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.
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)
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
5. To further provide assistance through contact such as email or telephone number
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.
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:
• 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.
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.
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.
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.
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.
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.
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.
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.
This document was updated on 16 June 2022 and is effective from that date.
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.