Effective Date: 01 February 2023
"WE53" PRIVACY POLICY
Version: 0.1
Last update: 23 December 2022
At WE53 (trading name of LLP "Chargeup") we respect your privacy and are committed to protecting your personal data. In this Privacy Policy we will outline how we will use, process and store any personal data we collect from you or that you provide to us, either through our Website or via our Mobile application. We will also tell you about your privacy rights and how the law protects you.
When you use our Services, you're trusting us with your information. We understand this is a big responsibility and work hard to protect your information and put you in control.
1. This policy applies to your use of:
2. This Policy aims to give you information on how we collect and process your personal data through your use of our Website or the Mobile application, including any data you may provide when you purchase a service, sign up to our newsletter/email, take part in a competition or survey. We may also collect and use information about you that is provided by third parties. Our Website and the Mobile application are not intended for children and we do not knowingly collect data relating to children.
3. If you have any further questions, you can contact our Data Protection Officer (DPO) on compliance@we53.io
4. The Regulation (EU) 2016/679 (General Data Protection Regulation) ("GDPR") gives you the right to see, erase, or challenge the data we hold about you (among other rights). Our support team or DPO can help with any queries you might have in relation to your data. Read the full Privacy Policy for further details on how we use your information.
5. Our Website and Mobile application use cookies to distinguish you from other Users. This helps us to provide you with a good experience when you browse our Website and Mobile application and allows us to improve the functionality of our Website and Mobile application and the User experience. Please see our Cookie Policy on the Website and Mobile application for further details.
6. In this Privacy Policy, WE53 will sometimes be referred to as 'we', 'us', or 'our'. Additionally, there are references to "You". In these instances, "You" may be a visitor to our Website, or a User of our Mobile application and its services ("User").
Controller
For the purpose of the GDPR the data controller is LLP "Chargeup" ("WE53") a company established under the laws of the Republic of Kazakhstan (company number 220940042409) and with registered address: 050002, Kazakhstan, Almaty city, Zhetysu district, Potanin Street, 47/26.
Data Protection Officer
1. We have appointed a Data Protection Officer, who has a number of important responsibilities including:
2. You can contact our DPO at: compliance@we53.io or LLP "Chargeup", 050002, Kazakhstan, Almaty city, Zhetysu district, Potanin Street, 47/26.
3. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please e-mail us compliance@we53.io
Complaints
1. You have the right to make a complaint at any time to the Commissioner, the Cyprus supervisory authority for data protection issues (https://www.dataprotection.gov.cy/). We would, however, appreciate the chance to deal with your concerns before you approach the Commissioner, so please contact us in the first instance.
2. So that we're clear and there's no misunderstanding about how we handle your personal data, we will:
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
a) Submitted Information - information you give us through direct interactions:
This is information you give us about yourself by filling in forms on the Mobile application and/or the Website, or by corresponding with us (for example, by e-mail or via the chat functions on the Mobile application and/or the Website).
It includes information you provide when you register to use the Mobile application, download or register the Mobile application, subscribe to any of our Services, enter into any order or transaction on the Mobile application, participate in discussion boards or other social media functions on the Mobile application or the Website, enter a competition, promotion or survey and when you report a problem with a Mobile application or the services.
The information you give us may include your e-mail address, phone number, transaction information (payment data, payment amount, cardholder name, first 6 and last 4 card digits, bank name, payment processing system).
b) Information we collect about you and your Device.
Device Information - each time you visit the Mobile application or our Website we will automatically collect the following information:
c) ThirdParty Information: Information to help us deliver our service to you.
Third-party Providers are not managed or controlled by the Company, and this Privacy Policy does not apply to Third-Party Providers. The Company is not responsible for the content, privacy policy or actions of third-party providers. The User has the right to study and understand the privacy policy of any third-party provider before providing any information to them or through them. The User's interaction with these features is governed by the privacy policy of the third-party provider that provides this feature.
To opt of cross-app tracking and using your Device ID:
1. Below is a summary of the key types of data that we make use of as part of the WE53 services. For more information on how these types of data are used and for which purposes then please see the table below.
2. We use information held about you in the following ways:
(a) Submitted Information: We will use this information:
(b) Device Information: We will use this information:
(c) Third Party Information: We will use this information:
3. We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
4. We have set out below, in a table format, a description of all the ways we use your personal data as stated above, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful reason depending on the specific purpose for which we are using your data.
|
What we use your information for |
Type of Information |
Our reasons |
Our legitimate interests |
|
To provide the WE53 services: To fulfil our obligations in any contract you have entered into or will enter into with us. Including: To provide you with access to WE53 platform and to enable your interaction with WE53; To provide customer service; Processing and delivering your order; and Collecting and recovering money owed to us. |
Submitted Information |
Fulfilling contracts
Our legitimate interests
Consent
Legal obligation |
Being efficient about how we fulfil our legal and contractual duties. Our commercial interest in providing you with a good service.
|
|
To keep the WE53 services up and running: To administer our Website and the Mobile application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your Device; To allow you to participate in interactive features of our service (such as prize draw, competition or completing a survey), when you choose to do so; To notify you about changes to our service and legal binding documents; and as part of our efforts to keep our Website and the Mobile application safe and secure. |
Submitted Information,
Device Information,
Third Party Information |
Fulfilling contracts
Our legitimate interests
Consent
|
Being efficient about how we fulfil our legal and contractual duties. Our commercial interest in providing you with a good service.
|
5. What do we mean, when we say:
Legitimate Interest: this means the interest of ours as a business in conducting and managing WE53 platform to enable us to provide to you the WE53 services. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
Fulfilling a Contract: this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Consent: this means that we will only process your personal data for certain specific purposes if we obtain your consent before such processing, for example in order to collect and process your location data and/or to send you notifications. We normally ask for your consent the use of your personal data in order to provide our services to you when you download the Mobile application. Please note that if you do not provide your consent for this purpose, or withdraw it at a later stage, we may be unable to provide our services to you.
6. Opting out. You can follow the opt-out links on any marketing message sent to you. In case of Third Party Information gathered via cookies you have the right to opt-out through the opt-out options provided by the relevant third party. For more information, please see the Cookie Policy.
7. Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
8. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We retain your information for as long as it is necessary for the performance of the contract we have with you. If you no longer want us to use your information you can send a request to compliance@we53.io. Please note that in this case we may be unable to provide our services to you.
1. The hosting facilities for our Website and the Mobile application infrastructure are situated within the EU.
2. The data that we collect from you will be transferred to, and stored at, a destination inside the European Economic Area (EEA).
3. All information you provide to us is stored on our secure servers. Any transmission of information is encrypted using TLS technology, the current standard in secure communications over the Internet. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk.
4. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
1. You have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights:
The right to access - You have the right to request us for copies of your personal data.
The right to rectification - You have the right to request that the Company correct any information you believe is inaccurate. You also have the right to request the Company to complete the information you believe is incomplete.
The right to erasure - You have the right to request that the Company erase your personal data, under certain conditions.
The right to restrict processing - You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
The right to object to processing - You have the right to object to the Company's processing of your personal data, under certain conditions.
The right to data portability - You have the right to request that the Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you.
WE53 does not knowingly collect any personal data from children under the age of 16. If you think that your child provided this kind of information to the Company, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Any changes we may make to our Privacy Policy in the future will be posted on our Website or in the Mobile application and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our Privacy Policy.