Privacy Policy
An intuitive and innovative solutions provider, Wallex is quickly becoming Asia’s leading platform for borderless transactions. Pay, collect, convert and hold FX in 46 currencies across 180 countries.
1. SCOPE AND CONSENT
2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
3. HOW WE USE YOUR PERSONAL DATA
4. HOW WE SHARE YOUR PERSONAL DATA WITH OTHER WALLEX USERS
5. HOW WE PROTECT YOUR PERSONAL DATA
6. ACCESSING AND CORRECTING YOUR PERSONAL DATA
7. STORAGE, SECURITY AND RETENTION OF YOUR PERSONAL DATA
8. Your Rights Regarding Personal Data
1. SCOPE AND CONSENT
By signing up, accessing, or using any products, services, content, features, technologies, or functions available on the Wallex Online System, website, mobile sites, applications, and all related sites, you agree to the terms of this Privacy Policy
By using our Services, engaging with us, submitting information to us, and/or registering for a Wallex Account, you consent to our collection, use, disclosure, and retention of your personal information as outlined in this Privacy Policy and our Terms and Conditions.
You may withdraw your consent for the use of your personal information as described in this Privacy Policy by contacting us at [email protected]. However, please note that withdrawing your consent may result in limitations to your Wallex Account or our inability to provide certain Services to you.
2. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
In this Privacy Policy, "Personal Information" refers to any information linked to a specific individual, which can be used to identify that individual, either on its own or when combined with other information accessible to Wallex. We do not consider any anonymized or aggregated information, which can no longer be used to identify a specific individual, as Personal Information.
We collect Personal Information from you and the devices you use, including mobile devices, to access or use our Services. It is important to ensure that all Personal Information you provide to us is complete, accurate, and truthful. Failure to do so may prevent us from offering you the products and services you request.
We collect, use, store, and transfer different kinds of personal data about or relating to you, including but not limited to the following:
a) Identity and contact data, which
if you act in your personal capacity: your name, passport or other unique identification number, telephone number, mailing address, email address, social media profile information, images/copies of your passport or identification document, your likeness (including photographs of yourself and other biometric information), utility bill or driving license;
if you represent a company, the information we collect may include details about the organization or company, such as the company name, registration number, address, email address, telephone number, shareholding details, beneficiary details, and other relevant information related to business transactions. Where necessary, to ensure compliance with the laws, we may collect information relating to the source of funds, relationship with the beneficiary, purpose of the transaction, its ownership and control structure;
b) Financial data, which
includes information about your financial position, status and history, and payment account details (such as bank, credit, payment or other payment details).
c) Transaction data, which
includes details about fiat currency transfers, as well as issuance, transfer, administration, settlement, custody and recording activities in respect of security and payment tokens to, from and amongst your accounts with us;
d) Technical data, which
includes details about the devices and technology you use including internet protocol address, your login data, and other technology on the devices you use to access our website, mobile application, products and/or services; and/or
e) Usage data,
includes information about how you use our website, products and/or services, including cookies, IP addresses, and account details.
We collect personal data from or relating to you in various ways, including but not limited to
the following:
a) when you access and/or use or submit information to our websites, mobile applications (collectively the “Business Channels”), our verified channels with social media (collectively the “Social Media Channels”), products and/or services (or part thereof);
b) when you submit forms in or relating to our website, mobile application and/or any of our products or services;
c) when you register to attend any of our in-person events or webinars;
d) when you post, publish, transmit, or upload content on our business and social media channels or through our services;
e) when you register for, use, or access any of our social media channels, services on business channels owned and/or operated by us or when you register as a member of the business channels owned and/or operated by us, or use services on such business channels owned and/or operated by us;
f) when you interact with our personnel such as customer service officers, marketing representatives and agents;
g) when you request that we contact you;
h) when you ask to be included in an email or other mailing list;
i) when you respond to our promotions and other initiatives;
j) when you enter into agreements or business relations with us;
k) through other publicly available sources and third parties (such as your demographic or contact information that may be used to verify you or your business, or to assess fraudulent activity;
m) when we receive references from business partners and third parties, for example, where you have been referred by them; and/or
n) when you submit personal data to us for any other reason.
Third-Party Data
Where you disclose personal data of other individuals to us, you warrant that such individuals have consented to us collecting, using and/or disclosing such personal data for (i) the relevant purpose for which you made the disclosure or as was notified to you at the relevant time; and (ii) the other purposes as described above in this Privacy Policy.
3. HOW WE USE YOUR PERSONAL DATA
Generally, Wallex collects, uses and/or discloses personal data, and you consent to such collection, use and/or disclosure by Wallex, for the following purposes:
a) to process your application, including but not limited to verifying your identity and evaluating your financial and legal track record, for our goods or services;
b) to provide products and services to you, including administering and/or managing your relationship or account with us;
c) processing and/or dealing with any of your requests and any necessary investigations relating to your requests;
d) carrying out due diligence or other screening activities in accordance with legal or regulatory obligations or risk management procedures that may be required by law or by us;
e) carrying out your instructions or responding to any of your inquiries;
f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to improve and design our products, understand customer preferences and market trends, and to review, develop and improve the quality of our products and services;
g) to communicate with you on matters relevant to your relationship with or interest in us;
h) pre-emptively detecting and/or investigating fraudulent conduct, misconduct, unlawful action or omission, and any suspicion of the aforementioned, and analyse and manage other commercial risks;
i) to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered into between us and you;
j) to protect and enforce our contractual and legal rights and obligations;
k) to conduct audits, reviews and analysis of our internal processes, for action planning and managing commercial risks;
l) to manage the safety and security of our premises and services (including but not limited to carrying out closed-circuit television surveillance and conducting security clearances);
m) to comply with any applicable rules, laws and regulations (including any laws and regulations relating to anti-money laundering, countering the financing of terrorism / proliferation financing, and tax reporting obligations), codes of practice or guidelines or to assist in law enforcement and investigations by relevant law enforcement agencies, regulatory authorities and other governmental agencies, anywhere in the world;
n) to provide such personal data to issuers on our platform and/or their financial intermediaries (where applicable) to allow them to comply with any applicable rules, laws and regulations (including any laws and regulations relating to anti-money laundering, and countering the financing of terrorism/proliferation financing), codes of practice or guidelines or to assist in law enforcement and investigations by relevant law enforcement agencies, regulatory authorities and other governmental agencies (including tax authorities);
o) to provide such personal data to financial institutions and other agents or service providers, in connection with refunds or erroneous transactions; and
p) any other purpose relating to any of the above.
We may also use and process your Personal Data for other marketing and promotional related purposes such as via post, email, telephone call, SMS, mobile app notification, website, and/or online messaging service (“Additional Purposes”):
a) to assess and improve the products and services that you use or may use;
b) to selectively send you information about our products, services, activities and/or events that may be relevant to you;
c) providing or marketing services, products and benefits to you, including promotions, loyalty and reward programs;
d) to conduct research, surveys and data analysis relating to or to enhance any service or product provided by us (whether conducted by Wallex or jointly with another party) that may be relevant to you (“Research Purpose”); and
e) Match personal data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Wallex or other third parties.
We may share personal data with our regulators, affiliated companies, service providers, agents, and other third parties for the above purposes and any other reasonable related purposes. This includes sharing data for legal and regulatory reasons or when permitted under the PDPA and other applicable Malaysian laws, such as in response to requests from law enforcement agencies.
If we transfer personal data to countries outside of Malaysia, we will do so in accordance with the relevant provisions under Malaysian laws and regulations. Additionally, we will comply with the applicable laws and regulations governing the transfer of personal data from the countries where it was collected.
4. HOW WE SHARE YOUR PERSONAL DATA WITH OTHER WALLEX USERS
The protection of your Personal Information is very important to Wallex. We will share selected Personal Information with other Wallex Users to facilitate your transactions and to help resolve a dispute between you and another Wallex User.
Our policies and Terms and Conditions expressly prohibit a receiving party from using any Personal Information that we may share with them for unrelated purposes, such as to directly market to you, unless you have agreed to it. Contacting Users with unwanted or threatening messages is also against our policies and constitutes a violation of our Terms and Conditions.
5. HOW WE PROTECT YOUR PERSONAL DATA
We will take reasonable steps to protect your Personal Data against unauthorized disclosure. To the extent permitted by law, we may transfer or disclose your Personal Data for the above Purposes and Additional Purposes stated in this Notice, to the following entities or parties, whether they are located overseas or in Singapore:
a) Wallex Group of companies;
b) Counterparties and their respective financial institutions in relation to payments and other transactions;
c) Agents, contractors or third-party service providers who provide operational services to Wallex Group, including but not limited to courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to Wallex Group;
d) Vendors or other third-party service providers, including but not limited to advertisers and event management companies, in connection with promotions and services offered by Wallex Group;
e) Professional advisors and external auditors, including legal advisors, financial advisors and consultants;
f) Co-branded and other business partners; and/or
g) Any other party to whom you authorize us to disclose your Personal Data.
6. ACCESSING AND CORRECTING YOUR PERSONAL DATA
We take measures to ensure the Personal Information we collect is accurate and up-to-date, allowing you to access and update or correct it as needed.
a) Accessing Your Personal Information
You can access your Personal Information anytime by logging into your Wallex User panel and clicking on “Settings.”
b) Updating/Correcting Your Personal Information
You are responsible for ensuring that all Personal Information you provide is complete, accurate, true, and correct. If you wish to update/correct your personal information, please contact us at [email protected]. We reserve the right to reject your update/correction request if we have reasonable grounds to believe the update/changes should not be made.
7. STORAGE, SECURITY AND RETENTION OF YOUR PERSONAL DATA
a) Security Measures
All personal data is kept confidential and we take reasonable measures to protect it from unauthorized or accidental access, misuse, disclosure, alteration, processing or loss, by implementing appropriate physical, electronic, administrative and supervisory controls.
b) Retention of Personal Data
According to Money Services Business Act 2011 requirements, we must retain all information
about your transactions with us, including personal data at least a minimum of seven (7)
years or beyond the specified retention period for special cases such as pending legal
proceedings or investigations which has yet to be resolved.
We shall take all reasonable steps to ensure that your personal data is destructed and permanently deleted when no longer required for the purposes described in this Privacy Notice. We also do not offer any online facilities for you to delete your personal data held by us.
c) Cookies
When you browse our websites, use our mobile applications, engage with our social media channels, or contact us through customer service channels, we and the third party with whom we partner may use cookies, tags, scripts, web objects, advertising identifiers (such as Apple’s IDFA or Google’s Advertising ID), and similar technologies (“Cookies”) to collect and store information about your usage to improve the quality of our services.
Cookies may transmit data about you and your service usage, including but not limited to your IP address, browser/device type, browsing history, and time spent on our website or mobile application, to the Company and our partners. This helps us provide and develop a more personalized browsing experience and improve targeted advertising.
We may allow third parties to use Cookies on our website and mobile application to gather similar information. These third parties may combine the data they collect with other information they have about you from different sources. We do not always have access to or control over the Cookies they use.
The Company may share non-personally identifiable information with third parties, such as advertising identifiers, location data, or encrypted account identifiers, to improve targeted advertising on platforms like search engines and social media channels.
Cookies may be stored either persistently or only during a single user session, depending on the type of cookie involved. If you do not wish your Cookies to be collected, you may deactivate them by adjusting your internet browser settings to disable, block, or deactivate cookies, deleting your browsing history, and clearing the cache from your browser. Additionally, you may also be able to limit some information sharing through your mobile device settings.
D) Telephone Calls, Emails and Text-Based Enquiries
To continuously improve our service, all communications between you and the Company, whether via telephone calls, e-mails and/or text-based methods may be recorded and monitored.
8. Your Rights Regarding Personal Data
If you have any questions or concerns regarding this Privacy Policy, please contact us via email at [email protected]