Last Updated: 03 February 2020
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 3rd 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.
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.
The information we collect
There are three basic categories of information we collect:
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:
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 3rd party providers, your name will show up with it.
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.
Enter an email address that you’ll use to sign in to your Company account, like firstname.lastname@example.org. 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
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.
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.
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.
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:
Country of SIM, connected Mobile service provider (home or roaming).
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).
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.
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:
Information we get from third parties
These 3rd 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
How we use your 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:
For internal business purposes: Company may use Personal Information for its internal business purposes, including to:
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:
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:
Information we collect about you, we will use this information:
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:
Cookies & analytics technologies
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.
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.
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.
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.
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.
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.
Other Rights and Important Information
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 email@example.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.
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 firstname.lastname@example.org . 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:
– 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:
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.