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Privacy Policy

Updated: December 13th, 2022

This Privacy Policy contains an overview about the collection, use and disclosure of your personal data. In case the information covers only one of our services we will explicitly point this out to you. Please read this Privacy Policy carefully as it applies when you use our Services or visit our Website or use our App. We take privacy and protection of data seriously and are committed to handling the personal information of those we engage with, whether customers, suppliers or colleagues, responsibly and in a way that meets the legal requirements of the countries in which we operate.

This policy also applies to any mobile applications that we develop for use with our services and Team specific pages on the Site, and references to this “Site”, “we” or “us” is intended to also include these mobile applications. Please read below to learn more about our information practices. By using this Site, you agree to these practices.

1. Who we are

UAB Wind Technologies (“Wind”, “us”, “we”, “our”) is responsible for the collection, use and disclosure of your personal information. If you have any questions about how we protect or use your data, please email us at support@wind.app.

2. Data we collect about you

We will collect the following data about you:

2.1 Information you give us.

(a) You may give us information, including personal information, about yourself when you sign up to use our Services, e.g. your name and email address. This also includes information you provide through your continued use of our Services, participate in discussion boards or other social media functions on our Website or App, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, personal description and photograph.

(b) We may also need additional commercial and/or identification information from your e.g., if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.

(c) In providing the personal data of any individual (other than yourself) that for example may receive payments from us as part of your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy;

2.2 Information we collect about you. With regard to your use of our Services, we may automatically collect the following information, some of which may be or include personal information:

(a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

(b) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.

2.3 Information we receive from other sources. We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:

(a) the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;

(b) business partners may provide us with your name and address, as well as financial information, such as card payment information;

(c) advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website;

(d) credit reference agencies do not provide us with any personal information about yourself but may be used to corroborate the information you have provided to us.

2.4 Information from social media networks. If you log in to our Services using your social media account (for example, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy.

2.5 Children’s information Our products and services are directed at adults 18 years and over and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents Wind from collecting such data. If any information is collected from a child without verification of parental consent, it will be deleted.

3. How do we protect your information

3.1 We use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transaction information will be encrypted.

3.2 As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information during transmission, and any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

3.3 We continuously educate and train our employees about the importance of confidentiality and privacy of customer personal information. We maintain physical, electronic and procedural safeguards that comply with the relevant laws and regulations to protect your personal information.

4. Uses made of the information

4.1 We use your information in the following ways:

(a) where you have given us your consent to process your data;

(b) to carry out our obligations relating to your contract with us and to provide you with the information, products and services;

(c) to comply with any applicable legal and/or regulatory requirements including laws outside of your country of residence or to comply with any legal process;

(d) to notify you about changes to our Services;

(e) to customize our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency or token to another, we may use this information to inform you of new product updates or features that may be useful for you;

(f) as part of our efforts to keep our Services safe and secure;

(g) to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(h) to improve our Services and to ensure that they are presented in the most effective manner;

(i) to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

(j) to allow you to participate in interactive features of our Services, when you choose to do so;

(k) to allow us to pursue available remedies or limit the damages that we may sustain and to enforce our terms and conditions

(l) so that we can provide you with information regarding our public policy advocacy efforts.

(m) to provide you with information about other similar goods and services we offer;

(n) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or

(o) to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of your information

5.1 We may share your information with selected third parties including:

(a) affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;

(b) advertisers and advertising networks solely to select and serve relevant adverts to you and others;

(c) analytics and search engine providers that assist us in the improvement and optimisation of our site; and

(d) our group entities or subsidiaries - which can be found by clicking here

5.2 We may disclose your personal information to third parties:

(a) affiliates, business partners, suppliers and subcontractors for the performance and execution of any contract we enter into with them or you;

(b) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

(c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements; or to protect the rights, property, or safety of Wind, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

(d) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;

(e) to prevent and detect fraud or crime;

(f) in response to a subpoena, warrant, court order, or as otherwise required by law;

(g) to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;

(h) to allow us to pursue available remedies or limit the damages that we may sustain

(i) to recover debt or in relation to your insolvency; and

(j) to develop customer relationships, services and systems;

(k) if you consent, to share your details when using our Services.

5.3 If your discoverability feature is enabled, Wind customers can search for you via the email address or phone number registered to your Wind account. You can manage this discoverability feature under your account settings. You can also generate a link to share with any users to make it easier to send and receive money.

5.4 We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to support@wind.app.

6. Sharing and storing your personal data

6.1 The data that we collect from you may be transferred to, and stored at, a destination outside the United States. It may also be used by staff operating outside the US who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfillment of your payment order, the processing of your payment details and the provision of support services. By submitting your personal information, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

7. Cookies

7.1 We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with the best experience. It also enables us the ability to improve our services, for detailed information on cookies and other technologies we use and the purposes for which we use them see our Cookie Policy.

8. Retention of your information

8.1 As a regulated financial institution, Wind is required by law to store some of your personal and transactional data beyond the closure of your account with us, see your rights below. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.

8.2 We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.

8.3 Retention periods defined for the storage of your data can be found by clicking here.

9. Third-party links

9.1 Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

10. Changes to our privacy policy

10.1 To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the website and update the “Last Updated” date. To stay up to date on any changes, please check back periodically. Your use of our services following these changes means that you accept the revised Privacy Policy. If you would like to review the version of the Privacy Policy that was effective immediately prior to this revision, please contact us at support@wind.app

11. Data Subject To Bangladesh Law

11.1 UAB Wind Technologies is located and operates its website in Dhaka, Bangladesh. Depending on where you live, the information that you provide and that this Site collects may be stored on servers that are outside of your state, province, country or other governmental jurisdiction, and the privacy laws that apply may not be as protective as those in your home jurisdiction. If you are located outside Bangladesh and choose to provide information to us, Bangladesh transfers personal information to other countries and processes it there. By using this website, you consent to this transfer and processing of data.

12. Contacting Us

12.1 Please contact us at support@wind.app and let us know if you have any questions or comments about our policies or practices.

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