Walawong Solutions Pte Ltd (“Walawong,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive, including information that would be considered “personal data” within the meaning of the EU General Data Protection Regulation (“GDPR”). As used in this privacy policy, “personal data” refers to information about an identified or identifiable individual, such as their name or email address.

For the purposes of the GDPR, Walawong is considered the data controller in some situations and the data processor in other situations. When we are acting as the data controller, we are responsible for deciding how we use the information that we hold. When we are acting as the data processor, Customers and their End Users are responsible for deciding how we use the information that we hold. We are an entity registered in Singapore with registered office at 160 Robinson Road #14-04 Singapore 068914.

The GDPR applies to you if you are located in the European Economic Area, the United Kingdom or Switzerland (an “EEA Individual”).

Walawong provides software (the “Walawong Software“) that enables users (“End Users” or “you) to aggregate account information and data, from the data sources where these End User’s End User Data (as defined below) are stored (as modified from time to time, the “Services”).

“End User Data” means End User account information and data, including (a) account name, account type and public wallet or deposit addresses, (b) information related to account balances account transactions, in both amounts and in other currency equivalents (e.g. US Dollars), (c) information about account transactions, including amount, date, time, type, location, price, cost basis, fees, quantity, sender and recipient and (d) information about the End User as the account owner, such as publicly provided name.

Walawong also provides the Walawong Software, the Services, the website at www.walawong.com (“The Website”), the dashboards, the related tools and the various related services, features, functions, software, applications, websites and networks associated with Walawong (collectively the Services) to our customers (“Customers” or “You”) that can use these Walawong Services to integrate the Walawong Software and Services into their applications or third-party applications (collectively, “Walawong Enabled Applications”).

Please note that by accessing and using any of the Walawong Services, you are accepting the practices described in this privacy policy, subject to any rights or restrictions that might apply under the GDPR if you are an EEA Individual, including the rights described in the European Privacy Rights for EEA Individuals provisions below. This privacy policy is incorporated by reference into (a) the Terms of Service for End Users that govern the access and use of the Walawong Software, the Services and the other Walawong Services and (b) the Terms of Use for the Customers or the subscription agreement for certain other customers that govern (i) the access and use of the Services (or other similar services) and the other Services and (ii) the provision of the Walawong Software and the Services to End Users through a Walawong Enabled Applications (collectively, the “Terms”).

This policy applies to information we collect or may collect:

For End Users:

For Customers:

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use the Walawong Services. By accessing or using any of the Services, you agree to this privacy policy. This policy may change from time to time as more particularly described in the Changes to Our Privacy Policy provision below.

None of the Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Services or the other Walawong Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Walawong Services or any of its features or register on use any of the interactive or public comment features of any of the Walawong Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at support@walawong.com.

The technologies we use for automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.

We collect or may collect several types of information from and about users of the Walawong Software, the Services and the other Walawong Services, including:

For End Users:

Login information required to authenticate, access and maintain connection with your accounts, including, usernames (which may be in the form of email), passwords, API keys, one-time multi-factor codes (e.g., SMS, token-based, hardware-based and others), and session tokens End User Data Usage details and information; and/or Geo-location information;

For Customers:

Information by which you may be personally identified, including personal data such as name, telephone number, address and e-mail address; Your IP address, including when you create an account; Information that you provide by registering or creating an account in connection with the Walawong Services; Financial and billing information, including credit or debit card information; Analytics information; Information that is about you but individually does not identify you, such as the date and time of visit; Device, internet and mobile information such as the hardware model, operating system version, browser type, language, wireless network, and mobile network information Geo-location information; When you report a problem with any of the Services or any of the other Walawong Services; Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or Details of transactions you carry out through the Services, and any of the other Walawong Services.

Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.

We may use or partner with third-parties, agents or contractors for various purposes in connection with our business and operations (collectively, “Service Providers”), including, storage of access credentials and End User Data, the provision of the Walawong Software and the Services through a Walawong Enabled Application through the Customers and billing and payment services. In the course of performing these responsibilities and providing such services, these other companies may have access to your personal information. We may also share information, including your End User Data and personal information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. We do not list our current Service Providers because they change from time to time. If you would like the names of any of the Service Providers, please email us at support@walawong.com.

We use commercially reasonable efforts to ensure that each Service Provider to which we have shared your End User Data and personally identifiable information in connection with providing services are required to use your personal information in strict compliance with its terms, privacy policy and applicable law and do use this End User Data or personal information except in connection with its business that employs the Services or the other Walawong Services. These Services Providers have adopted their own terms and privacy policies, which are not subject to control by Walawong. You should always review the terms and policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your data and information.

We use information that we collect about you or that you provide to us, including any personal data: For End Users: To provide you with the Walawong Software and the Services through a Customer's Walawong Enabled Application. To enhance the safety and security of the Walawong Software and the Services. In any other way we may describe when you provide the information. For any other purpose with your consent.

For Customers: To provide you the Services and the other Walawong Services and the content and the other products and services that you request from us. To process and complete transactions, including registration for the use of the Services and the other Walawong Services and send you related information. To provide technical and other support to you. To send you promotional communications, such as providing you with information about services, features, surveys, newsletters, offers and events; and providing other news or information about us. To fulfill any other purpose for which you provide it. To provide you with notices about your account. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. To notify you about changes to the Services and the other Walawong Services. To enhance the safety and security of all of the Walawong Services. To verify your identity and prevent fraud or other unauthorized or illegal activity. In any other way we may describe when you provide the information. For any other purpose with your consent.

We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Walawong Software, the Services or any of the other Walawong Services outside of the Singapore, information that we collect about you may be transferred to servers inside Singapore and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Walawong and you. By allowing Walawong to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as a local cache so that you can open and view content faster.

Although users from all over the world may access the Walawong Software, the Services and the other Walawong Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to Singapore and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

We may disclose aggregated or anonymized information about our users, and information that does not include any personal data, without restriction. We do not sell any personal information.

We may disclose End User Data to our Customers in connection with the provision of the Services through their Walawong Enabled Application.

We may disclose personal data that we collect or you provide as described in this privacy policy: To our subsidiaries and affiliates. To Service Providers, including Customers, that we use to support our business as more particularly described in the Third-party Responsibilities and Services provision above. To other users in your organization in connection with the Services or any of the other Walawong Services. To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Walawong’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by Walawong about users of is among the assets that may be or are actually transferred. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent.

We may also disclose your End User Data or personal data: To comply with any court order, law or legal process, including to respond to any government or regulatory request. To enforce or apply the Terms and other agreements, including for billing and collection purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Walawong, our customers or others.

We may share information that is anonymized or in an aggregated form that does not include any personal data about you and we may use and share any such anonymized or aggregated information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We may use, disclose or sell that anonymized or aggregated information without restriction so long as we do not disclose any of your personal data or violate the terms of this privacy policy or any applicable law.

GDPR and the laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data: Performance of a contract: In most cases, we collect and use your End User Data and personal data and other information to meet our obligations under a contract to which you are a party or pursuant to which we are providing services to you. For example, when you use the Customer Services or the other Walawong Services, we will use your personal data to respond to your requests and to provide you with these services. Legitimate interests: We may use your personal data information for our legitimate interests on the grounds that it furthers our legitimate interests in commercial activities (but only to the extent that such interests are overridden by the interests or fundamental rights and freedoms of the affected individuals) including: Analyzing and improving the Walawong Software, the Services, the other Walawong Services and our business Providing the services pursuant to our contracts with our clients Marketing Legal compliance: We may use and disclose personal data in certain ways to comply with our legal obligations under European or Member State law or other applicable law. Consent: To the extent required by law, and in certain other cases, we handle personal data on the basis of implied or express consent.

We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

End Users may change, correct or delete any personal data that they have provided to the Customer providing the Walawong Enabled Application through which you are accessing the Walawong Software and the Services as directed by such Customer.

Customers may change, correct or delete any personal data that they have provided to us through their dashboard or by emailing us at support@walawong.com.

We understand that the security of your access credentials, End User Data and personal data is very important.

For End Users, Walawong will encrypt the access credentials that you use to access your End User Data and employ other commercially reasonable security measures to protect End User Data in accordance with good industry practice and all applicable laws.

For Customers, we provide reasonable administrative, technical, and physical security controls to protect your personal data.

Despite our efforts, however, no security controls are 100% effective. Walawong cannot ensure or warrant the security of your credentials, End User Data or personal data. Any transmission of your credentials, End User Data or personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on or through the Website.

We may amend this policy from time to time to ensure that this policy is consistent with any developments to the way we use your personal data or any changes to the laws and regulations applicable to us. We will make available the updated policy on our website (www.walawong.com/policy). All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time.