Wubu- Privacy Policy.docx

This Privacy Policy has been developed for WUBU FZCO (Wubu, we, us, our, ours or Company). This Privacy Policy is reviewed annually, unless there is a change in regulation that requires to implement an earlier update. The Chief Information Security Officer/ Data Protection Officer (CISO/DPO) is responsible for maintaining, developing, implementing, and updating this Privacy Policy and ensuring compliance with all applicable laws, regulations, and best practices. The Board of Directors of Wubu (Board) is responsible for approving and monitoring the implementation of this Privacy Policy and the related procedures. Upon establishing that an update is required, the CISO/DPO proposes changes by presenting them to the Board. Once the Board approval is sought, the changes are incorporated in the Privacy Policy.

This Is The Privacy Policy Of WUBU FZCO

PRELIMINARY
1. Your privacy is very important to us. We are committed to the protection of your Personal Data (defined hereinafter). We are WUBU FZCO a freezone company with limited liability incorporated in the Dubai World Trade Centre, Dubai, United Arab Emirates (UAE) under the Dubai World Trade Centre Authority, bearing License Number L-3325 (Wubu). The purpose of this policy (Privacy Policy) is to inform you about the way we process your Personal Data.
2. This Privacy Policy governs our data collection, processing, and usage practices. It also describes your choices regarding use, access, and correction of your Personal Data. Personal Data for the purpose of this Privacy Policy includes any data or information relating to you which may, by itself, or in combination with other data or information, be able to identify you (Personal Data).
3. It is important that you read this Privacy Policy together with any other Personal Data processing notice we provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them. By visiting, accessing, or using Wubu’s platform (Platform) you (User or you or your) consent to this Privacy Policy and to the data processing purposes and practices stated in it. The Platform collectively refers to the Wubu website (https://www.wubu.com) (currently under development), or designated instant messaging channels, which will arrange orders from Users clients to buy and sell supported virtual assets against fiat or swap supported virtual assets for other supported virtual assets.
4. If you do not agree with the data processing purposes and practices stated in this Privacy Policy, you may choose to stop using the Platform. We periodically update this Privacy Policy and we encourage you to review it periodically. Unless specified otherwise, any changes to this Privacy Policy shall be effective as and when they are published on the Platform.
IMPORTANT INFORMATION
1. This Privacy Policy is reviewed annually, unless there is a change in the applicable laws. Applicable laws include but are not limited to, the Federal Decree Law No. 45 of 2021 regarding the Protection of Personal
  
  Data (PDPL), Law No 4 of 2022 Regulating Virtual Assets in the Emirate of Dubai, including the VARA Technology and Information Rulebook, along with applicable federal anti-money laundering (AML) and countering the financing of terrorism (CFT) laws, regulations and guidance. The CISO/DPO is responsible for the maintenance of this Privacy Policy. The CISO/DPO is responsible for data management and protection, and for maintaining policies, procedures, systems,
  
  and controls to protect your Personal Data and information against any misuse, unauthorized access and undue processing and analysis.
2. The Board of Directors of Wubu (Board) is the approving body for the Privacy Policy. Upon establishing that an update is required, the CISO/DPO proposes changes by presenting them to the Board. Once the Board’s approval is obtained, the approved changes are incorporated in the Privacy Policy.
PURPOSE AND WITHDRAWAL OF CONSENT
1. Without the necessary information about you, we may not be able to provide you with the services, or the support you request. Some of the Personal Data we obtain is collected to comply with applicable laws and regulations, including anti-money laundering laws. This Privacy Policy explains: i. The types of Personal Data we collect;
  1. How we use your Personal Data;
  2. Types of information we disclose to third parties and the types of such third parties; iv.
    
    How we transfer your Personal Data and
    
    v. How and when we protect your Personal Data.
2. Where we are relying on consent to process your Personal Data, you can withdraw your consent. Such withdrawal will not affect the lawfulness of earlier processing undertaken by us insofar it was in compliance with this Privacy Policy. Such withdrawal will take effect within 30 calendar days of submission of request. If you wish to submit such a request, please contact us at help@wubu.com.
PERSONAL DATA PROTECTION PRINCIPLES

Your Personal Data is processed in accordance with the relevant data protection principles, including lawfulness, fairness, and transparency; purpose limitation; collection limitation; data minimization; accuracy; rectification measures; storage limitation; integrity and confidentiality (security); and with due consideration to the applicable laws and regulations.
INDIVIDUALS FROM WHICH WE COLLECT PERSONAL DATA

A User is an individual whose Personal Data we process as a data controller, which would typically be: (i) the visitors to our Platform; (ii) the clients of our Platform who utilise our services; and (iii) representatives of third-party service providers who interact with us to fulfil their contractual obligations with us.

6. INFORMATION WE PROCESS, LAWFUL BASIS, PURPOSE AND MODES OF COLLECTION

We process different types of Personal Data, which we set out in the table below together with the lawful basis for our use of your information and the source of such information:

Information we process

Purpose / activity

Lawful basis

Mode of Collection

Personal identifiers/details

Identity data: includes first name, last name, username, ID document number.

Contact data: includes, contact details, email address and telephone numbers.

Profile data: includes the username and password of Users when they log in the Platform.

 Register for our services.

 Fulfil any requests you make.

 Allow you to participate in any interactive features of our service, when you choose to do so.

 Performance of a contract with you.

 If the processing is for Personal Data that has become available and known

to the public by you



Necessary to comply with a legal obligation.

 Our direct interactions with you, or our email correspondence with you.

Sensitive Personal Data

 Criminal records

 Collected as part of the due diligence process for Users and third-party representatives.

 We may also collect information about criminal convictions and offences but only in the context of fraud or security checks when this is necessary to comply with applicable laws or with any applicable financial services standards or requirements.

 Performance of a contract with you.

 Necessary to comply with a legal obligation.

 Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you.

Information we process	Purpose / activity	Lawful basis	Mode of Collection
Legal proceedings data Details of legal proceedings, details of criminal convictions or related to judicial or security procedures.	 In order to ensure that our service provision complies with the applicable laws.	 Performance of a contract with you.  Necessary to comply with a legal obligation.	 Public registers and records.  Third party providers of databases containing relevant information.
Marketing data: includes your name, position and business details and includes your preferences in receiving marketing from us and our third parties and your communication preferences.	Promote and market our services. Provide you with personal offers tailored to your needs and customising what we show you to your preferences. Distribute information, newsletters, publications, and other communication via various mediums to keep you informed	 Your consent.  Performance of our contract with you.	 Our registration, enquiry or contact forms, our direct interactions with you, or our email correspondence with you.
Feedback and opinions	Allow us to answer queries and complaints you may have. Help us evaluate the quality and consistency of our services. Research and develop new product offerings and services	 Performance of our contract with you.	 Our enquiry or contact forms, and our correspondence with you.
Technical Data: includes your internet protocol (IP) address, your login data, internet browser	Enables us to:	 Your consent.	 As you interact with our Platform, we will automatically collect Platform communication and usage

Information we process	Purpose / activity	Lawful basis	Mode of Collection
and device type, time zone setting, location data and your use of our Platform, including which pages you visited, how you got to our Platform, the time and length of your visit and your language preferences.	 monitor the performance and relevance of our Platform and our ad words campaigns;  ensure that content from our Platform is presented in the most effective manner for you and for your computer;  tailor the content of our Platform for you; and  keep our Platform, our other IT systems, and facilities safe and secure.	 Performance of our contract with you	data about your equipment, browsing actions and patterns. We collect this personal data through the operation of your browser on your device, by using cookies and other similar technologies. Please see our cookie policy as provided in section 11 for more information.
Email interaction  Information contained within our correspondence with you.	 Fulfil any requests you make.  Measure the effectiveness of our email correspondence with you, including marketing campaigns.  Plan marketing campaigns.  Segment our database.	 Performance of our contract with you.	 Our correspondence with you.
Banking data  For clients of Wubu, your bank account number, and card information.	 Perform the agreements we have with you and to manage our relationship in this respect.	 Your consent.  Performance of our contract with you.	 Our registration forms, order forms or correspondence with you.
Information we process	Purpose / activity	Lawful basis	Mode of Collection

Transaction history

 For clients of Wubu, your transaction history with Wubu, including any virtual asset purchase, sale and swapping transactions.

 Fulfil any requests you make.



Compliance with applicable laws and regulations.

 Your consent.

 Performance of our contract with you.

 Your interaction with

the Platform, your order forms, and correspondences with us.

You undertake that all Personal Data provided to us by you is true, complete, and accurate and you must notify us of any changes to such Personal Data.
We do not knowingly collect data from, or market to, children below the legal age as established under their relevant domestic laws, but in no event from children below the age of 18 years. By using the services, you represent that you are at least 18 years of age or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the services. If we learn that Personal Data from users who are less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

WE PROCESS AGGREGATED, ANONYMISED AND DE-IDENTIFIED INFORMATION

We may also create, process, collect, use, and share aggregated, anonymised, or de-identified data such as statistical or demographic data for any purpose as permitted under applicable laws. We may analyse such aggregated and anonymized information in a manner to further enhance the level of services that we offer on our Platform for business or research purposes, including improving and customizing the Platform for ease of use and the services offered by us. Such information also includes average number of Users of the Platform, the average clicks of the services, the features used, the response rate, etc. and other such statistics regarding groups or individuals. In doing so, we shall not be making disclosures of any Personal Data as such information will then no longer identify you as an individual person and we ensure that ensures the data is put beyond further use, despite being derived from your Personal Data. We may archive this information to use it for future communications for providing updates and/or surveys. Furthermore, we may also use this information to comply with legal or regulatory obligations.
WHEN WE MAY DISCLOSE THE PERSONAL DATA
1. Your information may, for the purposes set out in this Privacy Policy, be disclosed for processing to the following groups of recipients:
  1. our employees, our affiliates, and their employees. For instance, Wubu will share your information with other Wubu affiliates for the purpose of the provision of our services or when such affiliates provide support services to Wubu;
  2. our third-party consultants, (sub-)contractors, suppliers or other service providers who may access your Personal Data when providing services to us (including, but not limited, to information technology support services). This includes information technology experts who design and host our
    
    Platform, and general service companies; iii. auditors or contractors or other advisers auditing, assisting with or advising on any of our business purposes;
    1. analytics and search engine providers that assist us in the improvement and optimisation of our Platform;
    2. our successors in title, our prospective sellers, or buyers of our business or to our Affiliates when we have a merger or re-organisation;
    3. government bodies and law enforcement agencies and in response to other legal and regulatory requests;
    4. any third-party where such disclosure is required in order to enforce or apply any terms and conditions pertaining to our services or other relevant agreements; and
    5. protect the rights, property, integrity, or security of Wubu, our affiliates, third-party service providers, or others (including, without limitation, you). This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
2. Where your details are provided to any other party in accordance with an express purpose, we will require them to be kept safe and secure your Personal Data and only use it for the intended purpose.
INTERNATIONAL TRANSFERS

Your Personal Data is stored and transferred in compliance with the applicable legislation or regulations of the UAE. You should be aware that certain third-party service providers, such as our liquidity providers, may be located in, or have facilities that are located in, outside UAE, in a different jurisdiction than either you or us. We may transfer of Personal Data outside the UAE to such thirdparty service providers, and we shall do so only when the country or territory to which the Personal Data is to be transferred (i) has a bilateral or multilateral agreements related to Personal Data Protection with the UAE or (ii) has special legislation on personal data protection therein, including the most important provisions, measures, controls, requirements and rules for protecting the privacy and confidentiality of the your Personal Data and their ability to exercise their rights, and provisions related to imposing appropriate measures on the controller or processor through a supervisory or judicial authority. However, some countries to which your Personal Data may be transferred do not benefit from an appropriate data protection regulatory framework. For such countries, we shall transfer your Personal Data, only upon ensuring that a suitable degree of protection is afforded to it through the implementation of the necessary safeguards, such as an adequacy decision by the relevant authority, adequate binding corporate rules or through the inclusion of standard contractual clauses in our agreements with such organizations. We may also transfer your Personal Data to recipients outside the UAE based on (i) your express consent; or (ii) if such transfer is necessary for judicial processes; or (iii) if such transfer is necessary for entering into or performing a contract between us and you or between us and a third party for your interests, or

(iv) if such transfer is necessary for an act relating to international judicial cooperation; or (v) if the transfer is necessary for protection of public interest. We shall notify you with regards to the specific safeguard we shall adopt in transferring your Personal Data to such recipients if you specifically seek such data in exercise of your rights as a data subject.

You provide your consent, through the acceptance of this Privacy Policy for such transfer. If you wish to procure specific information about the third-party service providers with whom your Personal Data has been shared, please contact us at service@wubu.com. If you choose to proceed with a service that requires the involvement of a third-party service provider, then your Personal Data may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. For these providers, we recommend that you read their privacy policies, so you can understand the manner in which your Personal Data will be handled by these providers.
SECURITY OF PERSONAL DATA
1. Information security
  1. The Internet is not a secure medium. However, we have put in place a range of security procedures to safeguard your Personal Data. Where you have been allocated a profile to interact with the Platform, this area is protected by your username and password, which you should never divulge to anyone else.
  2. We are committed to ensuring that your Personal Data is secure. To prevent unauthorised access or disclosure we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect via our Platform. We use industry-standard technical mechanisms and ensure that our affiliates or vendor entities use data encryption technology while implementing restrictions related to the storage of and the ability to access your Personal Data.
  3. Please be aware that communications over the Internet, such as emails, are not secure unless they have been encrypted. Your communications may route through a number of countries before being delivered. This is the nature of the world wide web/internet. While we make our best efforts to secure personal data and facilitate access to your Personal Data, it is important to note that no transmission over the internet or any method of electronic storage can be guaranteed to be absolutely 100% secure. We cannot accept responsibility for any unauthorised access or loss of Personal Data that is beyond our control.
  4. We will use reasonable endeavours to implement appropriate policies, rules, and technical measures to protect the Personal Data that we have under our control (having regard to the type and amount of that data) from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction, or accidental loss.
  5. We will ensure that your information will not be disclosed to government institutions or authorities except if required by law (e.g., when requested by regulatory bodies or law enforcement organisations in accordance with applicable legislation).
  6. We also aim to conduct all applicable security risk assessments to ensure the availability of risk mitigation controls, to better safeguard the integrity of your data.
  7. Our facilities are scanned on a regular basis for security holes and known vulnerabilities, to best ensure its security. Your Personal Data is contained behind secured networks and is only accessible by a limited number of individuals who have special access rights to such systems and are required to keep the Personal Data confidential.
  8. We also have mechanisms in place to access your Personal Data in case of an actual or technical
  failure. We also ensure testing and evaluation of our technical and organizational measures at regular intervals to gauge the effectiveness of such measures.
2. No guarantee
  1. Without prejudice to our efforts on protection of your Personal Data, nothing contained in this Privacy Policy constitutes a warranty of security of the facilities, and you agree to transmit data at your own risk.
  2. Please note, that we do not guarantee that your Personal Data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please, always check that any website on which you are asked for financial or payment information in relation to our services is in fact legitimately owned or operated by us.
  3. If you do receive any suspicious communication of any kind or request, do not provide your information and report it us by contacting our offices immediately at help@wubu.com. Please also immediately notify us at service@wubu.com if you become aware of any unauthorized access to your profile on the Platform.
  4. Furthermore, we cannot ensure and do not warrant the security or confidentiality of data transmitted to us or sent and received from us by internet or wireless connection, including email, phone, instant messaging service or SMS, since we have no way of protecting that information once it leaves and until it reaches us. If you have reason to believe that your data is no longer secure, please contact us at crco@wubu.com.
3. Data breaches
  
  Should your Personal Data be breached, and your financial and personal security be at risk, we shall promptly and immediately communicate to you the nature of the breach which has taken place, the likely consequences of such a breach and shall describe thoroughly the measures we have implemented to address the breach and to mitigate any and all adverse effects to you and your rights. In the event of an actual or potential infringement or breach of your Personal Data that would prejudice the privacy, confidentiality, and security of such Personal Data, we shall immediately upon becoming aware of such infringement or breach report it to the UAE Data Office/ relevant data protection authority of the breach in accordance with applicable regulations and to you within a period of twenty-four (24) hours. We shall share (i) the nature of the actual or potential breach or infringement which may take or has taken place, (ii) the likely consequences of such a breach or infringement, and (iii) the measures we have implemented to address the breach or infringement and to mitigate all adverse effects to you and your rights. Further, we shall conduct an internal investigation as to the reasons of the breach or infringement of Personal Data and shall the results of the same with the UAE Data Office/ relevant data protection authority in the form of a report. A copy of said report shall be shared by us with the VARA, unless prohibited by applicable laws, as will be demonstrated by us to the VARA’s satisfaction. In the unlikely event of a breach occurring, please reach out to us at crco@wubu.com for further information and for further advise on how to mitigate the potential adverse effects of such a breach.
COOKIES POLICY

This Clause of the Privacy Policy explains what cookies are, what information we collect using cookies

and how we use cookies in respect of the Platform.
1. What is a cookie?
  1. A ‘cookie’ is a small piece of encrypted text saved on the browser or hard drive in your computer or mobile device when you visit a website. Cookies are selected pieces of information that websites or mobile applications send to your device or computer’s hard drive, while you are viewing or using our Platform. It allows us to recognise you and make your next visit easier and the experience of our services more useful to you. cookies can be stored for varying lengths of time on your browser or device.
  2. We use both session / transient cookies (which expire once you close your device web browser) and persistent cookies (which stay on your device until you delete them) to collect information to provide you with a more personalized and interactive experience in using our Platform and services. This type of data is collected to make our services more useful to you and to tailor your experience with us to meet your special interests and needs.
2. How we use cookies
  
  When you use and access our Platform, we may place a number of cookie files on your device or web browser. We use cookies to enable certain functions of the Platform i.e., to provide analytics, to prevent fraudulent or illegal activity, to store your preferences, to enable advertisements delivery, including behavioural advertising. We also use cookies to enhance your browsing experience by:
  1. Recognizing when you log in and any preferred settings.
  2. Giving you a browsing experience that is unique to you and to serve you content which we believe improves your sites experience.
  3. Analysing how you use our sites which helps us to troubleshoot any problems and to monitor our own performance.
    
    In addition to our own cookies, we may also use various third parties’ cookies to report usage statistics of our sites, deliver advertisements on and through our Platform, and so on.
3. Types of cookies we use
  
  We use the following four type of cookies,
  1. Essential cookies: These cookies are essential to let you move around the Platform and use its features. These cookies allow our Platform to provide services at your request. We use essential cookies to authenticate users and prevent fraudulent use of user accounts.
  2. Performance cookies: These cookies may be used to collect information about how you use the Platform e. g., which pages you visit most often, and if you experience any error messages. They also allow us to update our Platform to improve performance and tailor it to your preferences. These cookies do not collect any information that could identify you - all the information collected is anonymous.
  3. Functionality cookies: These cookies are used to remember the choices you make, e.g., your username, log in details and language preferences. They also remember any customizations you make to give you enhanced, more personal features of your digital experience.
  4. Advertising and targeting cookies: These cookies are used to collect information about your visit to our sites, the content you viewed, browsing habits to deliver adverts which are more relevant to your interest, links you followed and information about your browser, device, and your IP address. They also measure the effectiveness of advertising campaigns.
4. Cookies preferences
  
  Please note, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer on our Platform. You may not be able to store your preferences, and some of our pages might not display properly. Wubu is not responsible and will not be held liable for any loss resulting from your decision or inability to use cookies.
YOUR RIGHTS
1. We will take all reasonable steps to ensure that all information we collect, use, or disclose is accurate, complete, and up to date. Please contact us if your details change or if you believe the Personal Data, we have about you is not accurate or complete.
2. In some instances, you may also have the rights to:
  1. Request access to your Personal Data (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
  2. Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new information you provide to us.
  3. Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which you will be notified of.
  4. Object to processing your Personal Data and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which do not override your rights and freedoms.
  5. Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (i) if you want us to establish the data's accuracy; (ii) where our use of the data is unlawful but you do not want us to erase it; (iii) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  6. Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  7. Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case.
HOW LONG WE KEEP PERSONAL DATA

We retain Personal Data on your behalf, including User data, transactional data, and other session data, linked to your account. Your Personal Data will be retained for no period longer than as required by us for the purposes it was collected for, for the purposes of using our services, and for meeting any legal, accounting, reporting, government, regulatory or law enforcement requirements. However, all Personal Data documents, records and files will be securely retained for a minimum of 5 years. Such retention period shall be calculated from the date of closing of your professional relationship with us.
CONTACT US

If you have any queries or issues pertaining to your information or our Privacy Policy, then please do write to us at any time by emailing us at help@wubu.com.

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