Privacy and Security

1. Introduction

Wavix is service provider of the Services shall refer to Wavix Pte. Ltd., a Singapore company, with a place of business at 350 Orchard Road #11-08 Shaw House, Suite 32 Singapore 238868 if you are domiciled outside of USA or Canada and Wavix Inc., a Delaware corporation, with a place of business 1000 N., West Street, Suite 1200, Wilmington, Delaware, 19801, if you are domiciled within USA or Canada.Wavix, its subsidiaries and affiliates (“us”, “we”, “our”)are committed to protecting your privacy rights. This Privacy Policy should enable our users (“you” and / or “User”) to better understand how we keep your personally identifiable information (“Personal Information”) confidential.

2. Privacy Statement

To make this policy easier for understanding and to briefly inform you about our privacy priorities, we decide to make the following statement on our data privacy policy:

1. Data collection

We will collect and store your Personal Information, which is also known as “personal data” only when we will have legal grounds to do so.

2. Keeping confidentiality

We take our responsibility to protect the privacy and confidentiality of any personal data very seriously. We maintain physical, electronic and procedural safeguards that comply with applicable legal security standards to store and secure the client information from unauthorized access and use, alteration and destruction. However, in some cases government authorities like courts and police may get an access to your personal details without your authorization or prior notification, so we may disclosure your personal data for compliance reasons and for legal purposes, when and if it is required by the laws.

3. Appropriate usage

We will collect, use and maintain client information only for appropriate purposes, in accordance with applicable law requirements.

4. Data Minimization and Limitation of Data Retention

We will strive to collect as less personal data as possible and process it for the shortest possible time.

5. No Spam

We will keep your e-mail address data confidential and will provide you with option of managing the advertising communications.

6. Right to be informed

We will inform you about the collection and usage of your personal data in details.

4. How We Get Your Personal Information?

There are several ways, by which we collect your Personal Information:

We collect your Personal Information when you actively provide it to us.

For example,Users provide us with their Personal Information when signing up for an account, contact with our sales and/or support managers or communicating with Wavix by any other ways, responding to surveys, participating in events or promotions, or updating an account profile.

We may automatically collect your Personal Information.

When you use our Platform or Services some Personal Information may be automatically collected. For example, we may collect the data concerned of your activity on our Platform or activity related with our services, IP address and other metadata information of technical, geographical and sociological character. We may also use “Cookies” and other trackers to automatically collect information about Users through our Platform or Services, please see our Cookies Policy to get more information.

We may collect your Personal Information from the third parties.

We might supplement the information described above with information we obtain from other sources, including from both online and offline data providers. For example, we may get information about you from our service providers.

5. Categories of Personal Information that We Collect

We receive, store and process the following categories of Personal Information:

Personal Identifiers

Name, Surname, gender, date of birth, citizenship, ID numbers

Contact Information

Phone numbers, e-mails, residing address and any other physical or online contact information about a specific individual

Professional or employment-related information

Job titles, work location, department and duties

Payment Information

Your payment details, information about your purchases within the Platform

User Activity Data

IP address, Cookies and information about your interaction with our Platform and Services

Please note, that not all categories will be collected about every individual, because Personal Information collected depends on business, operational and legal necessity.

6. How the Personal Information is Used?

In general, we use your Personal Information to provide you with our Services and to improve our level of customer service or to meet a legal obligation of applicable law. We decide to list all purposes for which the Personal Informationmay be proceeded in order to ensure informational transparency:

• create and manage your Account;
• allow Users interact with our Platform and/or Services;
• send marketing, business and administrative messages and notifications to our Users, to allow us to notify you about changes in our products or services, or to offer you the deals, that may be interesting to you. We also believe that such communication allows us to improve our product and communicate important information to you in a timely manner;
• process and execute your transactions;
• respond to your communications and requests;
• analyze and understand our customers and their needs (for example for personalizing services by individual offers, which may be more relevant for your needs);
• improve and maintain the level of our Services (for example optimize our products and services design and functional; correct bugs and errors in the program part of our products and services);
• provide the necessary amount of data to our service providers for the purposes of performance of the contract,which you conclude with us;
• prevent, detect and investigate potentially prohibited, suspicious and / or illegal activities and/or report to the government agencies about such types of activities.

7. Legal Grounds for storage and processing of Personal Information

The legal basis for any operation(s) with your Personal Information will depend on the type of your personal data and the context in which it used. We warrant and represent you the following:

• Any processing of your Personal Information will start and continue only when we have the valid legal basis (or bases) for such data processing.
• We will check that the processing is necessary for the relevant purpose, and that there is no other reasonable way to achieve that purpose without processing of your Personal Information.

At least one of these legal grounds will apply when we will process your Personal Information:

(a) yourconsent to collect and process Personal Information;

(b) performance of a contract with you;

(c) our legitimate interests or the legitimate interests of a third party;

(d) the processing is necessary for us to perform a task in the public interest or for our official functions and/or the task or function that has a clear basis in law;

(e) necessity for compliance with our legal obligations;

(f) the processing is necessary to protect someone’s life or vital interests.

8. Disclosure of Your Personal Information

We may disclose your information for certain purposes and in the certain circumstances to the third parties as described below:

(a) The companies of which belong to the same group of companies as Wavix. We will share your Personal Information for the purposes of data proceeding and storage in our corporate group;

(b) Service Providers. We may transfer your personal data to our service provider in order to execute our contract obligations, to carry out any some business activity on our behalf and/or to assist us with the provision of services to you. For example, we may store of some of your Personal Information on the rented servers.

(с) Competent Government Agencies. We may provide your User Owned Data and / or Personal Information under response to the legitimate request from the competent government authorities or agencies (“Government Data Request”).

9. International Transfer of Personal Information

We are an international company and through international nature of our business your Personal Information may be stored and transferred to countries outside of the EEA for the execution of purposes described in this Privacy Policy. In any such case, we will take appropriate measures to ensure that the Personal Information is transferred, processed, and protected in accordance with this Privacy Policy and all applicable data protection and security laws. Your acceptance of this privacy policy constitutes your explicit consent for such data transfer.

10. How Long We Will Keep Your Data?

We will hold and process your Personal Information only for as long as reasonably necessary to carry out the purposes for which it was collected. For example, if you would wish to terminate our services, we will terminate the processing of your Personal Information, unless otherwise provided by law.

11. Children’s Personal Information

We recognize the importance of children's safety and privacy. Our Platform is designed for professional business and for adult individuals only (at the age of 16, or another applicable legal age). If you believe that We store and (or) process Personal Data about children without direct authorization of their parents or legal guardians, you may contact us.

12. Your Privacy Rights

Hereby we notify you that the GDPR or any similar applicable laws provides you with the following rights:

• Right of access. Youhave the right to obtain the detailed information about your Personal Information that we store and process, including the purposes of such data proceeding.
• Right to rectification. You may update or correct the personal information about yourself available with us, which you believe is an inaccurate, incomplete or no longer be relevant.
• Right to erasure (“right to be forgotten”). You have the right, in certain circumstances, to request data deletion concerning your personal data that we hold and process. Please note, that in some cases we may process your personal data even you request the data deletion, where the legal ground or obligation for such proceeding exists. You will be notified of the continuation of such processing and the reasons for its continuation, in the event that we need to continue processing your personal data.
• Right to restriction of processing. You have the right to restrict the processing of your personal data if there is a particular reason for wanting the restriction. This right may be concerned as alternative to the right to be forgotten and can be applied, for example, in the situation when the personal data should not be deleted, but the proceeding of personal data should be paused or limited.
• Right to object. You have the right to object to the storage and (or) processing of your personal information in certain circumstances, for example when the personal data is no longer to be proceeded or if you suspect that the personal data has been unlawfully processed.
• Right to data portability. You may request a copy of your personal data for the view and (or) data transfer purposes and we will provide you with your personal data information in structured and commonly used format. You shall have the right to ask us to transfer such personal data copy to the third party by the direct communication, if this technically possible.
• Right to lodge a complaint. Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority. For example, if you are a British citizen, you can complain to the ICO, if you are a citizen of France, you can complain to the CNIL, if you are a Cypriot, than you may make a compliant to the Office of the Commissioner for Personal Data Protection.
• Right in Relation to Automated Decision-Making and Profiling. You have the right to be free from decisions based solely on automated processing of your Personal Data.

Please note, that this list is provided only for your convenience and better understanding of your rights. This list does not limit your rights granted by the GDPR and/or applicable laws, when applicable data privacy laws provide you with any additional rights.

13. Right to manage marketing letters

You also can prevent or discontinue e-mail marketing communications by utilizing the unsubscribe options in marketing e-mails or manage your consent to the receiving of electronic marketing messages by the account settings. Please note, that withdrawing marketing consent does not mean that we will be prohibited to contact you for important matters like billing, technical notifications and other relevant communications.If you want to realize your personal data privacy rights or if you have some questions about how we process your personal data, please contact us.

14. Security of your personal data

We use appropriate level of technical and organizational measures to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to personal data transmitted, stored or otherwise processed. Nevertheless, we consider ourselves obliged to notify you that the processing and transmission of personal data over the Internet still carries certain risks, but we will take reasonable measures to mitigate them. For example, we will try to implement the commercially reasonable best industry practices to keep the personal data more secure.

15. Links to Other Sites and Informational Platforms

Our Platform may contain links to other sites and information platforms that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website. Wavix does not hold any liability for the information distributed or collected by third-party Platforms. The information practices and the content of such other Platforms are governed by the privacy statements of such other Platforms. We encourage you to review the privacy statements of any such other Platforms to understand their information practices.

16. Cookies Policy

Please read the following notice about the types of cookies and/or other trackers we use for the purposes specified in the Cookies Policy.

16.1.Changes and updates of this Policy

This Policy may be updated from time to time to reflect changing legal, regulatory, technical or operational reasons. We encourage you to periodically check this page for updates.Anyway, we will specially inform you in the case of substantial changes of this Policy, that may seriously affect your rights and interests.We will post the updates of this Privacy Policy on our official Platform available by the following link: https://wavix.com/privacy-and-security. Posting the information on the Platform shall be considered to the equal public sharing or notification of any User of changes made to the Privacy Policy.

17. Contact information

If you have any questions, please contact us at support@wavix.com.