Personal Data

Personal data is the information related to a natural person and which can be used to identify that person such as name, email address, telephone number, social media usernames, your device information, and transaction. This means that when you use our services, we will collect and/or access certain information about you which can identify you directly (name and telephone number for this regards) or may collect your indirect data. Information and/or Personal Data which may be collected, stored, processed, transferred, used and disclosed by NATIV Wallet includes but is not limited to information and/or data that can be used on its own or with other information to, directly or indirectly, identify, contact, or locate a single person, or to identify an individual in context.

By using the Services, it is considered that you have read and accepted this Privacy Policy.

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Basis of the Collection, Use and Disclosure of your Personal Data and the Purposes of such Processing

Type of Personal Data Collected

• name, surname

• telephone number

• official identification document (at KYC procedure)

• chat channels ID (optional)

• email address (optional)

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Use of Data

The Company may use your Personal Data to supply you with the Company Services required, to verify you and to contact you when required, in this regards- name, surname and telephone number are to be utilized.

The Company may just access your phone data to accommodate you with more convenient service. The Company also may utilize the Personal Data provided to help in administering, supporting and improving the business, as per the following ways:

1. to provide, maintain, deliver and improve the Company Services and obtaining your views of the Company Services

2. to send information about products and services

3. to carry out any other purpose for which the information was collected

4. to comply with the laws, regulations, rules, codes of practice or guidelines issued by authorities or regulatory agencies If you want to stop receiving information as per the above, you can opt out at any time by contacting us at the email address indicated in this Privacy Policy. At all times, access to the User’s Personal Data by the Company’s own staff and third-party intermediaries, will be restricted to the bare minimum required for the Company to perform our business and the provision of the Company Services

5. To further provide assistance through contact such as email or telephone number 

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Permission to data operating and Data processing

• We are asking for CAMERA and STORAGE permissions to capture user's images and pick images from the device gallery for better user experience.

• We are using the phone number that the user registers, for the purpose of user verification via one-time password (security code). (One-time password will be sent by Nexmo Inc.)

• We are storing your information in Firebase, cloud storage.

• Our KYC service provider; Sumsub (Sum and Substance Ltd.), collects and processes personal data under Article 28 of the EU GDPR and the UK GDPR.

• In the Profile section, Facebook ID and Line ID are the optional data which we may use as optional contact channel(s) with the user. We may send you NATIV Wallet activity information that might interest you to your registered messaging channel(s) . You can opt-out of receiving future marketing materials at any time. You can unsubscribe by following the instructions contained in the messages you receive. In case you opt-out of receiving these messages, we reserve the right to send you certain notifications necessary to the services we provide. We strongly recommend not to opt-out of receiving those communications as they are important for a user to know.

• On certain Operating System(s), NATIV Wallet may access the user's device contact list upon user's permission. We do not store/collect data from your device contact list. This function is to show the phone number of the registered NATIV Wallet users stored in your device contact list for user's convenience.

• Finally, we never use or share the personally identifiable information provided to us online in ways unrelated to the ones described above, we also provide you an opportunity to opt out or otherwise prohibit such unrelated uses.

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The Disclosure of Your Personal Data to Third Parties

For the processing pursuant to the purposes under above mentioned legal basis. The Company may collect from and/or use, send, transfer, process and/or disclose the Personal Data to the following persons:

• Juristic persons having control over the Company or under the control of the Company including other companies under the same control of the Company, or other juristic persons or persons in which the Company is a contractual party, or having the legal relationship with the Company, including other service providers having power in making decision to take any action related to your Personal Data both within and outside the country such as external service providers, cloud service providers or other business partners of the Company. In this regard, the Company shall ensure that those service providers will process your Personal Data in accordance with this Privacy Policy and the applicable laws.

• The auditors, external examiners of the Company, government authorities, transferee of the right of claim, and any other persons or juristic persons that the Company is required to transfer the Personal Data as necessary to comply with the laws.

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Consent

Your Personal Data may be processed only if you have unambiguously given your consent or, the processing is necessary for the performance of the Company Services you request or, for compliance with legal obligations as in the case of Anti Money Laundering and Terrorist Financing Regulations (AML/TF) or, pursuant the public interest or, a third party with whom the Personal Data is disclosed except where such interest is overridden by the interest to protect the fundamental rights and freedoms that arise from the right of privacy. As an individual you may exercise your right to access your Personal Data held about you by the company by contacting us at the address below.

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Right to be forgotten

Upon request, you have the right to have your Personal Data erased by the Company. The Company acting reasonably will take all necessary actions , including to inform third-party data Processors to comply with the request unless your Personal Data needs to be retained to comply with legal obligations or court orders.

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Security

The Company acknowledges and realizes the importance of your Personal Data. Thus, the Company has improved and developed the security systems for your Personal Data in accordance with the laws, and up-to-date with safety in accordance with the international standard at all times. The Company will proceed at its full effort to comply with this Privacy Policy, and will urge the Company’s personnel, including data processors, who are entitled to access the Personal Data or has legal duty, to keep and respect your Personal Data security. In case the Company is necessary to transfer any of your Personal Data to foreign country, the Company will apply the standard as prescribed by the laws on personal data protection. Additionally, the Company will not transfer your Personal Data to the destination country that has no personal data protection standard sufficiently in accordance with the criteria as prescribed by the laws, except that you consent the Company to send or transfer your Personal Data to such destination country. However, in case of computer espionage resulting that your Personal Data has been stolen, whether by ways of hacking, stealing, copying or destroying database, destroying personal code (password mining) or any other methods, without the Company’s fault, in such circumstance, the Company will have the right to disclaim any liability resulting from such act.

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Children’s Privacy

NATIV Wallet is not intended for children under the age of 20. We do not knowingly or intentionally collect information about children who are under 20 years of age. At under the age of 20, you may not use the app in any way.

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Language

The translation of this Privacy Policy, whether in any language whatsoever, is for your convenience only, without any intention to change this Privacy Policy. In case of any discrepancy between the English version and any other languages version, the English version shall prevail.

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Data Subject’s Support

The Company shall provide its Users with user support through an In-App chat with an agent. To get into the user's account and chat channel, the user must log in into NATIV Wallet with a registered social media account which is collected on our database storage.

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Data Retention

The Company will retain your Personal Data and that of beneficiaries of the Company Services for a reasonable period or as long as the law requires. The Company will retain your data as long as needed for the provision of the Company Services.

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Response to Personal Data Breaches

When the Company learns of a suspected or actual Personal Data breach, the Company shall perform an internal investigation and take appropriate remedial measures in a timely manner. Where there is any risk to the rights and freedoms of Data Subjects, the Company will notify the relevant Supervisory Authorities without undue delay and, when possible, within 72 hours from when it learns of such breach. Data Subjects will be informed when the Personal Data breach is of a “high” level.

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Governing Law

By using the Services, or otherwise providing information to the Company, you consent to the processing and transfer of information in accordance with Cayman Islands laws.

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Validity

This document was updated on 16 June 2022 and is effective from that date.

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Your rights

You have the right to make a request to access or delete any of your personal data that we might possess. You can make a request by contacting our Data Protection Officer at the address below. You may be required to provide additional information to authenticate your request.

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Final Provisions

You may request the Company to access your information and Personal Data at any time. The Company shall be responsible for and be able to demonstrate compliance with the principles outlined in this Privacy Policy. The Company may at its own discretion assign or transfer this Privacy Policy and your related information to any person or entity that acquires or is merged with us without restriction. Any claims, questions, comments and requests regarding this Privacy Policy should be addressed to the Company by contacting our Officer at the address below. Changes to the Privacy Policy The Company may update this Privacy Policy from time to time at its own discretion and in response to changing legal, technical and/or business development. The revised Privacy Policy will take effect immediately upon publication by the Company and we will replace this page with an updated version. When we update our Privacy Policy, we shall take appropriate action and inform you accordingly by a Privacy Notice consistent with the significant changes we would have made. However, you acknowledge that it is your sole responsibility to check the “Privacy Policy” page from time to any time so as to be aware of any changes which may have occurred from time to time.

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Contact

Should you have any question, complaint, request to access, or query regarding this Privacy Policy and/or would like to examine any of your Personal Data in possession of the Company. You may contact NATIV Wallet Customer Support throughout 24 hours via NATIV Wallet In-App chat or at admin@21ctresearch.com.