WM Privacy Policy

Who are we?

We would like to assure you that the collection and processing of your personal data by Wakanda Messenger (“we”, “our”, “us”) as per the below will be always in full compliance with the EU General Data Protection Regulations 2016/679 (“GDPR”) and other applicable privacy laws.

This Privacy Policy applies to https://wakandamessenger.com and Wakanda messenger services (the "App"). May you switch to other websites or application, their own data protection regulations and policies will apply.

This Privacy Policy (“Policy”) sets out how we collect, use, disclose, secure, dispose and retain any personal data collected and how individuals (“you”, “your”) may interact with us about it.

What kind of personal data do we collect?

Personal data is any information relating to an identified or an identifiable natural person who can be directly or indirectly identified by reference to an identifier.

Some examples of personal information that we may collect are:

  • Personal Particulars (E.G. Name, Contact Details, Residential Address, Proof Of Address, Date Of Birth, Identity Card/Passport Details, And/Or Corporate Details Including Board Of Directors, Shareholders And Beneficial Owner/S);
  • Financial Details (E.G. Income, Expenses);
  • Images And Video And Voice Recordings Of Our Conversations With You;
  • Employment Details (E.G. Occupation, Directorships And Other Positions Held, Employment History, Salary, And/Or Benefits);
  • Information About Your Risk Profile;
  • Banking Information (E.G. Account Numbers And Banking Transactions); And/Or Personal Opinions Made Known To Us (E.G. Feedback Or Responses To Surveys);
  • Information Obtained With Consent From Your Mobile Device Like Device Location, Device Information (Including Storage, Model, Mobile Network) Transactional And Promotional SMS, Communication Information Including Contacts And Call Logs.

In addition, the use of our website may result in indirect personal data processing about you, for example:

  • Technical connection data, such as the visited page of our website, your shortened IP address, date and time of the visited and the type of terminal used;
  • Data collected as part of the website management and security purposes.

For what purpose and on what legal basis do we collect your personal data?

Wakanda Messenger collects and uses the financial information and other personal information from its customers for :

  • Developing And Providing Payment Facilities, Products Or Services (Whether Made Available By Us Or Through Us), Including But Not Limited To:
    • Wallet, Prepaid Card Or Other Transactions And Clearing Or Reporting On These Transactions;
    • Carrying Out Research, Planning And Statistical Analysis; Or Analytics For The Purposes Of Developing Or Improving Our Products, Services, Security, Service Quality, And Advertising Strategies;
  • Assessing And Processing Applications, Instructions Or Requests From You Or Our Customers;
  • Communicating With You, Including Providing You With Updates On Changes To Products, Services And Banking Facilities (Whether Made Available By Us Or Through Us) Including Any Additions, Expansions, Suspensions And Replacements Of Or To Such Products, Services And Financial Facilities And Their Terms And Conditions;
  • Managing Our Platform And Business Operations And Complying With Internal Policies And Procedures;
  • Responding To Queries Or Feedback;
  • Addressing Or Investigating Any Complaints, Claims Or Disputes;
  • Verifying Your Identity For The Purposes Of Providing Financial Facilities, Products Or Services;
  • Conducting Screenings Or Due Diligence Checks As May Be Required Under Applicable Law, Regulation Or Directive;
  • Complying With All Applicable Laws, Regulations, Rules, Directives, Orders, Instructions And Requests From Any Local Or Foreign Authorities, Including Regulatory, Governmental, Tax And Law Enforcement Authorities Or Other Authorities;
  • Monitoring Products And Services Provided By Or Made Available Through Us;
  • Complying With Obligations And Requirements Imposed On Us From Time To Time By Our Service Providers;
  • Financial Reporting, Regulatory Reporting, Management Reporting, Risk Management (Including Transaction Monitoring), Audit And Record Keeping Purposes;
  • Enabling Any Actual Or Proposed Assignee Or Transferee, Participant Or Sub-Participant Of Wakanda Messenger Rights Or Obligations To Evaluate Any Proposed Transaction;
  • Enforcing Obligations Owed To Us; And/Or Seeking Professional Advice, Including Legal Advice.

We may also use personal information for purposes set out in the terms and conditions that govern our relationship with you or our customer.

Wakanda Messenger may divulge some personal information collected from the customer, for cross selling or any other purposes.

Any information that is freely available or accessible in public domain shall not be regarded as personal information for the purposes of this Policy and Wakanda Messenger shall not be responsible for the same.

The collection and processing of your personal data takes place for the following purposes, in accordance with Art. 6 GDPR:

  • When necessary for our legitimate business interests for an effective recruitment and selection process and/or in relation to all aspects of our business given that it is not overridden by your rights;
  • Based on your consent, while using Wakanda messenger services;
  • Necessary to fulfil our legal obligations.

Do we share your personal data with third parties?

The personal information collected by Wakanda Messenger shall not be disclosed to other organization except:

  • Where The Disclosure Has Been Agreed In A Written Contract Or Otherwise Between Wakanda Messenger And The Customer;
  • Where Wakanda Messenger Is Required To Disclose The Personal Information To A Third Party On A Need-To-Know Basis, Provided That In Such Case Wakanda Messenger Shall Inform Such Third Party Of The Confidential Nature Of The Personal Information And Shall Keep The Same Standards Of Information/ Data Security As That Of Wakanda Messenger.
  • Where Request For Disclosure Is Requested By Local Authority Under Applicable Law or Regulations.

How do we transfer your personal data?

In case of transfer to an entity located outside the European Economic Area we will act appropriately to ensure the personal data has the level of protection as required by the GDPR.

In all cases, we will ensure that the recipient of the data has put in place appropriate technical and organizational measures and is compliant with applicable data protection laws.

Where is your personal data stored?

We store your personal data in external Amazon data centers.

How long will your data be stored for?

As a matter of principle, personal data is retained (1) for as long as needed to achieve the purposes as described in this Policy, or (2) if we have another legal basis that requires a longer storage period.

We will delete or anonymise personal data (or equivalent) once they are no longer necessary to achieve the purposes for which they have been collected, subject however (i) to any applicable legal or regulatory requirements to store personal data for a longer period, or (ii) to establish, assert, exercise and/or defend actual or potential legal claims, investigations or similar proceedings, including legal holds.

Your privacy rights

You have the right, subject to the applicable local data protection legislation, to:

  • Request access to, and receive a copy of, the personal data we hold about you (‘Right to access’, Art. 15 GDPR);
  • If appropriate, request rectification or erasure of the personal data that are inaccurate (‘Right to rectification’, (Art. 16 GDPR);
  • Request the erasure of the personal data, subject however to applicable retention periods (‘Right to be forgotten’, Art. 17 GDPR);
  • Request a restriction of processing of the personal data where the accuracy of the personal data is contested, the processing is unlawful,
    or if the Data Subjects have objected to the processing (‘Right to restriction of processing’, Art. 18 GDPR);
  • Object to the processing of the personal data (‘Right to object’, Art. 21 GDPR);
  • Receive the personal data in structured, commonly used and machine-readable format (‘Right to data portability’, Art. 20 GDPR);

If you object to the processing of your personal data, we will no longer process the personal data unless we have compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.

Sharing of personal information with Wakanda Messenger is voluntary and in case customer wishes to withdraw its consent or make modifications to the personal information, customer can do so by suspending their subscription to the Wakanda app and customer accepts the effects of such withdrawal.

How do we protect your personal data?

We have established the security in accordance with the GDPR principles. The measures taken are technical and organizational measures relating to data security in order to guarantee an adequate level of protection regarding confidentiality, integrity, availability of the data and resilience of the systems.

Technical measures are those that directly involve the IT system. Organizational measures, on the other hand, are related to the system's environment and processes; and particularly to the people using it. The combination of both types of measures can prevent data from being destroyed or lost by mistakes, fakes and unauthorized access from occurring.

These measures are part of the life cycle of our organisation and are implemented at every level of the system. Furthermore, security is an ongoing process, not a static element. In this perspective, the technical and organizational measures are subject to technical progress and further development as risks and threats do.

Cookies

Our website and mobile application use cookies.

A cookie is a small text file placed on your computer or mobile device when you visit a website or use an app. Cookies collect information about users and their visit to the website or use of the app, such as their Internet protocol (IP) address, how they arrived at the website (for example, through a search engine or a link from another website) and how they navigate within the website or app. We use cookies and other technologies to facilitate your internet sessions and use of our apps, offer you products and/or services according to your preferred settings, track use of our websites and apps and to compile statistics about activities carried out on our websites and/or through our apps.

A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.

You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites.

We seek certain app permissions at the time of installation on your mobile device, providing us access to data on your mobile device to make your financial experience personalized and enabling us to offer you relevant products and services. Should you wish to modify or disable these permissions, you can change the app settings on your mobile device at any time. Do note that some of the functionality and offers on the app may get impacted by this action.

Reviews/changes to this Policy

We reserve the right to review this Policy periodically and where necessary, due to changes in business operations or data protection regulations or applicable employment legislation. Any updated version of this Policy will be uploaded on our website. By doing so, you are consistently aware of what and how data is processed. We recommend that you check our website from time to time to ensure that you remain satisfied with any such changes at time you send us new or additional information. You will find the date of the latest version at the beginning of the present Policy.

Further information

Feel free to contact us for more information. In addition to the Contact page on our website, should you have any enquiries, concerns or requests regarding this Policy, how your personal data is processed, please use the contact details below. You can address your questions, comments or request regarding privacy.

Email : [email protected]

As of : August 03, 2020

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