity as authentic and/or comparing your selfie image against your government-issued identification;
• Process payment for products or Services purchased;
• Process applications and transactions;
• Provide access to certain areas, functionalities, and features of our Services; and
• Allow you to register for events.

For internal business purposes: Company may use Personal Information for its internal business purposes, including to:

• Measure interest in Company’s Services;
• Develop new Products and Services or improve existing Products and Services;
• Ensure internal quality control;
• Communicate about individual accounts and activities on Company’s Services and systems, and in Company’s sole discretion, changes to any Company Policy or ny Terms and Conditions;
• Comply with regulatory requirements;
• Prevent potentially prohibited or illegal activities;
• Enforce our Terms of Use;
• Protect the safety of any account, to address fraud, security or technical issues, or to protect the Company’s rights or property;
• Comply with applicable laws, rules and regulations or court orders; and
• For any other purpose for which you have given express permission or consent to Company or to a Licensee of Company or to a 3^rd party company using Company product(s), be it an app, an SDK for app and/or server, or any such other Company product with their own brand.

For marketing purposes: Company may analyze and use Personal Information to provide you with materials about offers, Products, and Services that may be of interest, including new content or Services. Company may provide you with these materials by phone, postal mail, email, as permitted by applicable law. Such uses include but are not limited to:

• To tailor content, advertisements, and offers;
• To notify you about offers, products, and services that may be of interest to you;
• To provide Services to you and our sponsors;
• For other purposes disclosed at the time you provide Personal Information; and otherwise with your consent.
• By using any of our Services or Products you consent to our Privacy Policy.
• Any personal information required to operate and provide to our users our Services and Products will be shared and stored on 3^rdparty Suppliers servers or 3^rd party Service Providers or any such other 3^rd parties as required to provide any or all of our Services.
• Non-personal Information

We may also use non-personally identifiable information that does not personally identify You, including by aggregating and/or de-identifying Personal Information, in order to understand better how our visitors, use the Site, research our visitors’ demographics, interests, and behavior, improve the Site or apps, provide visitors with customized services and information, and for other similar purposes. We may share this information with others for information or promotional purposes, and may use non-personally identifiable information in any manner permitted by law. When any non-personally identifiable information is combined with other information that identifies you, it will be treated as Personal Information in accordance with this Privacy Policy.

Uses made of the Information

We shall process all information we collect from you in accordance with this Policy and applicable laws and regulations, as may be amended from time to time, and the data controller, we may directly or through our service providers or agents process your information for any one or more of the following purposes, but not limited to:

Information you give to us. We will use this information:

• arising from any contracts entered into between You and us and to provide You with the information, products and services that You request from us;
• to provide you with information about other goods and Services we offer that are similar to those that you have already used, purchased or enquired about;
• to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail, notifications, SMS, MMS, social media as WhatsApp, Skype, Signal or others or any such other means) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to You or a Service you use or inquired for. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this. If you do not want us to use your data in this way, or to pass your details on to third parties for marketing purposes, please tick the relevant box situated on the form on which we collect your data (the order form or registration form or if not available or not found than simply email us at contact@rewireholding.com );
• to notify you about changes, updates or down times to any of our Service;
• to ensure that content from our sites o apps is presented in the most effective manner for you and for your computer or mobile device.

Information we collect about you, we will use this information:

• to administer our sites, apps and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our sites and apps to ensure that content is presented in the most effective manner for you and for your computer and mobile or wireless devices;
• to allow you to participate in interactive features of our Services, when you choose to do so;
• as part of our efforts to keep our sites and apps safe and secure;
• to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
• to make suggestions and recommendations to you and other users of our sites or apps about goods or services that may interest you or them.
• For identification purposes, including but not limited to, for KYC and login, and compliance purposes, including but not limited to for AML and address identification.

Information we receive from other sources. We will combine this information with information You give to us and information we collect about You. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

How we share information 

We may share Personal Information about You in the following ways:

• To verify your identity. For example, we may share information about you with credit reporting agencies to verify your Social Security number or with 3^rd party to verify authenticity of your identification document, that your are not a PEP (politically exposed person) and so forth.
• With vendors and service providers for: (i) provision of IT and related services; (ii) provision of information and Services you have requested; (iii) payment processing; and (iv) customer service activities; (v) fraud prevention; (vi) analytics services; and (vii) in connection with the provision of the Services. These service providers have contracted with us to only use the Personal Information for the purpose(s) for which the data were originally collected or may otherwise be lawfully processed.
• Business partners. We may share Personal Information with our business partners, affiliates, and for our affiliates’ internal business purposes or to provide you with a product or service that you have requested. We may also share Personal Information with business partners with whom we may jointly offer products or services, or whose products or services we believe may be of interest to You.
• With third parties for legal reasons. We may share information about you if we reasonably believe that disclosing the information is needed to:
  • comply with any valid legal process, governmental request, or applicable law, rule, or regulation;
  • investigate, remedy, or enforce potential Terms of Service violations;
  • protect the rights, property, and safety of us, our users, or others; or
  • detect and resolve any fraud or security concerns.
  • To comply with KYC and AML.
• With third parties as part of a merger or acquisition. In the event of a transaction or proposed transaction involving the transfer of substantially all of the assets of Company or one or more of its businesses to another entity, whether an affiliate or a third party, or in connection with a bankruptcy, we may share Your Personal Information in the diligence process or to otherwise facilitate the transaction, and with individuals assisting in the transaction or in connection with a bankruptcy. Your Personal Information may also be one of the transferred assets as part of the transaction or bankruptcy.

Cookies & analytics technologies

We use various technologies to collect information, including cookies, and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our site and your experience, see which areas and features of our site are popular, and count visits. We may use cookies on our site when You are logged in so that we can remember this fact. This prevents you from having to log in every single time you visit a new page. These cookies are typically removed or cleared when you log out to ensure that you can only access restricted features and areas when logged in. This site offers newsletter or email subscription services and cookies may be used to remember if you are already registered and whether to show certain notifications which might only be valid to subscribed/unsubscribed users. When you submit data to through a form such as those found on contact pages or comment forms cookies may be set to remember your user details for future correspondence. Web beacons are electronic images that may be used on our site or in emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our site. For more information about cookies visit: http://www.allaboutcookies.org/ .

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.

Some of our business partners (e.g., advertisers) may also use cookies on the Site. For example, on occasion an advertiser may run a banner campaign on our Site. This Privacy Policy covers the use of cookies by this Site only and does not cover the use of cookies by any business partners or advertisers on our Site.

We may also use analytics tools such as but not limited to Google Analytics to collect information regarding visitor behavior and visitor demographics on our Site, and to develop website content and for marketing purposes. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and Processing of data generated by your use of the Site by going to http://tools.google.com/dlpage/gaoptout.

Clear Gifs (Web Beacons)

We may employ a software technology called clear gifs (a.k.a. Web Beacons) that help us better manage content on our Site by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear gifs are embedded invisibly on Web pages and are about the size of the period at the end of this sentence. We may tie the information gathered by clear gifs to our customers’ Personal Information. We may use clear gifs in our HTML-based emails to let us know which emails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns.

How long we keep your information 

We will retain your information for as long as You use our Services or as necessary thereafter to fulfill the purpose(s) for which it was collected, provide our products and Services, resolve disputes, establish legal defenses, conduct audits, enforce our agreements, and comply with applicable laws, such as but not limited to the United Kingdom and European GDPR privacy regulations.

Where we store your information

All information You provide to us is stored on our secure servers. Any transactions, specifically any payment transactions will be stored encrypted. Where we have given You (or where You have chosen) a password which enables you to access certain parts of our site, app or Services, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. 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 or app; any transmission is at Your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. Any information from European residents will be stored on servers in a country of the European Union.

External Sites

Our Services may contain links to other websites and other websites may reference or link to our Services. These websites are operated by third parties not controlled by us, and by linking to them or being linked from them Company does not endorse, approve or make any representations about third-party websites or domains. We encourage You to read the privacy policies of each and every website and domain that you interact with. We are not responsible for the privacy practices or content of such other websites or domains and You visit them at your own risk.

Social Media

Our Services may contain links and interactive features with various social media platforms. If you already use these platforms, their cookies may be set on your device when using our Services. You should be aware that Personal Information which you voluntarily include and transmit online in a publicly accessible social media platform, blog, or chat room, or otherwise online, or that you share in an open forum, may be viewed and used by others without any restrictions. We have no control over such uses of your information when interacting with a social media platform, forums or otherwise online and by using such services You assume the risk that the Personal Information provided by You may be viewed and used by third parties.

Security

We take commercially-reasonable measures to protect the data you have given us from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. However, please be aware that no transmission of Personal Information over the Internet or the electronic storage of this information can be absolutely guaranteed to be free from unauthorized use or access. Before submitting any Personal Information via the Site or Services, please keep in mind these risks and know that You do so at your own risk.

Your Choices 

• Communications Preferences

If you no longer want to receive email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. You will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain communications regarding Company and you will not be able to opt out of those communications (e.g., communications regarding updates to our Privacy Policy or 2FA emails).

• Sharing Preferences

We may give you choices regarding the sharing of your information with affiliates and third parties. Choices you have about the sharing of your information will be described in the privacy policies or notices you receive in connection with the products or Services you obtain from us.

Changes to this Privacy Policy

Company and www.rewirehding,com (“we”), may change this Privacy Policy (or any Terms and Conditions) from time to time. If we do, we will post the revised Policy on this page with a new “Last Updated” date. All changes will become effective when posted unless indicated otherwise. If we make any material changes we may choose, at our sole discretion, to post a notice on this website or to potentially sent a notification to your Company app or to your email prior to the change becoming effective. We encourage You to periodically review this page for the latest information on our privacy practices.

Other Rights and Important Information 

• Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 16 years of age, and no part of our Services are directed to children under the age of 16. If you learn that your child has provided us with Personal Information without your consent, please let us know by contacting us at contact@rewireholding.com . If we learn that we have collected any personal information from children under 16, we will use commercially-reasonable efforts to delete such information.

• Your rights

You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise that right at any time by contacting us at contact@rewireholding.com . Our sites or apps may, from time to time, contain links to and from the websites or in-app links of our partner networks, advertisers and affiliates. If you follow a link to any of these websites or in-app links, please note that these websites or in-app links have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before You visit such websites or before You submit any personal data to these websites on in-app links.

Disclosure of information

By using any of our Service, websites or apps You agree irrevocably that we have the right to share your personal information with:

• any member of our staff or related entity within our group, parent or holding company or subsidiaries. – selected third parties including: – businesses, financial service providers, banks, Card providers, suppliers and sub-contractors, service providers, for the performance of any contract we enter into with you or with third parties or for providing our services through our apps, products, and our infrastructure, such as including but not limited by:

– analytics and search engine providers that assist us in the improvement and optimization of our sites or apps;

– credit reference agencies for the purpose of assessing your credit score where this is a condition of us entering into a contract with you. We will disclose your personal information to third parties:

– KYC/AML/anti-terrorism-financing and any such other Compliance agencies or third party contracted companies for such purpose of assessing your identity, living or fiscal address, anti-money laundry checks and checks for source of funds or other such services where this is a condition of us entering into a contract with you or such third party. We will disclose your personal information to third parties:

• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
• If Company sells part or all of its assets, acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
• If we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights, property, or safety of Company, or rewireholding.com owners, or any of its officers, shareholders, customers, or others. This includes exchanging information with other companies and organizations for the purposes of financial compliance, customers fiscal address compliance verifications to comply with applicable laws, fraud protection and credit risk reduction and so forth.

Using our service, website or app means You accept these Privacy Policies but also accept irrevocably all our Terms of Service so read them carefully.

Contact us 

If you have questions or comments about this Privacy Policy, please contact us at  contact@rewireholding.com