Walledo respects your privacy and it is committed to protecting your personal data. This privacy notice will inform you how your personal data is dealt.
1. Purpose and scope of this Policy
It is also important that you always keep your data safe and private. Never sell your data.
We aim to make you fully aware of how and why we are using your data.
This Policy together with other documents of Walledo apply to your use of Walledo application.
Our services and App is not intended to the people under the full legal age and we do not knowingly collect data related to such persons or children.
Walledo s.r.o. is the controller and it is responsible for your personal data (referred to as Walledo, we, us, our) made available or generated in relation with your use of Walledo App, Platform operation or within any contact we have with you throughout our relationship.
You can make a complaint at any time to the supervisory authority for data protection issues on its official website. We would appreciate the chance to deal with your concerns before you approach the supervisory authority, so please contact us in the first instance.
Our legal address is as follows:
Walledo s.r.o., 13000, Roháčova 188/37, Prague – Žižkov, Czech Republic.
3. Your duty to inform us of your data
We expect and request that you provide us the accurate and fair data without errors. It is important that you keep your data updated, accurate and current. Please, keep us informed if your personal data changes at any time of your relationship with us.
4. Third party links
Our App may include links to third-parties, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-parties and we can not be responsible for their privacy statements. We encourage you to read the privacy statements of every website or app you visit.
5. Information we collect about you
Personal data or personal information means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We collect and process the following data about you:
Information you give us. This is information you give us by filling in forms on the App or by corresponding with us (by e-mail, via chat functions on the App etc.) We kindly ask you not provide us more information than it is required in the form or within the correspondence neither about you nor about any other persons – any extra personal data about you or other persons does not qualify to neither collected nor processed.
6. Uses made of the information
Here we summarize the key types of the ways we use data as part of Walledo services.
1) We will use the information, submitted by you
– to carry out our obligations arising from any transactions you enter into with us included but not limited to top ups, instant transfer, electronic money change, withdrawals, purchases, voucher acquisitions and inform you on products and services that you request from us;
– to provide you with information about our goods and services;
– to provide you or permit selected third parties to provide you with information about goods and services;
– to verify your identity to protect against fraud, comply with financial crime laws and to confirm your eligibility to use our products and services;
– to notify you about changes in our services or other useful information about our services;
– to enable location services. You may switch off location services in relation to this feature in the privacy settings of the payments section of our App;
– provide you with the information, products and Services that you request from us (including access to your account on our App and our money management services);
– perform payment transactions requested by you on your Account via both national and international payment systems – comply with rules and obligations specified in card certification schemes such as when a chargeback request is filed or a card related dispute has been lodged
– to protect against fraud and comply with our regulatory and anti-financial crime regulations;
– to manage and administer our business;
– perform customer surveys, market analysis and statistics so we can improve our Services and user experience, and develop new offerings based on our customers preferences and feedback
– notify you about changes to our services and help you to solve any difficulties you may encounter while using our products and services;
– assess the quality of our customer services and to provide staff training. Calls to our customer support may be recorded and monitored for these purposes;
– perform analysis on customer complaints for the purposes of preventing errors and process failures and rectifying negative impacts on customers;
– provide you with information about new products and services including personalised offers and information about upcoming campaigns and games in accordance with your marketing preferences and location;
– attract customers with similar preferences and interests as yourself via retargeting/remarketing campaigns by means of Facebook custom audiences. Some of the data that we disclose to Facebook is Aggregated Data or anonymised data. We will only disclose your personal data to Facebook if we have your consent or it is in our legitimate interests to do so.
personal data that we receive from third parties is combined with the personal data that you provide to us and used for the purposes described above.
– to provide you with our services (including money management)
– administer our App and for internal operations, including troubleshooting, data analytics, testing, research, statistical and survey purposes
– to improve our App to ensure that content is presented in the most effective manner for you and for your device.
– to allow you to participate in interactive features of our App, when you choose to do so
as part of our efforts to keep our App safe and secure
– to protect against fraud and comply with our regulatory and anti-financial crime regulations to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you based on your preferences;
personal data that we collect from your device (for example, location data) is used to:
protect against fraud and other financial crime;
– to provide you with our money management services;
– to deliver any relevant marketing to you based on your location.
2) We will use device information:
– to administer our services and the App for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
– to improve our App to ensure that content is presented in the most effective manner for you and for your computer;
– to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our App safe and secure;
– to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
– to make suggestions and recommendations to you and other users of our Site and the App about goods or services that may interest you or them;
– to verify your identity, protect against fraud, comply with anti-financial crime laws and to confirm your eligibility to use our products and services; and
to comply with our regulatory obligations.
3) Location Information: We will use this information:
– to deliver relevant advertising to you, for example, information on nearby merchants;
– to protect against fraud; and
– to make you aware if any of your contacts, who are customers of Walledo and have location services enabled, are in the same area as you. You can switch off location services in relation to this feature in the privacy settings.
4) Third Party Information: We will combine the information, available to us with information you give to us and information we collect about you. We will use this information and the combined information:
– to help us better understand your financial circumstances and behavior so that we may make decisions about how we manage your Account;
– to process applications for products and services available through us including making decisions about whether to agree to approve any applications; and
for the purposes set out above (depending on the types of information we receive).
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
For example, we may use credit reference agencies to carry out credit searches on you. The use of credit reference agencies and fraud prevention agencies including such agencies overseas. Any such search under this section may leave a footprint on your credit files. You acknowledge that we may carry out such credit search in the knowledge that it may leave a footprint on your credit history.
We do not allow joint account holders, however in certain circumstances credit reference agencies may link your record with your spouse, partner or other financial associate. In certain circumstances, you are entitled to access your personal records held by credit and fraud prevention agencies. If you would like details of the credit reference and fraud prevention agencies from which we have obtained or may obtain information about you, please contact us via in-App support. You can withdraw your consent to be credit searched at any time by contacting our data protection officer.
7. Change of use
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected].
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
8. Fraud prevention agencies
The personal information we have collected from you will be shared with fraud prevention agencies who will use it to prevent fraud and money-laundering and to verify your identity. If fraud is detected you could be refused certain services, finance, employment or any other.
9. Your legal rights
You have the right to:
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.
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 data you provide to us.
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. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) 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 override your rights and freedoms.
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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
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.
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 at the time you withdraw your consent.
10. Categories of personal data and collection
We collect, use, store and transfer different kinds of personal data about you, which is grouped together as follows:
Identity Data – full name and date of birth
Contact Data – contact address, email address(es) and telephone numbers
Transaction Data – details about the use of your payments to and from your Walledo Account with us
Contractual information – details about the products or services we provide to you
Due Diligence Data – details about you that are stored in documents in various formats, or copies of them. This could include things like your passport, drivers license or birth certificate collected to fulfil customer due diligence requirements, that we are required by law to collect and process.
Personal data will only be collected directly and voluntarily from you as part of the application process or as a result of transactions. Some personal data may be verified by us or anti-fraud agency with use of publicly accessible sources to fulfil our customer due diligence requirements, that we are required by law to carry out.
11. International data transfer
Some of our external third parties are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
We will have to send your personal data outside of the European Economic Area (EEA) in compliance with applicable law, including to:
Follow your instructions
Comply with a legal duty
In relation to personal data processed by MasterCard, certain processors used by MasterCard are located outside of Europe. Personal data processed by MasterCard is subject to MasterCard Binding Corporate Rules, which you have enforcement rights under as a third-party beneficiary.
Once we transfer your data outside the EEU we shall observe the criteria set within the EEU. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en)
Where it is appropriate we use Model contracts for the transfer of personal data to third countries.
Where we use providers based in the US we shall consider if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared betwean the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
Where we share data with fraud and crime prevention agencies and fraud and/or criminal history checking service providers in the EEA, they may transfer your data outside of the EEA, in this case they impose contractual obligations on the recipients of that data to protect your personal data to the standard required in the EEA and/or they may require the recipient to subscribe to certain standards, intended to enable secure data sharing.
Please contact us at [email protected] if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
12. Fee policy
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
Your personal data is protected by legal rights and you can at any time:
– expressly and definitely object to our processing of your personal data;
– expressly and definitely request that your personal data is erased or corrected;
– expressly and definitely request access to your personal data.
For more information or to exercise your data protection rights, please, contact us using the contact details above.
If you are unhappy about how your personal data has been used please send us a complaint. Complaints can be sent to: [email protected]. You also have a right to complain to the relevant authority which regulates the processing of personal data.