, including mobile apps (all referred to further in this document as "Platforms").
"Whitehat Asset Consultan” LTD considers the protection of personal data to be its highest priority and strives toward meeting all the applicable requirements of the existing data protection legislation.
This Policy applies if one uses our services (referred to further in this document as “our Services”).
What using our Services means:
- Buying good and/ services and/ advertisement/ Selling good and/ services and / advertisement/ transaction information via our platforms, etc., including websites (“our Websites”), public Wi-Fi networks, or mobile applications;
- Being a member of any of our loyalty, referrals, etc programs if any
The current Policy also applies in case a user contacts us or in case our company contacts a user regarding our Services.
PERSONAL INFORMATION WE COLLECT
Please be advised that in connection with your registration on the website https://www.xlearventures.com/ and on the basis of the requirements of the existing e-commerce regulations and other laws or subsidiary regulations, the company is obliged to verify the identity of its merchants and, for this purpose, it shall use various means it considers necessary and as permitted by law to verify a participant’s identity. For the purpose of this policy "Personal Information" refers to information that identifies an individual, such as, but not limited to:
1. Company data such as legal name, company registration number, country of registration, company contact’s person, legal representative, monthly income, sex, nationality, full name, phone number, date of birth, address, e-mail, username, confirmation that you are over 18 years old (Our platforms are not directed towards children and minors. Our services are strictly limited to individuals 18 years of age and older, or the age of majority in the relevant to the user jurisdiction, whichever is greater. Thus, we may collect relevant documents to establish the real age of the individual. We may cancel a user's account and exclude a user from using our services if we suspect that a customer is under the lawful age.);
2. IP addresses, transaction information, banking details, passport/ ID number, account login details;
3. Information about your online browsing behavior on our Websites, Mobile Apps, and public networks, as well as information about when you click on one of our adverts, other profiling information, your online Buy/Sell operations, browser type, and mobile device identifiers; information about your precise geolocation, transaction information, your feedback and contributions to customer surveys and questionnaires;
4. We may also use personal information from other sources, such as specialized companies that supply information as Identity verification agencies including Mobile Service providers, online media channels, our partners, and public registers. We may collect the following types of personal information about you from other sources such as: contact details, credit history, purchases, interests, preferences, or other types of publicly available information, data about the origin of funds for the purpose of crime prevention.
PURPOSES OF COLLECTING PERSONAL INFORMATION:
1. to abide by the compliance requirements and improve the effectiveness of your operations
2. to execute our contractual obligations
3. personal data, processed for purposes of analysis, statistics, inquiries, and complaints processing for statistical purposes in order to improve our services and to enhance the user experience when using our services
5. for analyzing various forms of risk – credit, operational, risk of fraud, AML/CFT
6. in other cases which are not mentioned above, where it is our legal obligation or is necessary to protect a legitimate or public interest
7. tо manage and improve our corporate daily operations
DISCLOSURE OF PERSONAL INFORMATION
The company could provide part of the above-mentioned personal data to Governmental Authorities due to legal obligations or in order to establish, exercise, or defend its legal rights, as well as to our trusted partners, such as carefully selected Financial Service Providers, Identity verification agencies including Mobile Service Providers that carry out certain functions on our behalf.
Regarding these partners - please be informed that we only share personal information that enables our Business Partners to execute their services in an efficient and secure manner.
For your information we use the best modern encryption methods for a username and password, and any other confidential information sent by and to the client or our servers, thus protecting the customer and our company from third-party manipulations. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorized or unintended access that is beyond our control. Furthermore, customers should not violate or circumvent established security rules as this will lead to unfavorable consequences for the customer as blocking of their accounts and, if needed, informing the authorities concerned.
In case you suspect unauthorized access and/or abuse of your account, please take precautions by changing your password or by contacting us at the following email address for further assistance – firstname.lastname@example.org
DPO email: email@example.com
RIGHTS REGARDING YOUR PERSONAL INFORMATION
These include the following rights to:
1. receive confirmation and/or detailed information, including a copy of the personal data processed for you (access right) in an online format
2. erase some personal information where and when it is allowed
3. object to the collection and further processing of your personal information - you may withdraw your consent for the processing of your personal data at any time by contacting the support team
4. file a complaint with your local data protection authority
For inquiries regarding your rights or if you wish to exercise one of them, feel free to contact us at firstname.lastname@example.org. Our specialists will process your request and reply accordingly without undue delay within 30 days of the receipt of the request. If we are unable to do so for reasons beyond our control, we will notify you in good time, indicating the reasons for the delay as well.
RETENTION REGARDING YOUR PERSONAL INFORMATION
We shall preserve your personal data for the minimum period required and, in order to achieve the objectives stated in the current Policy, unless we are legally bound or have the right to keep them for a longer period of time.
The decision on how long to keep your personal information after our relationship with you has ended, will be taken based on our legal obligations and regulators' expectations.
STORAGE OF PERSONAL DATA
All information submitted to us is stored and kept on secure servers. While the transmission of information via the Internet is not completely secure, any payment transactions and submissions of personal information are transmitted using SSL encryption technology. We shall do our utmost to protect personal data, but any transmission of data is at the user's own risk. Once we have received any personal information, strict procedures and security features will be used to prevent unauthorized access.
In the event of any conflict between the English and other language versions, the English version shall prevail.
Created on 01.10.2022