References in this Policy to “Cwallet”, “we”, “our” or “us”, are to UAB Amonra Limited, a private company incorporated in the special administrative region of Hong Kong, having its registered address at Room 1318-19, Hollywood Business Center, No.610, Nathan Road, Kowloon City, Kowloon District, Hong Kong, and references to “user”, “customer”, “you” or “your” are to the person who is a visitor or a user of:
- i. The platform is accessible via mobile or desktop device-based applications ("Applications"), the website https://cwallet.com/, and/or through the interface of the automated bot software (collectively, “Platform”);
- ii. Applications for mobile phones, tablets, desktop, or other devices that provide you access to the Platform’s functionality;
- iii. The automated bot software providing you access to the Platform’s functionality without using the graphic user interface, but rather by communicating with the Platform through pre-defined commands (“Bot Software”);
- iv. Our website https://cwallet.com/ (“Website”) serves both as a point of access to our Platform and our informational website describing our Platform, our products, services, and projects.
In this Policy, we may refer to collectively the Platform, Applications, the Bot Software, the Website as the “Software”.
IF YOU DO NOT AGREE WITH THIS POLICY PLEASE LEAVE THE PLATFORM, UNINSTALL MOBILE OR DESKTOP APPLICATIONS, DISABLE YOUR ACCESS TO THE BOT SOFTWARE OR CEASE USING OUR SERVICES IMMEDIATELY.
a. We will act as a data controller about personal information about you that may be either provided by you or collected by us.
b. As a data controller, we will solely determine the purposes and means of the processing of your personal information.
a. In Section 2 we have set out:
- i. the general categories of personal information that we may process;
- ii. the purposes for which we may process personal information; and
- iii. the legal basis of the processing.
b. We may process information about your use of our Platform and Applications (“usage data”). The usage data may include:
- i. your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views and navigation paths, as well as information about the timing, frequency, and pattern of your service use;
- ii. your device number, device id or unique identifier, device type, and unique device token, operating system, and applications used, application crash-data, application version, device identifiers such as IDFA (Identifier For Advertisers), Android ID (Android device), referrer URL (Playstore), Google Advertiser ID, device model;
- iii. cookies, local storage files.
The source of the usage data is our analytics tracking system and your usage of the Platform and the Software. This usage data may be processed to analyzing the use of the Platform, Applications, Software, and our services. The legal basis for this processing is your consent and our legitimate interest, namely monitoring and improving the Platform, Applications, and our services.
c. We may process your account data (“account data”). The account data may include your nickname, email address, your phone number, and, in case you registered by authorizing through Telegram, Twitter, Reddit, or Discord, your corresponding account identifier within these platforms and/or messengers.
The source of the account data is you. The account data may be processed to provide you access to the Platform, Software, and our services, ensuring the security of the Platform, Software, and our services, maintaining back-ups of our databases, and communicating with you. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.
d. We may process information contained in any inquiry you submit to us regarding the Platform, Software, and/or our services (“inquiry data”). The inquiry data may be processed to respond to your inquiry, offering, marketing, and selling relevant services to you. The legal basis for this processing is a performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement and our legitimate interest.
e. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your nickname, your contact details, and information contained in communications between us and you.
The source of the customer relationship data is you. The customer relationship data may be processed to manage our relationships with customers, communicating with customers, keeping records of those communications, and promoting our products and services to customers. The legal basis for this processing is our legitimate interest, namely the proper management of our customer relationships.
f. We may process information relating to transactions, including using our services, that you enter into with us or instructing us and/or through the Platform (“transaction data”). The transaction data may include your contact details and the transaction details.
The transaction data may be processed to supply you services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interest, namely the proper administration of our Platform and business.
g. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our Software or the Website may generate the metadata associated with communications made by using contact forms.
The correspondence data may be processed to communicate with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of the Platform, our services, and business and communications with users.
h. We may process your transactions information when you interact with technically supported decentralized swaps and liquidity protocols (“interaction data”). This data may include your swap transactions, swap requests, contributing your crypto assets to liquidity pools, and other details of your interaction with such decentralized protocols.
The source of this data is your account on the Platform. This data may be processed to provide relevant services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
i. We may process information when we verify your identity (“verification data”). This verification data may include your name, address, telephone number, e-mail address, date of birth, national identification number, government identification documents, and, if applicable, information regarding your bank account (such as the name of the bank, the account type and account number).
The source of this data is you. This data may be processed for identity verification and the detection of money laundering, terrorist financing, fraud, or any other financial crime, and/or perform our obligations to verify the identity of our customers. The legal basis for this processing is the compliance with our legal obligation, the protection, and assertion of our legal rights, your legal rights and the legal rights of others, the performance of a contract between you and us, and/or taking steps, at your request, to enter into such a contract.
j. We may process any of your personal information identified in this policy where necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interest, namely the protection and assertion of our legal rights, your legal rights, and the legal rights of others.
k. We may process any of your personal information identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interest, namely the proper protection of our business against risks.
l. In addition to the specific purposes for which we may process your personal information set out in this Section 2, we may also process any of your personal information where such processing is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person.
m. Please do not supply any other person's personal information to us, unless we prompt you to do so.
a. We may disclose your personal information to our affiliates, our contractors, and our service providers insofar as reasonably necessary for the purposes, and on the legal basis, set out in this Policy.
b. We may disclose your personal information to our insurers and/or professional advisers insofar as reasonably necessary for obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise, or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedure.
c. In addition to the specific disclosures of personal information set out in this Section 3, we may disclose your personal information where such disclosure is necessary for compliance with a legal obligation to which we are subject, or to protect your vital interests or the vital interests of another natural person. We may also disclose your personal information where such disclosure is necessary for the establishment, exercise, or defense of legal claims, whether in court proceedings or an administrative or out-of-court procedure.
d. If we are required by the applicable law (for example, you are a resident of the EEA zone or Switzerland) and your personal information is to be transferred outside our country of incorporation (Hong Kong) and/or the EEA zone or Switzerland, we will ensure an adequate level of protection by any of the recognized methods of transfer, including but not limited to entry into the standard contractual clauses for the transfer of personal information to processors established in third countries.
b. Cookies make it easier for you to use our Platform during future visits. They also allow us to monitor traffic and personalize the content of our Platform for you. Session-based cookies only last while your browser is open, and are automatically deleted when you close the browser. Persistent cookies last until you or your browser deletes them or until they expire.
c. Some of our cookies are necessary for certain uses of the Platform. These cookies allow us to make our Platform usable by enabling basic functions like page navigation. The Platform may not function properly without these cookies.
d. We may also use functional cookies and cookies from third parties for analysis and marketing purposes. Functional cookies enable certain parts of the Platform to work properly and your user preferences to remain known. Analytics cookies, among other things, collect information on how visitors use our Platform, the content and products that users view most frequently, and the effectiveness of our third-party advertising.
g. We use the following third-party services to monitor and analyze web traffic and user behavior:
- iii. Amplitude. Amplitude is a cloud-based product analytics platform. Amplitude utilizes the data collected to track and examine user behavior and prepare reports on how our users use the Platform and services. The service is subject to Amplitude’s Privacy Notice: https://amplitude.com/privacy
- While we do our best to keep this list updated, please note that third parties who place cookies on your device may change from time to time, and there may be a slight delay updating the list.
- Internet Explorer
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
For other browsers, please consult the documentation that your browser manufacturer provides.
You can opt out of interest-based targeting provided by participating ad servers through the Digital Advertising Alliance. Please consult http://www.aboutads.info/ for more information.
5. Local Storage
b. You can clear local storage files from your browser by taking the following actions:
- i. In Firefox, localStorage is cleared when the following conditions are met: (a) user clears recent history, (b) cookies are selected to be cleared, and (c) time range is “Everything”;
- ii. In Chrome, localStorage is cleared when the following conditions are met: (a) clear browsing data, (b) "Cookies and other site data" is selected, and (c) timeframe is "from the beginning of time." In Chrome, it is also now possible to delete localStorage for one specific site;
- iii. In Internet Explorer, to clear localStorage: (a) click on Tools--Internet Options, (b) General tab, (c) delete browsing history on exit, (d) ensure “Cookies and website data” (or “temporary internet files and website files”) is selected, and (e) consider unchecking "Preserve Favorites website data" at the top;
- iv. In Safari, to clear localStorage: (a) click Safari, (b) then click preferences, (c) select the Privacy tab, (d) click Remove all website data and (e) click Remove Now.
6. General Processing
a. Our processing means any operation or set of operations which is performed on personal information, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction, support, maintenance, etc. We do not make automated decisions, including profiling.
b. Your personal information is stored on cloud services provided by Amazon. Amazon Privacy Notice is available at https://aws.amazon.com/privacy.
c. We have implemented measures designed to secure your personal information from accidental loss and unauthorized access, use, alteration, and disclosure.
7. Retaining and Deleting Personal Information
a. We only retain your personal information for as long as we must use your information as described above or comply with our legal obligations and legitimate interests. For instance, we may retain your data as necessary to meet our legal obligations, such as for tax and accounting purposes.
b. We will retain your personal information no longer than 3 years from i) your last login to the Platform, Applications or any other parts of Software, ii) the last delivery of our services to you, or iii) our last interaction with you related to your inquiry about the Platform, Software, our services or any other issues you have related to the Platform, Software or services whichever is later.
c. We will store your personal information that is used to send you promotional e-mails and/or newsletters or used for your support tickets. Such information will be stored and processed solely for this purpose until you withdraw your consent, where applicable, or unsubscribe from newsletters, but not longer than for 3 years after your last interaction with us.
d. Otherwise, we either delete or anonymize the personal information collected. In case personal information was transferred to backup storage and, therefore, cannot be deleted, we continue to store it securely, but do not use it for any purpose. In all the other cases, we proceed with the deletion of personal information.
8. Third Parties
9. Rights of European Users
If you are located in the EEA zone, the UK, Switzerland as a data subject (a person whose personal information is collected, stored, and processed) you have several rights under data privacy laws:
a. Right of access. You have the right to obtain confirmation of your personal information is being processed by us. If that is the case, you can access your personal information and the following information: (i) the purposes of the processing; (ii) the categories of personal information; (iii) to whom the personal information has been or will be disclosed; (iv) the envisaged period for which the personal information will be stored, or the criteria used to determine that period.
If you would like to have a copy of your personal information from us, we will provide it if (i) you prove your identity, (ii) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, for any further copies, we may charge a reasonable fee based on administrative costs.
b. Right to rectification. You have the right to demand that we correct without undue delay your personal information which we have in our systems if it is inaccurate or incomplete.
c. Right to erasure (“right to be forgotten”). You have the right to demand that we erase your personal information, and we shall erase it without undue delay where one of the following grounds applies: (i) this personal information is no longer necessary to the purposes for which it was processed; (ii) you withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (iii) you object to the processing and there are no overriding legitimate grounds; (iv) your personal information has been unlawfully processed; (v) your personal information has to be erased for compliance with a legal obligation.
d. Right to restrict processing. You have the right to restrict us in the ability the process your information where one of the following applies: (i) you contest the accuracy of your personal information and we are verifying it; (ii) the processing is unlawful and you want to restrict it instead of erasure; (iii) we no longer need your personal information, but you need it for the establishment, exercise or defense of legal claims; (iv) you have objected to the processing and we are verifying whether legitimate grounds override your request.
e. Right to data portability. You have the right to receive your personal information which you provided to us in a structured, commonly used, and machine-readable format and have the right to transmit those data to another company, where: (i) the processing is based on your consent or a contract; and (ii) the processing is carried out by automated means.
Where technically feasible, you can demand that we transmit those data directly to another company.
f. Right to object. You have the right to object to the processing of your personal information based on our legitimate interests. We shall no longer process your personal information unless we demonstrate compelling legitimate grounds for the processing or the establishment, exercise, or defense of legal claims.
Where personal information is processed for direct marketing purposes, you have the right to object at any time to the processing of your personal information for such marketing.
g. Right to withdraw consent. You have the right to withdraw your consent for the processing of your personal information at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
11. Contact details
Company Name: AMONRA, UAB
Address: Architektu g.56-101, Vilnius, LT
Postal Code: 04111