Privacy Policy

Last updated: 14 January 2020

About this privacy policy

This document sets out the policy of WalletVN (referred to as "us", "we", or "our") operating WalletVN relating to the collection, handling, use, privacy and disclosure of your personal information (“Privacy Policy”). It also deals with how you can complain about a breach of privacy laws, how you can access the personal information we hold about you and how to have that information corrected.

This Privacy Policy applies to all your dealings with us regarding the collection, use, and disclosure of personal data when you use the site and access the services provided on the site (Service) and the choices you have associated with that data.

You accept this Privacy Policy and expressly consent to our collection, use and disclosure of your personal information as described in this Privacy Policy by using our website, completing any application forms or conducting any other business with us.

We are committed to protecting the privacy of the personal information we collect and receive. We are bound by the Australian Privacy Principles (APP) contained in the Privacy Act 1988 (Cth).

Information Collection and Use

We will collect your personal information by lawful and fair means directly from you unless it is unreasonable or impracticable to do so. We use your data to provide and improve the Service.

By using the Service, you agree to the collection and use of information in accordance with this policy.

Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and we consider reasonably necessary for our functions and activities ("Personal Data"). Personally identifiable information may include, but is not limited to:

Name, age, and contact details (including phone number, postal address, facsimile and email)
Identification information (e.g. passport number, driver’s licence number)
Financial information
Billing information (e.g. bank account numbers, digital currency account information)
Cookies and usage data (e.g. IP address, device information, operating system, web log information)

How We Collect Your Personal Information

We collect your personal information in a variety of ways, including but not limited to:

when you visit the site;
when you register on the site;
when you fill out a form;
by electronic systems such as applications; and
in connection with other activities, Services, features or resources we make available on the site.

Unsolicited Personal Information

Unsolicited personal information is personal information we receive that we have taken no active steps to collect.

We may keep records of unsolicited personal information if the information is reasonably necessary for one or more of the Services. If not, it is our policy to destroy the unsolicited information or ensure that the information is de-identified, provided it is lawful and reasonable to do so.

Usage Data

We may also collect information about how the Service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

We use cookies and similar tracking technologies to track activity on our Service and hold certain information. Cookies are files containing a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies, including beacons, tags and scripts, may also be used to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of cookies we use:

Session Cookies: We use Session Cookies to operate our Service.
Preference Cookies: We use Preference Cookies to remember your preferences and various settings.
Security Cookies: We use Security Cookies for security purposes.

Use of Data

WalletVN uses the collected data for various purposes:

To provide and maintain the Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer care and support
To provide analysis or valuable information so that we can improve the Service
To monitor the usage of the Service
To detect, prevent and address technical issues

We may also use your information to advertise and send you offers, updates, events and information about products or services that we believe may be of interest to you. We will always give you the option not to receive these communications, and you may unsubscribe at any time by notifying us.

Transfer of Data

Your information, including Personal Data, may be disclosed, used, transferred to and maintained on computers located outside your state, province, country or other governmental jurisdiction, where the data protection laws may differ from those in your jurisdiction. This may occur if:

our offices or related entities are overseas;
we outsource certain activities overseas;
transactions, information, Services or products have an overseas connection; or
our computer systems, including IT services, are overseas.

You consent to the collection, use, storage and processing of your personal information outside Australia as set out in this Privacy Policy.

If you are located outside Australia and choose to provide information to us, please note that we transfer the data, including Personal Data, to Australia and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. WalletVN will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. No transfer of your Personal Data will take place to an organisation or country unless adequate controls are in place, including controls relating to the security of your data and other personal information.

We cannot guarantee that personal information will be protected against unauthorised access or misuse and we do not accept liability for the improper actions of unauthorised third parties. We will retain your personal information for as long as necessary to fulfil our obligations to you, protect our legal interests, comply with Australian law, or as otherwise stated when we collected your information.

Disclosure of Data and Legal Requirements

WalletVN may disclose your Personal Data in the good-faith belief that such action is necessary to:

comply with a legal obligation;
protect and defend the rights or property of WalletVN;
prevent or investigate possible wrongdoing in connection with the Service;
protect the personal safety of users of the Service or the public; or
protect against legal liability.

We may use and disclose personal information for related purposes to third parties. Types of organisations to which we may disclose your information include:

any of our related companies;
financial institutions, payment processors or identity service providers;
anyone to whom our assets or business, or any part of it, is transferred;
individuals appointed by a government responsible for the investigation and resolution of disputes or complaints concerning your use of our services;
parties where you have otherwise consented;
parties where disclosure is otherwise required or authorised by law;
government bodies such as the ATO, ASIC, Australian Prudential Regulation Authority, police or courts, as required by law;
professional or government organisations; and
our contracted service providers and third-party service providers on the site who are bound by similar confidentiality obligations, including consultants, marketers, information technology service providers, dealers, agents and professional advisers.

Security of Data

The security of your data is important to us. However, no method of transmission over the internet or method of electronic storage is completely secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security and do not accept liability for any breach of security.

Service Providers

We may employ third-party companies and individuals to facilitate our Service ("Service Providers"), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose, and you consent to this.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service, and you consent to this.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses collected data to track and monitor the use of our Service. This data may be shared with other Google services. Google may use the collected data to contextualise and personalise advertisements within its advertising network.

You can opt out of making your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript from sharing information with Google Analytics about visit activity.

For more information about Google’s privacy practices, visit the Google Privacy & Terms page.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility or liability for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and are aware that your child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from a child without verification of parental consent, we will take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of changes by posting the new Privacy Policy on this page. We may also notify you by email and/or a prominent notice on our Service before the change becomes effective, and we will update the "Last updated" date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for changes. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Changes are effective when posted on this page.

Resolving Your Privacy Issues

If you have concerns about how we have collected or managed your information, please contact our Privacy Officer. For general privacy information, or if your concerns are not resolved to your satisfaction, you may contact the Office of the Australian Information Commissioner through www.oaic.gov.au or by telephone on 1300 363 992.

Our Privacy Officer

Our Privacy Officer can be contacted by email at privacy@walletvn.com.

Accessing and Updating Your Personal Information

You are entitled to access Personal Information that we hold about you. If you request access, in ordinary circumstances we will give you full access to your Personal Information. Depending on the nature of the request, we may charge a reasonable fee for providing access, but the fee will not be excessive.

There may be legal or administrative reasons to deny access. If we refuse your request to access your Personal Information, we will provide reasons for the refusal where required by law.