What this Privacy Notice covers
W1TTY Global Ltd ("W1TTY", "we", "our" or "us") operates a platform accessible through the W1TTY application, which is available for download on your mobile device (the "W1TTY App"), and our website at www.w1tty.com (our "Website"), that allows users to view the balance of, and carry out and manage transactions conducted through their multicurrency electronic account (collectively, the "W1TTY Service").
We offer the W1TTY Service in our capacity as an authorised electronic money institution under the W1TTY Service Terms.In addition, we offer a separate, unregulated concierge service (“W1TTY Concierge”) under a separate set of terms and conditions (“Concierge Terms”).
This Privacy Policy, also called a Privacy Notice (the "Notice"), describes how we use information that identifies or is associated with you (your "personal information") when you interact with us via our Website or otherwise through the W1TTY Service and W1TTY Concierge. It also explains your rights in relation to your personal information and how to contact us or supervisory authorities in the event you have a query or complaint.
This Notice may be changed from time to time. If we change anything important about this Notice (the information we collect, how we use it or why we use it) we will highlight those changes at the top of the Notice and provide a prominent link to it for a reasonable length of time following the change (and, for any important changes to how we use your personal information, prior to the change taking effect).
Who is responsible for your personal information
Your personal information is collected by W1TTY Global Ltd, a company registered in England and Wales under company registration number 12810623. For the purpose of offering the W1TTY Service, W1TTY is authorised by the UK Financial Conduct Authority for the issuance of e-money, having UK FCA firm registration number 932839.
W1TTY Concierge, however, is not a service that is regulated by the FCA and is separate from W1TTY Service.
If you would like to contact us, you can email us at support@w1tty.com.
W1TTY is committed to protecting your privacy. The effective management of all personal information, including its security and confidentiality, lies at the very heart of our business and underpins our practices and processes. We collect, use and are responsible for certain personal information about you. When we do so we are subject to applicable data protection laws (primarily the Data Protection Act 2018) and we are responsible as ‘controller’ of that personal information for the purposes of those laws.
Principles of personal data processing followed by us
We will ensure that your personal data is:
- Processed lawfully, fairly, and in a transparent manner in relation to you;
- Collected for specified, explicit and legitimate purposes (f. e. prevention of money laundering and terrorist financing, performance of Services, etc.), and not further processed in a manner that is incompatible with those purposes;
- Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Accurate and, where necessary, kept up to date;
- Kept in a form which permits your identification for no longer than is necessary for the purposes for which the personal data are processed;
- Processed in a manner that ensures appropriate security of your personal data.
W1TTY follows the above indicated principles strictly during the processing of your personal data and request the same from the data processors which it may use to process personal data on behalf of W1TTY.
What information do we collect and how do we use it
We will collect, store and use your personal information for the purposes set out in more detail in this section.
Your information may be shared with some third parties as set out in more detail below.
Information users of the W1TTY Service and W1TTY Concierge (our "Users") and visitors to our Website provide to us.
We collect most of our personal information directly from our Users and visitors to our Website, by telephone, post or email and/or via our Website or the W1TTY App.
We will indicate to you where the provision of certain personal information is required in order for us to provide you certain features of the W1TTY Service. In certain circumstances, if you do not provide personal information which is required, we will not be able to perform our obligations under the contract with you or may not be able to provide you with our products and/or services.
The following table sets out the categories of personal information that we collect directly from Users and visitors to our Website, how we use them and the legal basis we rely on for doing so:
Information Collected | Purpose of Processing | Legal basis for processing |
Contact details such as your name, address, email and telephone number(s). | We use this information to:
· communicate with you about any queries you may have regarding your access to and use of the W1TTY Service and W1TTY Concierge;
· send you service-related communications;
· administering the W1TTY Service, W1TTY Concierge and addressing user queries | The processing is necessary for our legitimate interests. |
Contact details such as your name, address, email and telephone number(s), and information about your marketing and communication preferences. | We use this information to send you marketing communications. | We will only process your personal information in this way to the extent you give us your consent to do so. |
Contact details such as your name, address, email and telephone number(s). | We use this information to:
(a) set up your account on the W1TTY Service.
(b) Provide you W1TTY Concierge under the Concierge Terms
(c) provide access to and administer the W1TTY Service
We disclose this information to:
(i) our fellow group company, Vipping Limited, of 4, V. Dimech Street, Floriana FRN 1504, Malta (“Vipping”) for the purpose of operating the W1TTY Concierge; and
for the purpose of providing the W1TTY Service:
(i) payment services providers, as well as intermediary services providers;
(ii) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs);
(iii) auditors, legal and financial consultants;
(iv) IT providers;
(v) fraud detection services providers;
(vi) Data processors;
(vii) other related business partners, including but not limited to, suppliers of the W1TTY Concierge | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service and our Concierge Terms).
If you access the W1TTY Service on behalf of a company, the processing is necessary for our and our customer's legitimate interests . |
Identity document data: such as ID Type (Passport / Identity Card / Residence permit), its copy, MRZ, document number, date of issue, date of expiry). | We use this information to:
(a) set up your account on the W1TTY Service.
(b) Provide you W1TTY Concierge under the Concierge Terms
(c) provide access to and administer the W1TTY Service
We disclose this information to our fellow group company, Vipping Limited, of 4, V. Dimech Street, Floriana FRN 1504, Malta (“Vipping”) for the purpose of operating the W1TTY Concierge, and we my disclose this information to: (i) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs); (ii) auditors, legal and financial consultants; (iii) IT providers; (iv) fraud detection services providers; (v) Data processors; (vi) other related business partners, including but not limited to, suppliers of the W1TTY Concierge. | |
Data obtained and/or created while performing legal obligation: such as inquiries, requests, notifications, orders, courts decisions or other data related to the specific Customer(s) which may be received by or provided to the police, courts, investigative bodies, notaries, tax administrator, courts, bailiffs and other institutions | Processing is necessary: (a) for compliance with a legal obligation to which we are subject; and/or (c) for the purposes of the legitimate interests pursued by us or the third party.
In order to provide the W1TTY Service, we my disclose this information to: (i) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs); (ii) auditors, legal and financial consultants; (iii) IT providers; (iv) fraud detection services providers; (v) Data processors; (vi) other related business partners, including but not limited to, suppliers of the W1TTY Concierge.
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Information about Customer‘s occupation and income sources: (i) Specific occupation: paid employee (position) / owner of legal entity (company name) / registered self-employee / unemployed / other; (ii) Main sectors of customer’s occupation, individual or business activity; (iii) Information regarding countries in which customer is employed, carries out individual activity or business: countries, whereas activity or business is conducted or registered in preferential tax zone, percentage of turnover in cash for such activity or business. | We use this information to:
(a) set up your account on the W1TTY Service (account opening, transfers of funds, payment collection and other payment services);
(b) prevention of money laundering and terrorist financing (implementation of the principle "Know Your Customer”);
(c) implementation of international sanctions;
In order to provide the W1TTY Service, we my disclose this information to: (i) payment services providers, as well as intermediary services providers; (ii) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs); (iii) auditors, legal and financial consultants; (iv) IT providers; (v) fraud detection services providers; (vi) Data processors; (vii) other related business partners, including but not limited to, suppliers of the W1TTY Concierge. | |
Payment account opening information: such as (i) Purpose for account opening; (ii) Source of Customer’s income and wealth; (iii)Services which the Customer plans to use; (iv) Monthly planned account turnover in GBP; (vi) Number of transactions and countries from which the funds will be received or transferred; (vii) Account number; | We use this information to:
(a) set up your account on the W1TTY Service (account opening, transfers of funds, payment collection and other payment services);
(b) prevention of money laundering and terrorist financing (implementation of the principle "Know Your Customer”);
(c) implementation of international sanctions;
In order to provide the W1TTY Service, we my disclose this information to: (i) payment services providers, as well as intermediary services providers; (ii) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs); (iii) auditors, legal and financial consultants; (iv) IT providers; (v) fraud detection services providers; (vi) Data processors; (vii) other related business partners, including but not limited to, suppliers of the W1TTY Concierge. | |
Financial data: such as (i) related payment card (i.e. currency, card number, validity date, card owner’s name and surname, CVV/CVV2); (ii) Customer’s account information (e.g., services, transactions type, sender, recipient, amount, purpose, extracts, etc.) (iii) information about accounts in other financial institutions (i.e. name of institution, country, account number); (iv)Customer’s creditworthiness information (i.e. creditors, type of debt and its amount, due dates, debtor’s identification number, etc.). | We use this information to:
(a) set up your account on the W1TTY Service.
(b) Provide you W1TTY Concierge under the Concierge Terms
We may disclose this information to our fellow group company, Vipping Limited, of 4, V. Dimech Street, Floriana FRN 1504, Malta (“Vipping”) for the purpose of operating the W1TTY Concierge; and
in order to provide the W1TTY Service, we my disclose this information to: (i) payment services providers, as well as intermediary services providers; (ii) authorities (i.e. supervising institutions, law enforcement institutions, courts, bailiffs); (iii) auditors, legal and financial consultants; (iv) IT providers; (v) fraud detection services providers; (vi) Data processors; (vii) other related business partners, including but not limited to, suppliers of the W1TTY Concierge. | Lawfulness of personal data processing.
Processing is necessary: (a) for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; (b) for compliance with a legal obligation to which we are subject; and (c) for the purposes of the legitimate interests pursued by us or the third party. |
Sensitive data: such as biometric data. | We process a limited amount of sensitive data when we carry out verification of identity documents that contain biometric data. | |
Details relating to communications between us, such as a note or recording of a telephone call, an email or letter sent, or other records of any contact with us. | If you contact us about your use of the W1TTY Service or W1TTY Concierge, we will use the content of those communications to respond to your queries and comments and to help us administer and improve the W1TTY Service.
We disclose this information to our fellow group company, Vipping for the purpose of operating the W1TTY Concierge Service and providing us with support to answer your queries or complaints. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service and our Concierge Terms).
The processing is necessary for our legitimate interests, namely administering the W1TTY Service, addressing user queries and comments, and to help us improve the W1TTY Service. |
Login information, such as the email and password that you use to set up your account. | We use this information to:
· authenticate you
· allow you to log in to your account on the W1TTY Service and to access W1TTY Concierge; and
· administer the W1TTY Service | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service and our Concierge Terms).
If you access the W1TTY Service on behalf of a company, the processing is necessary for our and our customer's legitimate interests. |
Information about your precise location. | We use this information to confirm if you are in the country you say you are based in when you create a W1TTY account, in order to identify fraud risk.
We disclose this information to our fellow group company, Vipping for the purpose of operating the W1TTY Concierge Service and providing us with support to answer your queries or complaints. | The processing is necessary in order to take steps prior to the performance of a contract (namely our Terms of Service and our Concierge Terms).
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Information about beneficial owners and directors. If we enter into an agreement with a company to provide them with access to the W1TTY Service, we will collect information about that company's beneficial owners and directors, such as their names, the size of their shareholding, their identification documents and the results of any identity checks conducted on them. | We use this information to verify your identity in connection with our anti-money laundering and "Know your Customer" obligations. | The processing is necessary in order to comply with a legal obligation to which we are subject. |
Information that we collect automatically
We also collect the following personal information about you and your use of the W1TTY Service automatically when you use the W1TTY Service:
Category of personal information | How we may use it | Legal basis for the processing |
Approximate location information. Other than information you choose to provide to us, we do not collect information about your precise location. Your device’s IP address may however help us determine an approximate location. | We may use information you provide to us about your location to monitor and detect fraud or suspicious activity in relation to your or a customer's account. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
Information about how you access and use the W1TTY Service. For example, the IP address from which you access the W1TTY Service, how frequently you login and access the W1TTY Service, the time you access the W1TTY Service and how long you use it for. | We may use information about how you use and connect to the W1TTY Service and W1TTY Concierge to present the W1TTY Service and W1TTY Concierge to you on your device. | The processing is necessary for our legitimate interests, namely to provide the W1TTY Service and W1TTY Concierge to the user. |
Information about how you access and use the W1TTY Service. For example, the IP address from which you access the W1TTY Service, how frequently you login and access the W1TTY Service, the time you access the W1TTY Service and how long you use it for. | We may use this information to monitor and detect fraud or suspicious activity in relation to your or a customer's account. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
We use this information to monitor the performance of, and improve the W1TTY Service and W1TTY Concierge and to develop new features of the W1TTY Service and W1TTY Concierge. | We will only use your personal information in this way to the extent you have given us your consent to do so. | |
We use this information to present the W1TTY Service to you on your device in accordance with your screen and window size and your browser settings. | The processing is necessary for our legitimate interests, namely providing you with access to the W1TTY Service. | |
Information about your device that you use to access the W1TTY Service, such as the type of device, operating system, browser, your Internet service provider or mobile network and your IP address. | We use this information to monitor the performance of, and improve the W1TTY Service and W1TTY Concierge and to develop new features of the W1TTY Service and W1TTY Concierge. | We will only use your personal information in this way to the extent you have given us your consent to do so. |
History data: Customer‘s experience using the W1TTY Platform, the register of all Customer‘s actions performed on the Platform (i.e. operations, such as funds transactions, linking cards, log-in and log-out register, register of reset password | We use this information to monitor the performance of, and improve the W1TTY Service and for proper and secure use of the Platform and of Customer’s online account. | Processing is necessary for the purposes of the legitimate interests pursued by us or the third party. |
Cookies and other trackers
The Website uses cookies and similar tracking technologies to collect information about your use of the Website and distinguish you from other users of the Website. Cookies are pieces of code that we transfer to your computer's hard disk to store or collect information.
We use these technologies to provide certain functionalities of the Website, such as the customer support chat functionality, as well as to collect information about how you access and use the Website.
For information about the cookies and similar trackers that we use on the Website, please refer to our Cookie Policy.
The W1TTY App also uses a mobile SDK for a similar purpose. Mobile SDKs are software packages that can be incorporated into mobile apps to deploy certain functionalities or collect information about how the application is used.
We use a mobile SDK provided by Mixpanel, Inc. to collect information about how users interact with the W1TTY App, such as the pages you view on the W1TTY App, how long you view them for, how frequently you log in to the W1TTY App and information about the device you use to do so. We use this information to monitor the performance of the W1TTY App, and to identify errors and improvements for the W1TTY App.
Other than cookies, Mobile SDKs and similar technologies that are required to operate the W1TTY Service and W1TTY Concierge, we will only use place cookies on your device or otherwise use these technologies to collect data from your device with your consent.
If you would like to withdraw your consent to non-essential cookies, you can do this by clicking on the floating cookie icon on the Website and updating your preferences. If you would like to withdraw your consent to the use of the Mixpanel mobile SDK, you can do so on the "About Us" page in your profile on the W1TTY App.
You also have the ability to opt out of all cookies by disabling cookies in your browser or mobile settings. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of the W1TTY Service and W1TTY Concierge. These settings will typically be found in the "options" or "preferences" menu of your browser. Please access the links below for information about how to do this on popular browsers and operating systems, otherwise you should use the "Help" option in your browser for more details:
(a) Cookie settings in Internet Explorer
(b) Cookie settings in Firefox
(d) Cookie settings in Safari web and iOS.
You can also opt out of data collection through Mobile SDKs using your device settings:
(a) for iPhone and iPad users: in your device's settings access the Privacy > Analytics & Improvements tab, and toggle "Share With App Developers".
(b) for Android users: on your device's settings access the Privacy tab, and toggle "Send diagnostic data".
How long do we keep your information?
We will keep your information for a period of years from the date you close your W1TTY account and withdraw the balance of your W1TTY account, unless we are required to retain it for longer to comply with applicable law or if we believe your personal information may be necessary to deal with a complaint, investigation, dispute or legal claim.
We aim to keep your personal data that we hold up-to-date, so please advise them of any changes by e-mailing support@w1tty.com and dpo-uk@w1tty.com. You must notify us by emailing support@w1tty.com and dpo-uk@w1tty.com within days if any of any change in your name, residential address, telephone number, e-mail address, or referees' address, and any other details that we may reasonably consider to be material to our dealings with you. We will also routinely refresh our information. When it is no longer necessary to retain your personal information, we will delete or anonymise it.
Recipients of personal information
We only allow third parties to handle your personal information if we are satisfied that they take appropriate measures to protect your personal information.
Marketing consent
We will only send marketing communications to you if you actively opt-in to receive them, either via agreeing to push notifications in the W1TTY App, and/or by consenting to marketing through non-App based channels (during the application process or any time thereafter). Non-App based channels include email, telephone, post and direct messages online (e.g. through social media).
You can withdraw your consent to receive such marketing communications at any time by changing your W1TTY App settings for push notifications, and/or by clicking on the unsubscribe link at the bottom of each marketing communication sent through non-App based channels.
Where your information will be held
The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third party service providers have operations, including countries outside of the UK or EEA. These international transfers of your personal information will be made pursuant to appropriate safeguards, including:
(a) ensuring that the personal data is transferred to countries recognized by the European Commission or the UK Secretary of State (as applicable) as offering an equivalent level of protection; or
(b) implementing appropriate contractual safeguards, including Standard Contractual Clauses approved by the European Commission and the UK Information Commissioner's Office.
We will take appropriate steps to ensure that your personal information is treated securely and in accordance with applicable law and this privacy policy regardless of where it is processed.
If you wish to enquire further about the safeguards we use, please contact us using the details set out at the beginning of this privacy policy.
Keeping your personal information secure
We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed unlawfully.
Your Rights
Your rights under the Data Protection Act 2018 and how to exercise them are explained in the table in Annex A to this Privacy Policy.
This Privacy Policy itself provides confirmation of the details required in relation to your ‘right of access’.
Links to third party website
Our Website, our W1TTY App, our products and/or services and other communications may, from time to time, contain links to third party websites.
The personal data that you provide through these websites is not subject to this Notice. If you follow a link to any of these websites, please note that these websites have their own privacy policies / notices which will set out how your information is collected and processed when visiting those sites.
Children
Our Website and App are not aimed at children under the age of 18. If you are under 18 years old, you should not submit any personal information to us via our Website or our W1TTY App without checking with your parent or guardian.
Annex A
Your Rights
Your Rights and How to Exercise Them | Exceptions |
Right of Access: To obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: (a) the purposes of the processing; (b) the categories of personal data concerned; (c) the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) of the GDPR and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
How to exercise:
This Privacy Policy provides confirmation of the details required in relation to your right of access.
Under the DPA, you have a right to access certain personal records that we hold about you. Any access request may be subject to a fee to meet our costs (as the case may be) in providing you with details of the information they hold about you if the request is unfounded or excessive. You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
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Right to rectification: to obtain from us without undue delay the rectification of inaccurate personal data concerning you.
We must communication to each recipient to whom the rectified personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
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Right to erasure: to obtain from us the erasure of personal data concerning you without undue delay where:
(a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
(c) you object to the processing based on legitimate interest where there are no overriding legitimate grounds for the processing;
(d) the personal data have been unlawfully processed;
(e) the personal data have to be erased for compliance with a legal obligation to which we are subject.
We must communication to each recipient to whom the erased personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
| Processing is necessary for
(b) compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; or
(e) the establishment, exercise or defence of legal claims. |
Right to request the restriction of processing concerning you where:
(a) the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;
(b) the processing is unlawful and you oppose the erasure of the personal data and request the restriction of its use instead;
(c) we no longer need the personal data for the purposes of the processing, but it is required by you for the establishment, exercise or defence of legal claims;
(d) you object to the processing based on legitimate interest pending the verification whether our legitimate grounds override yours.
We must communication to each recipient to whom the restricted personal data have been disclosed, unless this proves impossible or involves disproportionate effort.
We shall inform the data subject about those recipients if the data subject requests it.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
| Where processing has been restricted under this right, such personal data shall, with the exception of storage, only be processed:
(a) with your consent; or
(b) for the establishment, exercise or defence of legal claims; or
(c) for the protection of the rights of another natural or legal person; or
(d) for reasons of important public interest of the Union or of a Member State.
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The right to data portability: to receive the personal data concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from us, where:
(a) the processing is based on consent or is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract; and
(b) the processing is carried out by automated means.
You have the right to have the personal data transmitted directly from us to another controller, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to the right to erasure.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
| That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.
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The right to object to processing: to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on processing necessary for the purposes of the legitimate interests pursued by us or a third party (except where such interests are overridden by your interests or fundamental rights and freedoms which require protection of personal data), including profiling.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com.
| Where:
(a) we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject; or
(b) for the establishment, exercise or defence of legal claims.
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The right to ask us not to process your personal data for direct marketing purposes: to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing.
You have the right to ask us not to process your personal data for marketing purposes. Each of we will usually inform you (before collecting your data) if it intends to use your data for such purposes or if it intends to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms used to collect your data.
You can also exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com. | |
The right not to be subject to automated individual decision-making, including profiling: to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.
You can exercise the right at any time by contacting us at support@w1tty.com and dpo-uk@w1tty.com. | If the decision:
(a) is necessary for entering into, or performance of, a contract between you and us;
(b) is authorised by Union or Member State law to which we are subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests; or
(c) is based on the data subject's explicit consent.
In the cases referred to in points (a) and (c) we shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on our part, to express his or her point of view and to contest the decision.
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