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Privacy Policy
WAM TOKEN ACQUISITION, KYC/AML - Updated 04.11.2021
The following Token Privacy Policy was designed for WamGlobal and it will be reviewed and updated periodically according to all applicable laws and regulations.
The WAM TOKEN Acquisition, KYC/AML Privacy Policy (hereinafter referred to as “the Token Privacy Policy”) is applicable only for the acquisition process of the WAM Tokens directly from the WamGlobal and also refers only to the subdomain https://whitepaper.wam.app.
Following the WamApp users’ requests, WamApp decided to allow the introduction of the WAM Services (as defined in the WAM Tokens Terms of Use) by taking all the necessary steps to integrate in the App, the WAM Token, an independent ERC-20 token created by WAM GLOBAL Inc.
The App’s users will be able to use the WAM Tokens as a feature of the App and all data processed will be detailed in the App’s Privacy Policy.
The purpose of this Token Privacy Policy is to easily inform you about:
  1. 1.
    The definitions of the terms provided by the GDPR.
  2. 2.
    Who is WamGlobal
  3. 3.
    Where can you find us and how can you contact us
  4. 4.
    What personal data WamGlobal may process about you, how your personal data are processed by WamGlobal, the purpose, legal basis and period of the processing
  5. 5.
    The disclosure of your personal data to third parties
  6. 6.
    Which are your rights and how can you effectively exercise them
  7. 7.
    Children’s personal data – we do not process data for children under 16 years old
  8. 8.
    What security precautions does WamGlobal have in place to protect your personal data
  9. 9.
    Links to other websites
  10. 10.
    Updates to the privacy policy
  11. 11.
    Information concerning Data Protection Supervisory Authority

1. The definitions of the terms provided by the GDPR

NSAPDP represents The National Supervisory Authority for Personal Data Processing, the Romanian independent public authority responsible for the compliance with the protection of personal data requirements.
Personal data represents any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Processing represents any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Restriction of processing represents the marking of stored personal data with the aim of limiting their processing in the future.
Controller represents the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Processor represents a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
Recipient represents a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether it is a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with the European Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
Third party a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorised to process personal data.
Data Breach represents a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data. This means that a breach is more than just losing personal data.

2. Who is WamGlobal?

WamGlobal is the commercial name of the WAM GLOBAL Inc., the creator of the WAM Tokens.
www.wam.app (hereinafter referred to as “the App”) is a technical infrastructure owned and administrated by Digitap World SRL, a Romanian company having the registered office in Cluj-Napoca, Romania, Cometei st. no 2-4, 400493, hereinafter referred to as “WamApp”.
whitepaper.wam.app is a subdomain of the App, on which are listed information’s about the WAM Token/WAM Services (as defined in the WAM Token Terms of Use), and at the drafting moment, WamGlobal has no control or access to any domain or subdomain of the Platform.
According to the GDPR n, considering the personal data processed by WamGlobal, we (WamGlobal) are considered data controller and investors are considered data subjects.
WamGlobal observes the confidentiality and security of the personal data constantly ensuring that all personal data are processed only for specific, explicit and legal purposes, according with the principles and provisions of the GDPR.

3. Where can you find us and how you can contact us

With respect to any information regarding the personal data we process you can e-mail us at dpo[@]wam.app.

4. What personal data WamGlobal may process about you, how your personal data are processed by WamGlobal, the purpose, legal basis and the period of the processing

As the law requires, should you wish to become a Token holder, you need to fulfil the Know Your Customer (KYC) procedures we have in place. Thus, we collect personal data directly from you when and if you decide to be a part of our project.
To easily identify the personal data we process, we have combined them in several categories according to the purpose of processing.
WamGlobal processes the users’ personal data, as follows:
CATEGORY 1 – WAM Tokens’ buyers
Personal data – first name, last name, date of birth, country of residence, the series and number of the identification document (ID card, passport, driving licence, etc), e-mail address, the phone number and the Public Registered Address (the wallet’s public address), financial status (which may indirectly results from the amount of the acquired Tokens).
The purpose of processing – the personal data are processed for the purpose of allowing you to acquire the WAM Tokens, as the applicable laws require us to collect and process the personal data mentioned above. All the personal data are processed for (i) concluding the Agreement, (ii) issuing the invoice and (iii) complying with the requirements imposed by the regulation applicable to Know Your Customer (KYC), Anti Money Laundering (AML) and Politically Exposed Persons(PEP).
The legal basis – art. 6 para. 1 letter b) of the GDPR, which allows us to process personal data, when necessary, for the performance of a contract.
art. 6 para. 1, letter c) of the GDPR, which allows us to process personal data, when is necessary to comply with the applicable legal provision.
The collection method - directly from you, when you access the platform indicated by us and fulfil the KYC procedure.
The retention period – as a rule we try to keep less data as possible, and in this case, we are keeping your personal data as long as it is required by the applicable law, especially the anti-money laundering and fighting against terrorism laws.
All data are maintained at least 1 year after you will Claim the last instalment of the WAM Tokens to which you are entitled to. After this term we will keep only the necessary data from the accounting perspective.
CATEGORY 2 – SOCIAL MEDIA PLATFORMS
Personal data – related to each user, such as: user’s social media accounts; any other information users decide to provide us with when they contact us on the social media platforms; any other information users decide to provide us with when they contact us by e-mail; comments and/or posts on our profiles.
Given that the internet is not a safe space, please do not send us or limit, as much as possible, the personal data communicated through social platforms or e-mail.
The purpose of processing – the personal data mentioned above are processed for customer support purposes.
The legal Basis: Art. 6 para. 1 letter b) of the GDPR Regulation, which allows us to process personal data when necessary, for performance of a contract or for the steps prior to its conclusion.
The collection method – personal data are collected directly from users when they decide to contact us.
The retention period: personal data are stored for the purpose of proving the fulfilment of contractual obligations between the parties for a period between 30 days and 1 year, depending on the nature of the request (complaint, request for guarantee, contractual request, general request, etc.)
Generally, personal data are kept for a limited period according to the purpose of the processing and the legal provisions applicable to each category of data.
WamGlobal ensures the proper deletion of personal data when such processing is no longer necessary.

5. The disclosure of your personal to third parties

Throughout its normal course of business WamGlobal will not disclose or transfer, for direct marketing purposes, your personal data to third parties, regardless if such parties are located in Romania, in EU or outside EU.
Our Employees
WamGlobal employees having access to personal data have been trained to observe the security and confidentiality of the personal data they have access to in performing the business activity. WamGlobal employees’ access to personal data is limited to the information required in performing their specific tasks.
Suppliers
We perform our daily activities at the highest standards thus sometimes we chose to cooperate with other companies in order to facilitate several technical or administrative processes such as: KYC verification, PEP verification, e-mail hosting services, storing data, sever hosting, legal services etc.
In case we decide to contract third parties for the supply of specific services, we will ensure that such third party complies with the provisions of GDPR and we will provide all information required for the proper performance of their services.
Legal Requirements
Your personal data may be communicated to governmental authorities and/or law enforcement agencies if required by the applicable law.

6. Which are your rights and how can you effectively exercise them

WamGlobal as data controller, ensures technical and organisational measures to be sure that your rights (as a data subject) are observed:
Right of access
You have the right to obtain the confirmation as to whether or not personal data concerning you are being processed by us, and, where that is the case, access to your personal data and information on how they are processed.
Right to data portability
You have the right to receive some of your personal data, which you have provided to us, in a structured, commonly used and machine-readable format and you have also the right to transmit those data to another controller without hindrance from us, where technically feasible.
Right to object
You have the right to object to processing of your personal data, when processing is necessary for the performance of a task carried out in the public interest or for the purposes of the legitimate interests pursued by us. You have the right to object at any time if your personal data are being processed for direct marketing purposes.
Right to rectification
You have the right to obtain from us without undue delay the rectification of inaccurate personal data concerning you. The rectification shall be communicated to each recipient to whom the data was sent unless this proves impossible or involves disproportionate (demonstrable) efforts.
Right to erasure ( "right to be forgotten" )
You have the right to obtain from us the erasure of personal data concerning you without undue delay and we have the obligation to erase your personal data without undue delay where one of the following grounds applies: your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraws consent on which the processing is based and there is no other legal ground for the processing; you objects to the processing and there are no overriding legitimate grounds for the processing; your personal data have been unlawfully processed; your personal data have to be erased for compliance with a legal obligation; your personal data have been collected in relation to the offer of information society services.
Right to restriction of processing
You have the right to obtain from us restriction of processing where one of the following applies: you contest the accuracy of your personal data, for a period enabling us to verify the accuracy of your personal data; the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead; we no longer need your personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims; you has objected to processing pending the verification whether the legitimate grounds of the controller override those of the data subject.
Right not to be subject to a decision based solely on automated processing
You have the right not to be subject to a decision solely based on automated processing, including profiling, which produces legal effects concerning the data subject or similarly affects the data subject in a significant manner. Therefore, we hereby state that WamGlobal does not use applications, algorithms, artificial intelligence or automatic process to make automatic decisions (without human intervention) that produces legal effects.
To exercise your rights listed above you can send us your request (accompanied by your contact details) electronically to the e-mail address gdpr[at]wam.app.

7. Children’s personal data

WamGloblal does not collect any Personal Data from children under the age of 16.
So, if you are under 16 please do not submit to us any Personal Data.

8. What security precautions does WAM takes to protect your personal data

We have assumed the responsibility to implement proper technical and organisational measures regarding the protection of privacy and security of your personal data. We have taken all reasonable measures to protect your Personal Data from damage, loss, misuse, unauthorised access, alteration, destruction, or disclosure, as following:
  1. 1.
    People who have access to our filing system are only those nominated by WamGlobal. To accesses the system, they use individual accounts and passwords which are changed periodically
  2. 2.
    All our employees, collaborators and service providers who are in contact with personal data must act in accordance with the principles and policies regarding to the processing of personal data. They were informed and they have assumed to respect of the GDPR by signing the Data Processing Agreements or as an effect of the law
  3. 3.
    Our employees and collaborators access personal data for the performance of their professional duties and only in accordance with the stated purpose of data collection
  4. 4.
    Computers from which the filing system is accessed are password-protected and have antivirus, antispam and firewall security updates
  5. 5.
    Personal data is printed only by authorised users, if it is necessary to perform our activity or to fulfil our legal obligations
Please also select carefully what personal data do you choose to submit thinking that the internet or e-mails are not impenetrable spaces, and a technical error can cause an unhappy event anytime with respect to your personal data.
On our website you may find links to other organisations. This Token Privacy Policy do not cover the personal data processed by them.
If you decide to access other organisation’s links, we encourage you to carefully read their Token Privacy Policy which should be found on their websites. In general, the Token Privacy Policy may be accessed on the bottom section of the website.

10. Updates to the Privacy Policy

In order to keep you informed, we always publish the latest version of the Token Privacy Policy on our website, without any specific notice in this respect.
We assure you that the way we collect and process your personal data is in accordance with the provisions of the GDPR Regulation.
We encourage you to constantly review this Token Privacy Policy in order to be constantly informed with respect to the categories, purposes and manners WamGlobal processes your personal data.
If you have any questions about our Token Privacy Policy, please contact to us at: privacy[at]wam.app.

11. Information concerning Data Protection Supervisory Authority

If you consider that your rights provided by Regulation no. 679/2016 have been violated, you can address directly to us or to our Data Protection Supervisory Authority: National Authority for the Supervision of the Processing of Personal Data (Autoritatea Naţională de Supraveghere a Prelucrării Datelor cu Caracter Personal) ”ANSPDC” by submitting a complaint.
Contact details of the authority:
Address: B-dul G-ral. Gheorghe Magheru 28-30, Sector 1, cod postal 010336, Bucuresti, Romania
Last modified 2mo ago