Privacy Policy

Privacy Policy

The General Data Protection Regulation (GDPR) (EU) 2016/679 is a regulation safeguarding data protection and privacy for all individuals within the European Union and the European Economic Area.

Wise Wolves Digital Assets, incorporated under the laws of the Republic of Cyprus (the "Company"), is committed to upholding your confidentiality rights. This Data Privacy Policy (the "Policy") applies to:

  • Natural individuals who are existing or potential clients of the Company.
  • Those acting as authorized representatives of entities that are existing or potential clients/partners.
  • Directors, shareholders, or beneficial owners of entities that are existing or potential clients/partners. For the purpose of this Policy, such individuals will be referred to as "You/Your".

This Policy outlines the reasons and methods for the Company's data collection and processing. We urge you to carefully consider the following:

  1. Familiarize yourself with this Policy to gain insight into our perspectives and the practices we have in place. The information you provide is treated as confidential and will be disclosed only under the conditions specified in this Policy or as mandated by applicable law.
  2. By actions such as visiting our website, downloading content, filling out web forms, communicating with us in any form, or sharing any personal data with the Company, you unequivocally consent to the terms outlined in this Policy.
  3. If you wish to interact with the Company but do not fully agree with this Policy, or if you do not understand any part of it, you should refrain from disclosing or sharing personal data. Any communication or data sharing with the Company signifies your explicit agreement with this Data Privacy Policy.

1. DEFINITIONS

“Controller” – means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data.

“Personal Data” – means any information relating to an identified or identifiable natural person (name, ID, location and any other factors specific to the physical, genetic, mental, economic, cultural or social identity of that natural person); The information for the legal entities such as businesses, partnerships, trusts or other organizations provided by its authorized person, signatory, partner, trustee, executor or a like shall be considered as appropriate.

“Processor” – means a natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the controller;

“Processing” – means obtaining, recording, storing, holding, using or carrying out any operation or set of operations on the information or data including organization, adaptation or consultation on the information or data, as well as disclosure by transmission, dissemination or otherwise making available, or alimenting, combining, blocking, removing or destructing of the information or data;

“Sub-Processor” - any processor engaged by the data importer or by any other sub-processor of the data importer and who agrees to receive from the data importer or from any other sub-processor of the data importer personal data exclusively intended for the processing activities to be carried out on behalf of the data exporter after the transfer in accordance with the data exporter’s instructions.

2. GENERAL PROVISIONS

The Policy determines the procedure and conditions for lawful basis of Personal Data processing by the Company, the list of personal data which may be processed, categories of recipients of your personal data, your right and obligations as well as another important information which is relevant to the processing of Your personal data. This Policy shall be construed and interpreted in accordance with the GDPR and Law 125(I) of 2018 and other laws of the Republic of Cyprus. You and the Company hereto irrevocably submit to the exclusive jurisdiction of the courts of the Republic of Cyprus in connection to any dispute arising from the terms of this Policy.

3. LAWFUL BASIS OF PROCESSING

Under the GDPR, the Company serves as the Controller of your Personal Data. It determines, either alone or in conjunction with others, the primary reasons and legal bases for collecting and processing your Personal Data. The Company highlights the following purposes and legal grounds:

  • Consent: By initiating interactions or preliminary contractual relationships with the Company and providing your personal data, you aim to explore the potential for an agreement. This also encompasses the on-boarding procedure, KYC, and KYT. You grant consent for the Company to process your Personal Data as described herein.
  • Performance of the Contract: Collecting and processing your Personal Data is essential for establishing a business relationship with you to offer:-  Services as licensed by the Company; and Other relevant services mutually agreed upon by you and the Company.
  • Legal Compliance: The Company processes personal data based on its regulatory obligations. Such compliance demands the Company to identify and verify information related to you and associated individuals, implement anti-money laundering measures, retain and collect Personal Data for specific durations, and disclose such data to regulatory authorities, among other duties.
  • Legitimate Interests: The Company may collect and process your Personal Data to safeguard its operational environment, so long as these interests do not override your rights, interests, and fundamental freedoms. The term "Legitimate Interests" encapsulates various reasons for data collection and processing not explicitly listed under other headings. Examples include fraud or financial crime prevention, service enhancement, internal administrative data transfers between group entities, and ensuring network or information security

4. WHAT INFORMATION WE COLLECT FROM YOU

The Company is required to collect the following Personal Data:

  • Personal information (name, address, email, telephone number, mobile number, temporary residential address, employment address, name of employer, personal status, i.e. identity card number, passport number, marital status, occupation, country of taxation and other);
  • Financial information (income, source and size of wealth and other);
  • Recording of the call conversations between You and the Company;
  • Your photos, pictures and/or images which were provided by You directly and/or indirectly in written and/or digital and/or during visit the Company’s office via a CCTV.

The Company is also required to collect and keep all the documents which confirm the accuracy of provided personal and financial information (passport, ID, Utility Bills, Bank Statements, Internal passports, Bank References, CVs or any other information which may be requested by the Company in order to comply with the applicable law).

The Company will do its utmost to ensure that all Personal Data we collect is adequate, relevant and limited to what is necessary in relation to the purposes for which they are collected and processed.

In cases where we receive data which was not requested or where information was unintentionally revealed, and the Company does not intend to use it for the purposes of processing or where data was received by mistake, The Company shall notify You that such data was received and destroy it, unless You instruct otherwise.

For the Company services and communication with You, we do not require the sharing of special category data or sensitive personal data (such as health data, political beliefs, etc.).

5. CATEGORIES OF RECIPIENTS OF YOUR PERSONAL DATA

Your Personal Data in the course of performing our contractual and statutory obligations may be disclosed to the following Processors, Sub-Processors and Controllers:

  • Supervisory and other regulatory and public authorities, including government bodies; 
  • External auditors, lawyers, agents, consultants and other professional advisors subject to confidentiality agreements;
  • Employees of the Company;
  • Subsidiaries and Affiliated companies within the Wise Wolves Group Ltd.

Unless expressly declared by You, the Personal Data collected and kept by the Company will not be disclosed to any third party other than the above-mentioned recipients.

 

6. PERSONAL DATA RETENTION TIME

In accordance with the applicbale laws and regulations of the Republic of Cyprus, The Company is obliged to keep and update Your Personal Data for as long as the Company provides its services to You. Upon the termination of the business relationship, Your Personal Data shall be kept for a minimum of five [5] years. After the legally required period lapses, Your Personal Data shall be destroyed.

However, the Company will be required to keep Your Personal Data for a longer period of time if it is a requirement of the law, competent authorities or other regulations (such as pending legal proceedings or investigations).

7. RIGHTS AND OBLIGATIONS

You have the following rights in relation to the Personal Data provided by You to the Company:

  • The right of access to or have a copy of Personal Data as well as some supplementary information on that data;
  • The right to request rectification of incorrect data concerning You;
  • The right for data portability if it should become relevant;
  • The right to request, on legitimate grounds the erasure of Your Personal Data;
  • The right to object the processing of Personal Data based on the Company legitimate interests and/or processing of Personal Data for direct marketing purposes;
  • The right to restrict processing of Your Personal Data;
  • The right to withdraw consent, by written notice, if the process of Your data is based on consent. Please note that this will not affect the lawfulness of processing based on consent before it was withdrawn by You;

The above rights can be exercised by sending the relevant email to: GDPR@wise-wolves.com.

Furthermore, You have a right to lodge a complaint regarding the processing of Your Personal Data by the Company by sending a complaint to GDPR@wise-wolves.com and the Company’s responsible officer will investigate the matter. In case You are not satisfied with the Company’s response or if You feel that Your concerns have not adequately addressed by the Company, You have the right to file a complaint with the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus.

8. SAFEGUARDING

The Company, the processors on its behalf and its affiliates / fulfilment assistants undertake to apply appropriate technical and organizational measures to, as far as possible, better protect your personal data against accidental or unlawful deletion or loss, alteration, illegal disclosure or access to them and generally their illegal processing (including remote access) as well as to ensure the possibility of restoring availability and access to them.

These measures aim to ensure a level of security that corresponds to the risk that your specific data may undergo, always taking into account the type and criticality of this data, the technical capabilities of our company, the development of technology, the cost of implementation and the nature, scope, context and purposes of any particular processing, while implementing procedures to regularly test, assess and evaluate the effectiveness of these technical and organizational measures.

9. PERSONAL DATA BREACH NOTIFICATION

In case the Company becomes aware of a Personal Data breach which may result in high risk to Your rights and freedoms, the Company shall without undue delay notify You of such breach and provide the following information:

  • Type of Personal Data affected;
  • The nature of breach;
  • Steps the Company shall take in order to minimize any damage.

You should inform the Company immediately by sending an email to GDPR@wise-wolves.com of any possible damage, loss or misuse such breach may cause to You in order to assist the Company assess all possible solutions promptly.

10. MISCELLANEOUS

This Policy is valid for an indefinite period. The Company reserves the right to make changes to this Policy by posting a new version of the Policy on the website of the Company. In this case, such changes come into force from the date of posting the relevant information on the site. Before entering into a business relationship with the Company, You undertake to contact the site for information about changes and additions to this Policy, as well as other relevant Terms and Conditions.

If one or more of the provisions of the Policy are or become invalid due to amendments to the current legislation, then this is not a basis for suspending the validity of the remaining provisions of the Policy. Invalid provisions must be replaced by legally permissible provisions that are close in meaning to the replaced ones.

11. CONTACT DETAILS

Controller:

Legal Name:

Wise Wolves DA

Registration number:

HE 422111

Address:

Spyrou Kyprianou 61, Mesa Geitonia, 4003, Limassol, Cyprus

 

Data Protection Officer:

Contact information:

gdpr@wise-wolves.digital

 

 

Governmental Authority:

Office of the Commissioner for Personal Data Protection

Office address:

Iasonos 1, 1082 Nicosia, Cyprus

Postal address:

P.O.Box 23378, 1682 Nicosia, Cyprus

Email:

commissionerdataprotection.gov.cy 

This document is only available in English. Any translated copies are not valid.

Customer Support Team

Wise Wolves DA aims to offer to its customers services of a highest standards meeting our customers’ needs. We realise that sometimes our services or products might not meet your expectations despite our best intentions. Please consider to contact our Customer Support Team for help or clarifications you may need.

If for any reason you are not fully satisfied with any aspect of our services, please let us know as soon as possible. Your suggestions and complaints are valuable for us since they help us to improve our services.

How you can submit your suggestion or complaint

You can submit your suggestion or complaint by:

+357 25 355 234 (working days, 09:00–18:00)
support@wise-wolves.digital
Mail to our PostBox: Spyrou Kyprianou 61, Mesa Geitonia, 4003, Limassol, Cyprus
Visit our Office: Spyrou Kyprianou 61, Mesa Geitonia, 4003, Limassol, Cyprus. See "Find us on the Cyprus map"

We will carefully investigate your suggestion or complaint and return to you with the outcome. At the same time, we will also take steps to improve and/or to ensure that similar problems are avoided in the future.

If you have submitted a complaint kindly be informed in regards of the basic steps of Complaints Management Procedure we follow.

Complaints Management Procedure

Not later than 5 working days upon receiving your complaint we will send you a Notice of Receipt of Complaint with a Reference Number for your complaint. Please use this number in future communications.

Your complaint will be forwarded to the Complaints Officer for further investigation. Depending on the nature and particulars of the complaint, we will take steps to resolve the issue and propose a solution to you as soon as possible.

Certain complaints may take more time than 15 working days to be investigated and resolved. In such a case we will keep you updated on what actions we are taking, and we will indicate when the investigation is likely to be completed.

Once a complaint has been investigated, we will contact you via your chosen channel of communication providing the proposed solution.

Where appropriate and without prejudice to the right to bring proceeding before a court in accordance with the law of the Republic of Cyprus, if you are not satisfied with our proposed solution and/or the actions we took to resolve your complaint, you may use the ADR (Alternative Dispute Resolution) procedures by filing a complaint to one of the Approved Alternative Dispute Settlement Bodies (Certified ADR providers/ Certified ADR entities), in accordance with the provisions of the ADR. The list of ADR providers in Cyprus is published on the internet portal of Consumer Protection Service, which is the Competent Authority by the Alternative Consumers Dispute Resolution Law of 2017 (N.85(I)/2017) at the following link.

For any other cases, you are advised to take legal advice for the resolution of the dispute.

Taking into consideration that the Central Bank of Cyprus is designated as the competent supervisory authority of the Republic of Cyprus, any breach of relevant EU laws including EU Directives which have been transposed into national law can be reported to the Central Bank of Cyprus. It should be noted that the Central Bank of Cyprus does not investigate individual consumer complaints.

Wise Wolves DA Complaint Process Workflow