Privacy Policy
PRIVACY POLICY Last Modified Date: 03/01/2021 1. About us 1.1. Woonkly OÜ (“Woonkly”, “we” and “our”) take the protection of your data seriously. This privacy policy ("Privacy Policy") explains our policy and practice regarding how we collect, use and share your personal information and how you can exercise your rights in relation to your personal information. 1.2. The Privacy Policy is part of Woonkly's terms of service available on its website: www.woonkly.com ("Website"). 1.3. If you do not agree with the Privacy Policy, please do not use the website. 1.4. Please read the following terms carefully before starting to use the Woonkly service, by starting to use the services, you certify that you have accepted our Privacy Policy. 2. Reach 2.1. Our services include advertising and cryptocurrency services, allowing you to view advertisements and earn Woonkly (Woonk) utility tokens. 3. The Controller 3.1. We are the data controllers, a company registered in Estonia as Woonkly OÜ (registration code: 14732669). You can contact us via e-mail at [email protected] or by mail at Roosikrantsi Street 2-1109, 10119, Tallinn, Estonia. 4. Personal data that we process 4.1. We only process information that you have provided to us or that has been collected by us while using our website. 4.2. We process: 4.2.1. From non-investor users, who observe advertisements: Name, date of birth, gender, profession, identification, contact information (address, telephone number, country, email address). 4.2.2. Of users who want to go to the panel of investors, for which they need to go through a “know your client” analysis “KYC”: address, date of birth, gender, marital status, profession, identification document (Passport, personal identification, driver's license), contact information (address, phone number, country, email address). 4.3. We process and analyze your IP, to identify your location because Woonkly services may be restricted in some regions by the following specifications listed below: 4.4. If the aforementioned information is not available, you will not be able to use the service on the website. 5. How we use your personal information 5.1. We process your information mainly to fulfill the contract between us, to comply with legal obligations and in some cases based on consent, if it has been granted. 5.2. We process your personal information as presented in the following table:
Personal information
Processing purpose
Legal basis of the processing
Name
    To identify the user (including the KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
Date of birth
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
Gender
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
Profession
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
    User consent
Contact information (Address, country, phone number, email address)
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Email address to direct advertisements, as long as the consent has been given by the user.
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
    User consent
Identification information
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
    User consent
Marital status
    To identify the user (including KYC)
    To provide you services
    For security and control purposes related to the service
    To satisfy legal and regulatory requirements
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
IP address
    In order to provide the availability of our services where possible and appropriate.
    To validate records, logins.
    To detect attacks on our system.
    Processing is necessary for the creation of the contract
    Necessary to comply with the legal obligations of a controller
5.3. We keep the records in the case of having given consent for the receipt of advertising emails. We also keep logs whether you have given consent for direct marketing e-mails. There is the option to make changes related to the receipt of advertising emails and withdraw consent.
6. Retention of personal information
6.1. We retain your personal information for as long as necessary, in accordance with the objective of collecting data required by law.
6.2. If you wish, your information can be removed.
7. How we share your personal information
7.1. We do not disclose your personal information to third parties without your, except if we have legal bases to do so (for example: to supervisory authorities, accountants and in events related to the law, or if necessary to process a claim against you).
7.2. You agree to the possible use of your data with third parties to process your personal information for the purposes of providing the ability to use the website.
8. Cookies 8.1. Our website uses cookies. The information related to Cookies is specified in our Cookies Policy.
9. Location of data and international transfers
9.1. Data processing (including storage) takes place on different servers within the European Union and the United States (Amazon's web services cloud).
9.2. In case we transfer your data to third countries. In case the company transfers your data to third countries, the company will follow applicable regulations and take appropriate measures to keep your data safe. We make sure that the cloud provider has a certified privacy shield.
10. Data security
10.1. We have taken steps to ensure that the data is as secure as possible. We keep your data safe through the use of organizational, physical and technological measures.
10.2. The technical measures we use include that all APIs ("Application Program Interface") are secured by authentication, encrypted keys, ports external to the server are closed with AWS Firewall and measures to prevent SSH attacks. ("Secure Shell") have been taken, all operations on the site are performed through an HTTPS session.
10.3. Access to personal information is restricted and certain access rights are established.
11. Your rights as a data subject 11.1. Right of access. As a user you can manage your personal information in your account / dashboard settings. We provide, upon request and at no additional cost, a copy of the personal information that we process.
11.2. Right to be informed. This privacy policy informs you about who we are, what types of personal information we process, how it is processed, the explanation of your rights and how they can be enforced. If you want more information about this Privacy Policy, you can find our contact at the end of this text.
11.3. Right to data portability. You can easily copy, move or transfer personal information previously provided to a third party service if you wish, in order to maintain its use.
11.4. Right to delete. You have the right to request the deletion of your personal data as long as the retention of data is not established by law.
11.5. Right of opposition. You have the right to object to the way in which your personal information is processed. You have the absolute right to object to the use of your personal data for marketing purposes. In any other circumstance, we will respond to your objection within one month.
11.6. Right to rectification. You have the right to correct and modify your personal information in your account within the website at any time, therefore, you are responsible for the accuracy of your personal data.
11.6.1. Right to restrict the process. In accordance with the GDPR ("General Data Protection Regulation"), you may, depending on the circumstances, have the right to ask us to suppress the use of your personal information. We reserve the right to store your personal information, even if it is not used.
11.7. Right to withdraw consent. You have the right to withdraw consent at any time without affecting the legality of the process, based on the consent prior to its withdrawal.
11.8. Rights related to automated decision-making, including profiling. We do not make automated decisions.
11.9. Right to complain to a data protection authority. You have the right to lodge a complaint with the Estonian Data Protection and Inspection Supervisory Authority, located at Tatari 39, 10134 Tallinn, Estonia.
12. Updates to this privacy policy
12.1. Please be aware that this privacy policy may be revised from time to time. Consequently, our privacy policy could present changes and / or modifications. Any changes and / or modifications will be published on the website and sent by email to the address previously provided to notify you of changes in the privacy policy. Before the changes take effect, a notification about the changes will be posted on the homepage of the website for a reasonable period of time.
12.2. The effective date is at the top of the privacy policy, it informs you of the latest update. We advise you to check this page from time to time to ensure that you are familiar with the updated version of the privacy policies.
12.3. By continuing to access and use the website after changes to the privacy policy have been posted, or after being notified by email, you agree to be bound by the new privacy policy.
12.4. If you do not agree with the updated privacy policies, you should stop using the website and the services provided through it.
13. Applicable law and jurisdiction
13.1. This privacy policy and the related obligations arising from it are governed by the laws of the Republic of Estonia.
13.2. Each and every one of the disputes that arise and are related to the protection of personal data will be resolved by the parties through negotiations.
13.3. In case the dispute by the parties is resolved through a judicial process, the parties agree to refer the dispute to the Harju County Court, in accordance with the legislation in force in the Republic of Estonia.
13.4. The aforementioned does not exclude consumers from their rights in matters of jurisdiction.
14. Comments and concerns
14.1. If you have questions or comments, or if you have concerns about the way in which we process your personal information, as well as if you would like to access or correct your personal information and your privacy preferences, as well as exercise your right to opt out , you can contact us by mail or email. (Established in clause number 3.1 of this privacy policy).
Address:
Woonkly OÜ
Roosikrantsi Street 2-1109, 10119, Tallinn, Estonia
Last modified 7mo ago
Copy link