WOLI PRIVACY POLICY
Data privacy is of high importance for WOLI and we want to be open and transparent with our processing of your personal data. We therefore have a policy setting out how your personal data will be processed and protected. This Policy applies to the adult users of Woli Services, i.e. to the Parents that hold a Parent Account and the children that have turned 18 years old and have accepted to be bound by this Privacy Policy as adult users of a Child Account and a Woli Card.
To the extent that the underage users of the Woli Services have reached the age provided in the law and they can lawfully grant their consent to the processing of their personal data, some of the provisions of this Policy apply also to them.
Who is the controller of your personal data?
The company “WOLI SERVICES LTD” (hereinafter referred to as “WOLI“) is the controller of your personal data under applicable law.
- Address: Mnasiadou & Strasikratous 10 ELMA HOUSE, 2nd Floor,
- 1065, Nicosia Cyprus
- company registration number HE411043
- VAT number 10411043W
- contact e-mail for personal data issues: dpo@woli.io
WOLI is entitled to offer services in the European Economic Area (which includes the EU countries as well as Norway, Iceland and Liechtenstein), except for Malta, Germany and Austria as an E-money Distributor of UAB Payrnet (“Payrnet”).
Payrnet is a company incorporated in the Republic of Lithuania (company number: 305264430) with its head office at AltSpace, Islandijos str. 6, LT-01117, Vilnius, the Republic of Lithuania and its registered office at Girulių str. 20, LT-12123 Vilnius, the Republic of Lithuania, which is authorised by the Bank of Lithuania under the Law on Electronic Money and Electronic Money Institutions (license reference 72, issued on 2020-08-28) for the issuing of electronic money and provision of the related payment services.
Please note that Payrnet and WOLI are both controllers of your personal data relating to your creation and use of your Woli Account and Woli Cards. More specifically, WOLI discloses or may disclose to Payrnet your and your child’s name, address, date of birth, address, citizenship, identification document numbers (such as passport), photographs or videos used to identify you, your family status and information related to transactions made through a Woli Account and or Card. Please note that Payrnet will process this information according to its own Privacy Policy.
Where do we store your data?
Unless otherwise provided in this Privacy Notice, the data we collect from you is stored within the European Economic Area. However, please note that we may transfer your personal data to collaborating companies which are based in the UK. We note that for the time being, the transfer of personal data to UK is permitted under the EU-UK Trade and Cooperation Agreement (“EU-UK TCA”). If the right to transfer data to UK under the EU-UK TCA is withdrawn or expires without an “adequacy decision” being made by the European Commission regarding such data transfers to UK, we will take all necessary measures in order to ensure that any transfers made will comply with the provisions of EU Regulation 679/2016 (GDPR).
Your rights
Right to access:
You have the right to request information about the personal data we hold on you at any time. For this purpose, you can send us an e-mail to dpo@woli.io
Right to portability:
Whenever WOLI processes your personal data by automated means based on your consent or based on an agreement, you have the right to get a copy of your data on a structured, commonly used and machine-readable format. You can also request to have your data transferred to a third person. This only includes the personal data you have submitted to us. In order to exercise the above right you can send us an e-mail at dpo@woli.io
Right to rectification:
You have the right to request rectification of your personal data if the information is incorrect, including the right to have incomplete personal data completed.
If you have a WOLI account, you can edit your personal data under your account.
You can also send us an e-mail at dpo@woli.io
Right to erasure:
You have the right to ask for your personal data, which are processed by WOLI, to be eased at any time, especially when:
- Your personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed
- The processing of your data is based on your consent and you withdraw that consent
- Your data have been illegally processed.
The above right does not exist in particular where:
- The processing of your data is necessary to establish, exercise or defend legal rights
- The processing of your data is necessary to comply with a legal obligation of WOLI that requires processing.
In any case, we will notify you whether or not your claim is satisfied and, in the event of non-satisfaction, the reasons involved in it.
In order to exercise the above right you can send us an e-mail at dpo@woli.io
Right to object:
You have the right to object to the processing of your personal data which is based on legitimate interest of WOLI. In that case, we will not continue to process the personal data unless we can demonstrate compelling and legitimate grounds for the processing which overrides your interest and rights or to establish, exercise or defend legal rights.
In order to exercise the above right you can send us an e-mail at dpo@woli.io
Right to object to direct marketing:
You have the right to object to the processing of your personal data for direct marketing purposes.
You can state your preference by the following means:
- following the instruction in each marketing e-mail
- sending an e-mail to dpo@woli.io
Right to restriction:
You have the right to request the restriction of processing of your personal data under the following circumstances:
- If you question the accuracy of your personal data and until WOLI verifies their accuracy.
- If processing of your data is unlawful and you object to their erasure by asking instead restriction of their use.
- If WOLI no longer needs your personal data for the purpose of processing, but the data is necessary to establish, exercise or defend legal rights
- If you object to the processing of your data by WOLI which is based on legitimate interest of the latter and until the existence of WOLI’s legitimate grounds overriding your freedoms or rights has been verified.
In order to exercise the above right you can send us an e-mail at dpo@woli.io
Right to lodge a complaint with the competent data protection authority:
If you consider WOLI to process your personal data in an incorrect way, you can contact us at dpo@woli.io. You may also lodge a complaint with the Commissioner for personal data protection in Cyprus or any other competent supervisory authority.
Updates to our Privacy Notice:
We may need to update our Privacy Policy. The latest version of the Privacy Policy is always available in our app.
Permission for us to process your Children’s personal information
To provide services under WOLI Terms and Conditions we need to collect information from you, about your Children for whom you wish a WOLI Account to be created and a WOLI Card to be used.
We have a specific Privacy Statement for Children which you should ask them to read and help them understand. It is particularly important for children who are allowed by privacy and data protection laws to give their own consent for their personal data to be processed. This varies between EU countries from children aged 13 or over to children aged 16 or over, inclusive of all ages in between. In some limited circumstances, where allowed by law, we may ask children in these age ranges for some of their personal information and for their consent to our use of it.
By entering into WOLI Terms and Conditions, you are giving us permission to gather, process and store your Children’s personal information for the purpose of providing our services to you and them.
When your child turns 18 years old, we will ask from him/her to accept this Privacy Policy and to give his/her consent (to the extent required by law) in order to continue to provide to him/her with services related to his/her Child Account and Woli Card. If your child does not accept this Policy nor grants any required consent, we will not be able to continue to provide our services related to him/her. In this case, we will delete his/her Child Account and deactivate any WOLI Card linked to it. We will also proceed to the deletion of his/her personal data in the time periods provided below (in the Section related to the Provision of Services related to the WOLI Account and the WOLI Card).
We note that if the child accepts this Privacy Policy, his/her Child Account will not be turned into a Parent Account. On the contrary the Child Account will continue to function in the same way as when your child was underage and you will continue to have the same rights related to the monitoring of your child’s activity as before. Your child will be asked to provide his/her consent to such monitoring.
CREATION OF WOLI ACCOUNT, ORDERING AND DELIVERY OF WOLI CARDS AND PROVISOIN OF SERVICES RELATED TO THE WOLI ACCOUNT AND THE WOLI CARD
Why do we use your personal data?
We will process your personal data in order to proceed to the creation of your accounts to be held by Woli, to ask for the issuance and deliver to you the Woli Cards that you have requested, in order to provide you with services related to the Woli Cards and Accounts, and issue the necessary invoices and other tax related documents for the services provided to you.
Your personal data is being used to identify you, to confirm your personal details, to verify that you are at least 18 years old, to confirm your relationship with your child for whom you may request the opening of a child account and with your spouse who may register as a Secondary Parent, to verify the age of your child.
What types of personal data do we process?
We will process the following categories of personal data:
* name, surname, date of birth, nationality/citizenship, ID or passport details, photo and a video
*Contact data such as but not limited to your residence address, working address, phone number, email
* Data concerning your family situation and your relationship with your children and spouse, name, surname, date of birth, nationality/citizenship, ID/passport details, address, e-mail, phone number, of your children that hold an account with us, photo of your child (if this information is shared with us)
* your Woli and your child’s username & password
* Financial data, such as TIN (if required for the issuance of invoices or other tax related purposes), the token of your debit or credit card that you use in order to load your Parent Account held with WOLI (this information can be saved in your Parent Account if you decide to do so)
* Financial/Transactional data such as how you use our service, transactional data (frequency, locations, recipients, transaction amount, currency, number, location, date and time, id of sender ledger and id of receiver ledger)
* your IP and connection details
* Information obtained when you use some of the app’s functionalities (description of daily tasks, amount allocated per task, performance of the task by the child, number of tasks per month by the child, number of tasks assigned by the parent per month, participation and performance in quizzes, number of attempts per quiz, videos provided through the app that you and/or the child access, viewing / streaming duration, email of friends for referrals, telephones of family members that use the app chat)
Who has access to your personal data?
As already mentioned, WOLI is obliged to disclose your personal data to PayrNet. WOLI and PayrNet UAB will process your personal data as independent controllers. You can find more information with respect to the processing of your personal data by PayrNet UAB in its Privacy Policy. We may also disclose your personal data to Railsbank Technology Ltd which acts as technology provider. Railsbank will process your personal data as an independent controller in accordance with its privacy policy, a copy of which can be found at the following weblink: https://www.railsbank.com/privacypolicy
Please note that we bear no responsibility for the processing of your personal data made by entities which act as (independent) controllers.
Additionally, we disclose your personal data to third companies which provide to us ID and address verification services, to our partners that provide to us clearing and other relevant services, to our accountants, auditors and tax advisors and to the competent tax authorities (which act as independent controllers). We may disclose your data to courier companies to the extent required in order to deliver the WOLI Card to you.
What is the legal basis for processing your personal data?
The processing of your personal data is necessary in order for WOLI to fulfil its obligations for the provision of e-money related services to you under the agreement that is being concluded between you and WOLI when you ask for the creation of a WOLI account. The processing of your personal data made for the issuance of invoices or other tax related documents is based on our obligation to comply with the applicable tax legislation. The processing of your child’s photo is based on your consent and in case your child can provide a valid consent, in your child’s consent.
The processing of the information obtained when you or your child use some of the functionalities of the app such as the chat, the quizzes and the daily tasks/operations functionality, is based on the legal contract which is concluded between us when you choose to purchase the WOLI package that gives access to these functionalities.
How long do we save your data?
We will keep your personal data for as long as you maintain a WOLI account. After the deletion of your account, we will keep for 8 years the information that we are obliged to keep for regulatory purposes (such as your name, surname, nationality, ID/passport details, address details, contact information, information to your income and family status and information on the transactions made through your WOLI account and card). Your personal data required for tax related matters will be kept for 10 years, unless otherwise provided in the applicable legislation.
Information related to your behaviour as a user, including information obtained when you or your child use some of the functionalities of the WOLI app, which we are not obliged to keep for regulatory or other legal reasons will be deleted 3 years after the deletion of your account.
Please note that in case you have not used your Parent Account and any Child Account and/or WOLI Card for more than 3 years, we will consider that you are an inactive user and we will proceed to the deletion of your account and of any information that we are not obliged to keep for regulatory or other legal purposes.
REGISTRATION AND VIEWING RIGHTS OF SECONDARY PARENT
This Section applies only to Secondary Parents (as the term is defined in WOLI Terms and Conditions)
Why do we use your personal data?
We will process your personal data in order to proceed to provide you with viewing rights in the Woli Service according to WOLI Terms and Conditions.
Your personal data is being used to identify you and to confirm your relationship with the Parent who is the holder of the WOLI Parent Account.
What types of personal data do we process?
We will process the following categories of personal data:
* name, surname, date of birth, nationality/citizenship, ID or passport details,
* Data concerning your family situation and your relationship with your children and spouse
Who has access to your personal data?
We may disclose your personal data to PayrNet UAB which will process your personal data as independent controller. You can find more information with respect to the processing of your personal data by PayrNet UAB in its Privacy Policy.
What is the legal basis for processing your personal data?
The processing of your personal data is necessary in order for WOLI to fulfil its obligations under the agreement that is being concluded between you and WOLI when you ask for your registration as a Secondary Parent.
How long do we save your data?
We will keep your personal data for as long as you are a registered Secondary Parent. After the deletion of the account in which you as a Secondary Parent have viewing rights, we will keep for 8 years the information that we are obliged to keep for regulatory purposes (such as your name, surname, nationality, ID/passport details, address details, contact information, information to your income and family status).
Information related to your behaviour as a user which we are not obliged to keep for regulatory or other legal reasons will be deleted 3 years after the deletion of your account.
COMPLIANCE WITH AML OBLIGATIONS
Why do we use your personal data?
The services provided to you by WOLI constitute e-money related services and WOLI acts as distributor of PayrNet UAB. WOLI and PayrNet UAB are obliged to conduct a series of checks and controls in order to confirm that you are not using their services for the purposes of money laundering or terrorist financing. In this context WOLI and PayrNet UAB are obliged to verify your identity, your address and information related to your source of income.
What types of personal data do we collect?
We will process your:
* name, surname, date of birth, nationality/citizenship, ID or passport details, photo and a video *Contact data such as but not limited to your residence address, working address, mobile phone, email
* Data concerning your family situation and your relationship with your children and spouse
* Financial/Transactional data such as how you use our service, transactional data (frequency, locations, recipients, transaction amount, currency, number, location, date and time, id of sender ledger and id of receiver ledger)
* Data concerning your financial situation, tax certificate, data related to your profession and salary/income
Who has access to your personal data?
Your personal data is forwarded to PayrNet UAB which acts as an independent controller, to collaborating companies which provide to us ID and address verification services as well as services related to AML checks (on PEP, sanctions lists etc). Your personal data may be disclosed to the competent authorities if this is required in order for us and/or PayrNet UAB to comply with the applicable legislation (i.e. mainly with obligations regarding reporting of suspicious transactions). Please note that the competent authorities will process your personal data as independent controllers.
What is the legal basis for processing your personal data?
The processing of your personal data for your account is based on our obligation to comply with AML legislation.
How long do we save your data?
We will keep your personal data for 8 years following the termination of our relationship, unless we are obliged to maintain your personal data for a longer period in order to comply with the AML legislation.
DIRECT MARKETING
Why do we use your personal data?
We will process your personal data to send you newsletters and marketing offers via e-mail and/or phone calls.
In order to optimise your experience as a WOLI user, we will provide you with relevant information and send you offers.
What types of personal data do we process?
We will process following categories of personal data:
- contact information, such as e-mail address and/or telephone number
- name
Who has access to your personal data?
Your personal data that is forwarded to third parties is only used to provide you with the services mentioned above. As a result, recipients of your personal data may be media agencies and technical suppliers for distribution of promotional messaging.
We never pass on, sell or swap your personal data for marketing purposes to third parties.
What is the legal basis for processing your personal data?
The processing of your personal data is based on your consent.
Right to withdraw your consent:
You have the right to withdraw your consent at any time by sending an e-mail to dpo@woli.io, and the right to object to the use of your personal data for direct marketing purposes.
When you do so, WOLI won’t be able to send you any further direct marketing offers or information based on your consent.
You can opt out from direct marketing by the following means:
- following the instruction in each marketing e-mail
- sending an e-mail to dpo@woli.io
How long do we save your data?
We will retain your personal data for direct marketing purposes until you withdraw your consent or object to the use of your personal data for direct marketing purposes.
CUSTOMER SERVICE
Why do we use your personal data?
We will process your personal data to manage queries, to handle complaints, enquiries, and technical support matters.
We may also contact you if there is a problem with your card and/or your account.
What types of personal data do we process?
We will process any data you provide to us, including the following categories:
* contact information such as name and surname, address, e-mail address and telephone number
* transactions history and information on payments
* all correspondence relating to the matter in question and the personal data contained therein
Who has access to your personal data?
Your personal data is forwarded to third parties, such as technology providers and other cooperating companies, only if necessary in order to handle your requests and/or your complaints. Also, we may share your data with our legal advisors if required in order to handle complaints or requests.
What is the legal basis for processing your personal data?
The processing of your personal data is based on our agreement when your request / complaint is related to it. Otherwise, it is based on our legitimate interest to provide to you satisfactory services.
How long do we keep your personal data?
We will keep your personal data for five years from the final settlement of the request, enquiry, complaint, query or other matter.
PREVENTION OF MISUSE AND CRIME
Why do we use your personal data?
We will use your personal data to detect, prevent and deal with misuse of our services and to prevent and investigate cases of fraud and/or other criminal acts.
What types of personal data do we process?
We will process following categories of personal data as an example
* contact information such as name, address, telephone number and e-mail address
* financial data, data related to your profession and salary/income
* information on the transactions made via WOLI cards
Who has access to your personal data?
Your personal data is forwarded to third parties only for purposes mentioned above.
We may share your personal data with insurance companies, legal authorities and consultants, law enforcement authorities to complete investigations. Some or all of the above recipients may have an independent right or obligation to process your personal data acting in that case as controllers.
What is the legal basis for processing your personal data?
The processing of your personal data to prevent misuse of our services is based on our legitimate interest.
How long do we keep your personal data?
We will keep your data for the time we need to prevent and/or report potential fraud and other offences.
This Policy is effective as of May 2021.
