CLIENT DATA PROTECTION POLICY

Client means a physical person who achieved the age of majority or a legal entity which, through its actions, is able to acquire civil rights and fulfil these rights on its own, and also create civil obligations for itself, fulfil these obligations on its own and bear responsibility in case of non-fulfilment of these obligations and which accepted the terms of this document and uses the services offered by the Website.

Administration is a sole private owner of the Website which provides organizational, financial, technical support for maintenance and operation of the System and the Website. The Administration also ensures continuous operation of the Website and 24/7 free access for all participants of the network.

Parties mean the Administration and the Clients of the Website.

Client Data Protection Policy (abbr. – «Confidentiality Policy») is a set of rules for processing of the Client’s data and interaction between the Parties during the process of use of the Website features by the Client.

Acceptance means a legal action of active nature performed by a Party and expressing the consent of the Party with the provisions and the rules for processing of the Client’s data contained in them and stated in the Confidentiality Policy. The Parties have agreed that such action may be performed by:
(a) the Administration by publishing this Confidentiality Policy on the Website;
(b) by the Client in a way determined in the provisions of this Confidentiality Policy.

General Data Protection Regulation (abbr. – «GDPR») – General Data Protection Regulation 2016/679 of the European Parliament and Council of the European Union of 27 April 2016 on protection of physical persons with regard to the processing of personal data and on the free movement of such data, and repealing the Directive 95/46/ЕС (General Data Protection Regulation).

Personal data is any actual information which allows to identify the subject of the data. This information includes the name, data on the location, online identifier and one or several factors characteristic for physical, physiological, genetic, intellectual, economic, cultural and social identity, including, but not limited to the IP address, name, electronic mail, API tokens, payment information and HTTP reply (status) code.

Website is an Internet resource created for the purpose of operation of the System under the domain name: https://www.jwallet.cc. The website is under organizational management and constitutes private property of the Administration.

1. General terms

1.1. This Confidentiality Policy determines the procedure for processing and protection of personal data of the Clients which may be obtained by the Administration when a Client uses the services provided through the Website.

1.2. The requirements of General Data Protection Regulation are taken into account in the process of compiling this Confidentiality Policy as well as in our algorithms of interaction with the Clients.

1.3. The Administration provides its services exclusively to persons who have achieved the age of 18 and are able to acquire civil rights and fulfil them on their own through their actions.

1.4. Within the framework of mutual relations with Clients of the Website, the Administration has the legal status of Data Controller.

1.5. The purpose of this Policy is to ensure proper protection of information on the Clients, including protection of their personal data from unauthorized access and disclosure.

1.6. Any relations connected with collection, storage, disclosure and protection of the information provided by the Client will be regulated by this Confidentiality Policy. The Administration pays special attention to data protection.

1.7. The Administration will notify the Client on the way it uses the information received by the Website.

1.8. The Clients who intend to use the features of the Website for the first time, including those in text format, must familiarize themselves with the terms of the Confidentiality Policy beforehand.

1.9. Clients who use the features of the Website after this Confidentiality Policy becomes effective must familiarize themselves with its current provisions. In this case, the Administration must send current versions of this Confidentiality Policy to the persons specified in this paragraph of the Confidentiality Policy. The fulfilment of this obligation includes the use of electronic mailing address specified by the Client in the process of completion of respective registration form on the Websi

1.10. Clients including those specified in paragraphs 1.8., 1.9 who have familiarized themselves and agree with provisions of this Confidentiality Policy express their full consent with the provisions of this Confidentiality Policy and authorize the Administration to use and process their personal data for the purposes determined by functional designation of the Website.

1.11. If the Client fails to fulfil his or her obligation specified in paragraph 1.10 of the Confidentiality Policy, then he or she is deemed to have refused the terms of this Confidentiality Policy. In this case, the Client may not use the features of the Website and is deprived of the opportunity to use the features of the Website. In cases foreseen in this paragraph of this Confidentiality Policy the Administration agrees to remove personal data of such a person.

1.12. If a person does not agree with the provisions of this document (fully or partially), then the person who has expressed such will may not use the Website. In this case, such Party must bear the consequences foreseen by paragraph 1.11 of this Confidentiality Policy.

2. Principles for processing of personal data of the Website Clients.

2.1. Personal data will be processed by the Administration in a legal, fair and transparent way with regard to the Client.

2.2. The Client’s personal data will be processed only in cases and for the purposes which these data are collected for.

2.3. The Client’s Personal data must conform, refer and may be restricted by the purpose of use of this Website which these data are processed for.

2.4. The Client’s personal data used by the Administration will be precise and up-to-date. Out-of-date or inaccurate personal data will be corrected or removed by the Administration.

2.5. The Administration performs regular verifications for the purpose of systematized database cleaning. The Administration stores the information on the Clients for a certain period of time if it is justified by commercial or legal purposes.

2.6. Personal data will be processed by the Administration in a way which ensures proper protection of personal data, including protection from unauthorized or illegal processing, and also from accidental loss, destruction or damage using appropriate technical or organizational measures.

3. Terms of use of the information provided by the Website Clients

3.1. In order to provide services to the Client through the Website, the Administration collects two types of information, i.e. the information of personal and non-personal nature.

3.1.1. Personal information includes the information which makes it possible to establish who the Client is and which may be used to establish the Client’s identity, contact him or her and also to determine his or her location (IP). If the Client refuses to provide his or her information, then the Client will have access to the larger part of the Website.

3.1.2. Personal information provided by the Client incudes name and surname, phone number, electronic mailing address and other contact information.

3.1.3. Personal information will be collected by the Administration by way of performing the following actions on the Website:
- use of the Website balance;
- compilation of an order in favour of third parties
- other functional capabilities foreseen by the services offered by the Website.

3.1.4. The Administration will use the Client’s personal information to provide services, send advertisements and offers and also to improve the Client’s experience on the Website.

3.1.5. Non-personal information includes the information which does not identify a specific individual.

4. Purposes of collection, processing and storage of the information provided by the Website Clients

4.1. The Administration will process the Client’s personal data only if the Client gives his or her consent for processing of his or her personal data for one or several specific purposes.

4.2. The Administration will process the Client’s personal data for the following purposes:
- to identify the Client within the framework of relations between the Administration and the Client;
- so that the Administration could provide to the Client a range of services offered by the Website;
- to conduct statistical and other studies based on depersonalized data.

5. Rights of the Clients who provide their Personal data for processing

5.1. The Client may:

5.1.1. obtain from the Administration the following information upon request:
(a) on the purposes of processing of the Client’s personal data by the Administration;
(b) on the persons who these personal data have been or will be disclosed to, specifically to recipients in countries which are not members of the European Union or any international organizations;
(с) on the supposed period for storage of personal data or, if it is possible, the criteria used to determine this period;

5.1.2. obtain from the Administration the information determining the categories of personal data

5.1.3. ask the Controller to correct or remove personal data or limit the processing of personal data with regard to the subject of the data or raise objection against processing of such data;

5.1.4. file a complaint to a competent supervisory authority controlling the procedure for processing of personal data:

5.1.5. in case of automated decision-making, including profiling specified in articles 22 (1) и (4) of GDPR, or at least, in such cases, asking to provide substantial information on the logic involved and also on the importance and probable consequences of such processing for the subject of the data.

5.1.6. ask the Controller to correct imprecise personal data of the Client without unjustified delays.

5.1.7. file an additional application if incomplete personal data have been provided.

5.1.8. ask the Controller to remove the Client’s personal data without unjustified delays on one of the following grounds:
- personal data are not required anymore for the purposes which they were collected for or were processed in another way;
- the Client does not agree with the provisions of the Confidentiality Policy;
- there are no legal grounds for processing such data;
- personal data have been collected and (or) processed in an illegal way;

5.2. If the Administration allowed the Client data to become public knowledge, then the Administration must remove such data of the Client and also, while taking into the account the available capabilities and the cost of fulfilment, the Administration must take reasonable measures, including technical ones, to notify the persons responsible for processing these personal data which the Client wishes to remove about removal of any links to these data or to prevent copying or replication of these data.

6. Terms of processing of the personal information provided by the Client and terms of its transfer to third parties

6.1. The Administration takes all necessary measures in order to protect personal information of the Client from unauthorized access, change, disclosure or destruction.

6.2. The Administration gives access to the Client’s personal data only to a circle of persons who need this information to ensure the operation of the Website and in order to provide services to the Client.

6.3. For the purpose of providing services to the Client, the Administration may transfer the Client’s personal information to third parties in order to provide the ordered services. In this case, the information will be transferred confidentially and in accordance with all obligations for ensuring the safety of personal information.

6.4. The Administration may use the information provided by the Client, including personal data, for the purpose of ensuring compliance with requirements of current legislation of the Hong Kong (and for prevention and/or suppression of illegal and/or unlawful actions of the Client). The information provided by the Client may be disclosed only in accordance with current laws of the Hong Kong upon request of a Court, request of law-enforcement authorities as well as in other cases foreseen by laws of the Hong Kong.

6.5. The Administration will take the measures necessary from commercial viewpoint in order to prevent third parties from collecting, changing or destructing the information placed at the Administration’s disposal on the Website.

6.6. Measures specified in paragraph 6.5 include controlling network flow for the purpose of identifying unsanctioned attempts to download or change information and also coding of the confidential information using Secure Sockets Layer (SSL) safety protocol and other similar technologies under certain circumstances. The website also allows to exercise control in order to prevent any illegal activity or any activity which may lead to a legal liability of the Administration or could cause damage to it.

6.7. The Administration undertakes to ensure the safety of the Website and will also constantly monitor its legality in such a way that the services offered through a Website would be accessible to all the Clients.

6.8. Despite the fact that the Company takes all the measures necessary from commercial viewpoint in order to prevent collection of personal information of the Clients by unauthorized persons, illegal interception or seizure of such information by third parties is still possible.

6.9. In case of a leak/ theft/ discrediting of personal data, the Administration will notify the competent authorities as soon as possible after such leak/theft/ discrediting is discovered.

7. TERMS OF USE OF THE WEBSITE

7.1. While using the Website, the Client confirms that:

7.1.1. he or she has all necessary rights allowing him or her to acquire civil rights and exercise those rights on his or her own, and also the ability to create civil obligations through his or her own actions, fulfil those obligations on his or her own and bear responsibility in case of non-fulfilment of such obligations;

7.1.2. he or she has provided valid personal information in the volume necessary for using the Website services. The fields which must be mandatorily filled in for the purpose of further provision of services by the Website bear a special mark, i.e. “*” symbol, and all other information can be provided at the Client’s own discretion.

7.1.3. the Client has been notified of the terms of this Confidentiality Policy and confirms that he or she agrees with it and accepts all rights and duties described in it. Familiarization with the terms of this Policy and putting a tick mark under the link to this Policy constitutes the Client’s written consent for collection, storage, processing and transfer of personal information provided by the Client to third parties.

7.1.4. The Administration does not verify the validity of the received (collected) information on the Clients except for cases when such verification is necessary for the purposes of fulfiling the obligations with regard to the Client and also in other cases which are not foreseen by the terms of this Confidentiality Policy, but are established by the norms of current laws of the Hong Kong.

7.1.5. by using the features of the Website, the Client agrees to receive periodic e-mail messages on updates of services provided by the Website.

7.2. The Client may receive personal information on himself or herself which the Client has provided to the Administration and also may transfer this data to other persons without any obstacles from the Administration which received such personal data.

7.3. The Client may object against certain types of processing of his or her personal data: direct marketing, processing for the purpose of protection of legal interests and fulfilment of some kind of tasks in the public interests / exercising authority powers and also against processing of such data for research or statistical purposes.

7.4. The Administration may provide links to websites and materials of third parties. The links to websites and materials of third parties are provided exclusively for information purposes.

8. Under this Confidentiality Policy, the “Client’s personal data” mean:

8.1. the data provided by the Client on his or her own while using the Website, including, but not limited to the name, contact phone number and/or electronic mail address, IP address, MAC address etc.

8.2. The data automatically transferred to the Website during its use though the software installed on the Client’s device, including IP address, cookie information, information from the Client’s browser (or another program to access the Website, time of access, address of requested page

8.3. The Administration uses the information of non-personal nature by using cookie files or by collecting information exchange flow for the purpose of improving the use of the Website, date and time of visiting this web-site etc. The examples of information exchange flow include:
- name of the domain and URL address which the Client uses to access the Internet;
- Internet protocol address (IP);
- type of the used web-browser;
- date and time of visiting this website etc.

8.4. Other information on the Client collected and/or provided under the terms of use of the Website.

9. Changes and removal of personal data

9.1. The Client may at any time change (upgrade, add) personal data provided by him or her or any part of it and also the parameters of its confidentiality by sending this information to the electronic mailbox of the Administration.

9.2. The Client may at any time remove personal information provided by him or her or any part of it in order to prevent its disclosure or transfer to third parties.

9.3. The Administration may remove the Client’s personal data if these data are not necessary anymore for the purposes that they were collected for and also if there are no grounds for storing such data.

10. Changes of Confidentiality Policy

10.1. Administration may introduce changes into this Confidentiality Policy. If any changes are introduced into the current version, then the date of the last update must be indicated. The new version of the Confidentiality Policy becomes effective after it is published on the Website unless otherwise is foreseen in the new version of the Confidentiality Policy. The current version of the Confidentiality Policy is accessible on the website at the address: [email protected]

10.2. This Confidentiality Policy and the relations between the Client and the Administration arising in connection with application of this Confidentiality Policy will be regulated by laws of the Hong Kong.

11. Contact information

11.1. All offers or questions with regard to this Confidentiality Policy must be notified to the Administration at the following e-mail address: [email protected]