INTRODUCTION
Service QOVVO Privacy Policy, hereinafter referred to as the “Privacy Policy” governs the privacy relations between the User, hereinafter referred to as the “User” or “Creditor” or “Recipient of a financial service” or “you” and the Service QOVVO owned by Network Project Ltd. Ltd. or “Company”, or “QOVVO Service”, or “we”, subsequently called “Parties”, in relation to the processing and protection of the User’s personal data when using the QOVVO Service and is part of a legally binding agreement between you and Network Project Ltd. Ltd., hereinafter referred to as the “Agreement”, regarding the use of the QOVVO Service.
In case of changes in the procedure for providing the QOVVO services, The Privacy Policy is subject to review and adjustments to reflect such changes. Updates to the Privacy Policy will be reflected on the website QOVVO.io at «Privacy Policy» Your use of the Service QOVVO Service after making the relevant changes, will be regarded as acceptance and consent to the updated version of the Privacy Policy.
Unless otherwise stated herein, references are made to the General Terms and Conditions for providing QOVVO Services hereinafter referred to as the “Terms” and all terms used in the Terms.
DEFINITIONS
a) Personal Data: any information about an identifiable natural person, directly or indirectly, by reference to an identifier, in relation to factors specific to that natural person;
b) Privacy Laws: any Applicable Laws protecting personal data;
c) Processing: any operation or set of operations performed on Personal Data or on sets of Personal Data.
INFORMATION
QOVVO Service may collect such Personal Data when you visit the website, complete the registration process and use the QOVVO Service, when you interact with our Service:
1. Information requested from the User:
a) Identification information: full name, identification number, date or country of birth, your photograph, photographs of your identity document (passport, ID card or driver's license), email, statements about your social status or job title, sanctions status;
b) Contact and communication information: permanent and current address, phone number, social media profiles;
c) Employment status: occupation, industry, employment status;
d) Financial information: bank account number, digital asset wallet, source of funds, cryptocurrency source, transaction history;
e) Other information: any information you provide to us at your discretion.
2. Information collected automatically. When you visit the website QOVVO.io , we automatically collect the following information:
a) Your wallet address: we may record the wallet address you use to connect to the Interface.
b) Technical information: information about your device, network, software, information that enables your access to the User Account, your browser type and version, time zone setting, browser extension type and version, operating system and platform, screen resolution, screen height and width. This information helps us optimize the interface for different devices and troubleshoot technical problems;
c) Information about visits to your website: a complete history of your visits, including the date and time of such visits, consent given to the Cookie banner, web page loading errors, access times for different pages, information for interacting with the web page (e.g. clicking, moving the cursor, etc.) and ways to exit the page, the links you click and the search queries you use. By analyzing this data, we gain a deeper understanding of user behavior, which in turn allows us to constantly improve the interface and improve the overall user experience.
In the event that you refuse to provide Personal Data at our request related to compliance with the provisions of Applicable Law or compliance with the Terms of Service, we reserve the right to refuse you the QOVVO.io Service.
USE OF INFORMATION
QOVVO Service may process your Personal Data in accordance with the Applicable Privacy Law and this Privacy Policy for the following purposes:
a) Identification and verification when providing you with services, to confirm your identity;
b) Providing personalized information and customized service offerings;
c) Managing the provision of the Service, fulfilling your wishes, providing information support, sending you technical notices, updates, security alerts, information about changes to our policy, administrative messages, detecting, preventing and resolving fraud, violation of the Terms, aswell as threats or harm, compliance with legal and regulatory requirements;
d) Improving the QOVVO Service we use your Personal Data to analyze the performance, correct errors and improve the usability of our Service;
e) Maintain the quality and security of our services, improve internal quality control, detect and correct errors, analyze service usage metrics (website pages visited, functions used, etc.), as well as for data analysis, auditing, reporting or other purposes;
f) In some cases, we may collect and use your Personal Data to comply with privacy laws and other Applicable Laws and Regulations;g) We use your Personal Data to communicate with you regarding your access to the QOVVO Service and to provide the QOVVO Service;
g) We use your Personal Data to communicate with you regarding your access to the QOVVO Service and to provide the QOVVO Service, as well as to inform you of any changes to our services or our contractual relationship;
h) For the purpose of preventing illegal activities, we may process your Personal Data to monitor and detect incidents affecting the security of our services, including to prevent or stop attacks on our computer systems or networks, our services, including to prevent or stop attacks on our computer systems or networks,
i) protect against malicious, fraudulent or illegal activities, including money laundering, terrorist financing and other criminal activities, complywith applicable laws, lawful requests and legal processes, including responding to subpoenas or requests from government authorities; with applicable laws, lawful requests and legal processes, including responding to subpoenas or requests from government authorities;
j) We may use your Personal Data to send you marketing communications via email or other agreed forms, in order to provide you with relevant information about the products and services of the QOVVO Service.
k) For any other purposes not prohibited by law and related to our business. We may collect and use information for business purposes in accordance with the rules described in this Privacy Policy.
We may collect and use information for business purposes in accordance with the rules described in this Privacy Policy.
SHARING AND DISCLOSURE OF INFORMATION
We may share or disclose information we collect in accordance with the rules described in this Privacy Policy and for the purposes set out in the “Use of Information” section above.
Parties with whom we may share information:
a) Affiliates and/or related entities, including where they act as our service providers;
b) Professional advisers for audit purposes and to comply with our legal obligations;
c) Third party service providers for business purposes, including fraud detection and prevention, security threat detection, data analytics, information technology and storage, and blockchain transaction monitoring. Any information shared with such service providers is subject to the terms of this Privacy Policy. All service providers with whom we collaborate may only use the information on our behalf and in accordance with our instructions.
THIRD PARTY SERVICES, THIRD PARTIES
The QOVVO Service may use technologies operated or controlled by third parties. For example, the Service may include links to websites, platforms and other services that are not operated or controlled by us.
When you interact with third-party services, including when you leave QOVVO Service , such third parties may independently collect information about you and solicit information from you. Information collected and stored by such third parties is subject to their own policies and practices, including what information they share with us. We encourage you to review their privacy policies and terms of use.
We may share your Personal Data with the following categories of third parties:
a) Providers of banking and payment network services that enable you to load funds, make and receive payments and withdraw funds;
b) Providers of risk assessment and fraud detection services, anti-money laundering and counter-terrorist financing services;
c) Online advertising platforms for marketing purposes;
d) Analytics and search engine providers engaged by us to improve and optimize the QOVVO Service;
e) Cloud service providers, who provide us, among other things, with the necessary infrastructure for the secure storage and management of your Personal Data;
f) Auditors, consultants, and similar contractors in connection with consulting services, subject to the necessary confidentiality conditions;
g) Third parties, if necessary, in accordance with legal requirements, to disclose your Personal Data and data on your use of our services, including, but not limited to, competent law enforcement agencies, regulators, courts, police, financial supervisory authorities, tax authorities and social security authorities. Such disclosure is subject to our good faith and is necessary to protect our security, prevent and investigate fraud or respond to a government request.
STORING INFORMATION
The QOVVO Service stores information received from Users for the time necessary to achieve the purposes of collecting such information specified in this Privacy Policy and not inconsistent with the requirements of Applicable Law. We declare that we will store and use this information in specified in this Privacy Policy and not inconsistent with the requirements of Applicable Law. We declare that we will store and use this information in accordance with applicable laws for lawful purposes.
Your Personal Data may be stored for different periods of time, depending on the category of such Personal Data:
a) Some information may be automatically deleted from the purpose of such information. If you have opted out of receiving marketing communications, we will store your email so that we know that you do not want to receive such information;
b) Account information will be stored for the duration of the Agreement, in accordance with industry standards or recommendations, as well as in accordance with our legitimate interests;
c) We may store information about the services provided to Users for the purpose of organizing and maintaining records, preventing fraudulent practices, communicating with Users in the event of complaints and enforcing our legal rights;
d) We may retain some Personal Data to comply with reporting and audit requirements, other legal requirements, including the FATF recommendations and relevant requirements that oblige us to retain Users' personal data for five years after the termination of the contractual relationship and extend such retention periods in limited cases provided for by applicable law.
TRANSFER OF INFORMATION
When transferring Personal Data, in accordance with the rules of privacy legislation and the provisions of this Privacy Policy, we ensure that the recipient of the Personal Data observes security measures for the storage and processing of Personal Data similar to those applied by us in the manner and to the extent provided for in this Privacy Policy.
The processing and storage of your Personal Data may be performed outside your jurisdiction by our service providers. Including: payment processing, data analysis (including fraud prevention and compliance checks), collecting data on the use of our websites and advertising services or identifying your needs for services or products. We take all reasonable steps to ensure that your Personal Data is treated securely in accordancewith this Privacy Policy and applicable local and international laws.
INFORMATION SECURITY
Personal data of Users collected by the QOVVO Service for the purposes and in the manner specified in this Privacy Policy, are stored on secure servers hosted in a cloud environment. In addition, we implement and maintain reasonable administrative, physical and technical security measures designed to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. However, the transmission of information over the Internet is not completely secure, and we cannot guarantee the security of the transmission of information about you.
We provide only limited access to your Personal Data to contractors, agents and other third parties to fulfill their obligations related to the provision of our Service to you. They may process your Personal Data only in accordance with our instructions, subject to confidentiality obligations.
In order to protect your privacy, you undertake to keep your Username and password used to interact with the QOVVO Service in secret.
MARKETING COMMUNICATIONS
QOVVO Service may periodically provide its Users and website visitors who have subscribed to updates, marketing materials and advertising of services. You have the right to refuse such communications at any time.
CHILDREN
The QOVVO Service is not intended for children. In accordance with the provisions of the Terms, in order to receive the Services, you must be legally capable of entering into the Agreement. We do not collect personal information from children. If you are a parent or guardian and believe that we have collected personal information about a person under the age of entering into the Agreement, please contact us at [email protected], and we will delete the relevant information.
CHANGES TO THIS PRIVACY POLICY
We may revise, amend, supplement and publish this Privacy Policy at any time. Any changes will be effective immediately upon our publication of the revised Privacy Policy. Your continued use of the QOVVO Service after such changes have been made and published, and any relevant changes made, will be subject to the terms and conditions of this Privacy Policy.
CONTACT US
If you have any questions or comments about this Privacy Policy, our data processing practices, or our compliance with applicable laws, please contact us at privacy@ qovvo.io.