Last revised on July 12, 2023
We respect and value your privacy as well as the integrity of the information you have provided and/or permitted us to collect. Thus, we endeavor to follow industry standards to ensure the security and confidentiality of your Personal Information (as defined below) when you access the Fabwelt Platform or use the Fabwelt Services.
Information provided by you when registering to the Fabwelt Platform
When you first sign up to use the Fabwelt Services by opening a Fabwelt Account, you may be required to provide with us your real name, date of birth, nationality, home address, email address, signature and other information which can be used to verify your identity. Generally, we will not collect nor process “Sensitive Information” (defined in GDPR as “special categories of personal data”), such as racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data that uniquely identify specific persons, or any information concerning health or sexual orientation. However, if you are using biometric authentication methods to sign into your Fabwelt Account and so are required to provide us with your fingerprint data or facial recognition data we shall need to seek your explicit consent to process such biometric data to comply with our legal obligations.
Information collected by us for compliance purposes
In order to comply with domestic and international industry standards, government rules and regulations, in particular the Anti-Money Laundering (AML) regulations, Know Your Customer (KYC) rules and Counter-Terrorist Financing (CTF) regulations, the Fabwelt Operators and Third Party Service Providers are required to collect and retain your Personal Information from identification documents, such as your passport, national identification card, driver’s license, tax identification and visa. Other documents which we may use are, including but not limited to, your proof of address, source of funds declaration, purpose and source of wealth.
Information collected by us during your usage of the Fabwelt Services
When you engage or use the Fabwelt Services, we will monitor and track your Personal Information in relation to your usage of the Fabwelt Services such as your IP address, phone number, blockchain addresses, the type of device you use to access the Fabwelt Platform, device information, operating system and hardware settings, browser type and network operator. This information shall either be directly obtained by the Fabwelt Operators or through Third Party Service Providers.
We collect this type of information to ensure that our interface and/or the Fabwelt Platform is seamlessly accessible for all permitted Users around the world and in order to provide you with the Fabwelt Services.
Communication of Personal Information
You hereby agree that we are entitled to collect and use the Personal Information you have provided on the Fabwelt Platform or generated through your usage of the Fabwelt Services for the purpose of communicating with you through messages, requests, emails, telephone conversions, voicemails, live chats. Such information will include file attachments in connection with your transactions on the Fabwelt Platform, or any other information related to your contact with the Fabwelt Operators.
Where we ask you for your Personal Information which you are obliged to provide to us you may decline to provide it to us but if you do so we may not be able to enter into or to perform our contract with you to provide the Fabwelt Services and we may have to terminate our relationship. For other Personal Information which you may not be under an obligation to provide to us but which we seek from you, if you do not provide it then we may not be able to properly perform our arrangements with you.
Information collected by the third-party
We shall collect your Personal Information from third parties as required or to the extent permitted under any Applicable Laws. Information from the third-party sources shall include, but not be limited to, public databases, credit bureaus, ID verification partners, blockchain data, marketing partners and resellers, advertising partners, and analytics providers.
Anonymised and Aggregated Data
Your Personal Information shall be made available to the Fabwelt Operators, our affiliates and service providers, and/or within our group of companies. This will include, but not be limited to, the employees and/or any persons or Third Party Service Providers working with the Fabwelt Operators who are responsible for using and protecting your Personal Information. Where it is necessary (e.g., to protect the vital interest of the users or other natural persons, to fulfil the purpose of public interest, or to pursue our legitimate interest without overriding your rights and freedoms), we may use and process your Personal Information without obtaining your consent.
We use and process your Personal Information for the following purposes or in the following manners:
To provide the Fabwelt Services
We use your Personal Information, either collected or delivered, in order to maintain and provide efficient Fabwelt Services in accordance with our contractual obligations owed to you (including, but not limited to, processing transactions) and, for our and your legitimate interests, to improve the efficiency of day-to-day Fabwelt Services and, to comply with our legal obligations, to verify your identity. We use IP addresses and unique identifiers stored in your device’s cookies to help us authenticate your identity and activities and provide the Fabwelt Services.
To protect Users as part of the provision of Fabwelt Services
In order to comply with our legal obligations we use the information collected to protect the Fabwelt Platform, Users’ Fabwelt Accounts and archives. We also use IP addresses and cookies to detect any suspicious activities and to protect against automated abuse, such as spam, phishing and Distributed Denial of Service (DDoS) attacks. To comply with the relevant legal rules and regulations For our legitimate interests and to comply with our legal obligations, we shall use the Personal Information in compliance with our legal obligations, global and local industry standards, government requests and our AML/KYC/CTF procedures.
For measurement, research and development purposes
For our and your legitimate interests, we actively measure and analyse your Personal Information to understand the way you use and interact with the Fabwelt Services. This review is continuously conducted by our operational teams to continuously improve the Fabwelt Platform’s performance and to resolve issues with User experience.
In addition for the same reasons, we use such information to customise, measure and improve the Fabwelt Services, our administration, the content and layout of the Fabwelt Platform, and to develop new services for you.
For communication purposes
We use your Personal Information, collected or derived from your communication devices or your email address, to interact with you directly, to provide you with necessary support and/or to keep you informed of logins, transactions, the Fabwelt Account security details, as well as other aspects. All direct communications shall be appropriately maintained with the Fabwelt Operators or Third Party Service Providers designated to be reviewed for accuracy, retained as evidence, or used to perform other statutory
To enforce the Terms
Personal Information is also used, for our legitimate interests, to continuously and actively enforce our Terms among our Users. Activities in this regard include, but are not limited to, reviewing, investigating and preventing any potentially prohibited or illegal activities that may violate preceding provisions, or disclose relevant information to third parties in accordance therewith. In light of this, we reserve the right to suspend or terminate any of the Fabwelt Services to any Users who are found to be engaged in any activities that violate our Terms.
For marketing and advertising
For our legitimate interests, we may share your Personal Information with our marketing partners for the purposes of targeting, modelling and/or identifying analytics as well as marketing and advertising services which are the same as or similar to the Fabwelt Services. In any marketing communications which are sent to you, you will be advised as to how you can opt-out of receiving any further marketing communications from us or such partners.
We shall take great care in implementing and maintaining the security of the Fabwelt Services as well as that of your Personal Information. We employ procedures and policies that incorporate industry best practices to ensure the integrity of your Personal Information and to prevent instances of unauthorised use.
The Fabwelt Platform’s security is fully integrated into Amazon Web Services, covering all aspects of security such as identity management, connection security, application security and database security for User’s interactions with the Fabwelt Platform.
Please note that it is impossible to fully guarantee the security of your Personal Information. While we take reasonable steps to safeguard your Personal Information, we disclaim any liability for the acts committed by those who gain unauthorised access or abuse your information and services unless caused by our gross negligence. Thus, you are recommended to understand this responsibility and to independently take the necessary safety precautions to protect your Personal Information, in particular your credential information, such as your username and password. You hereby agree that we shall not be liable for any information leakage and/or other losses not caused by our gross negligence, including but not limited to, hacker attacks, power interruptions or unavoidable technical failures.
We may be required by Applicable Laws to retain certain information, including Personal Information of Users, Users’ profiles, identification verification materials, information relevant to AML/KYC/CTF procedures, account information, account agreements, and other agreements between us and third-parties, account statements, and other records.
Such records shall generally be retained as required by law for the minimum amount of time necessary to accomplish the purpose for which it is collected and thereafter no longer than is permitted under Fabwelt Operators’ Information Retention Policy. However, even after you have deactivated your Fabwelt Account, we may retain copies of information about you and any transactions or services which you may have participated in for a period of time in accordance with the applicable laws, statute of limitations or as we believe as reasonably necessary to comply with the applicable laws, regulations, legal procedures or governmental requests in order to detect or prevent fraud, outstanding fees, resolve disputes, address problems with the Fabwelt Services, assist with investigations, enforce any of our Terms or other applicable agreements or policies, or to take any other actions consistent with Applicable Laws.
We may share, transfer, disclose, or allow access to your Personal Information to the following third parties for the purposes described below:
party websites to purchase products and services, and you agree that we shall have no liability whatsoever concerning such third-party websites and your usage of them.
Under certain circumstances, you have the rights under the data protection laws in relation to your Personal Information. These rights include but are not limited to the following:
Right to be informed
Right of access
You have the right to obtain access to the Personal Information we hold about you and specific information regarding our processing of this information.
Right to rectify
You have the right to require us to rectify your Personal Information that is inaccurate. You can check your account details at any time by signing into your Fabwelt Account and clicking the profile.
Right to erasure
You may require us to have your Personal Information deleted from our records where certain conditions are met.
Right to data portability
You reserve the right to request to transfer a machine-readable copy of your Personal Information to you or the third-party of your choice. We shall provide you, or the third-party, your Personal Information in a machine-readable format. This right only applies to Personal Information you have provided to us to use.
Right to restrict processing
You may request us to restrict or suppress the processing of your Personal Information under certain circumstances as follows:
Right to object
You may object to our reliance on our legitimate interests as the basis of us processing your Personal Information which may impact your personal rights. You may also object to our processing of your Personal Information for any direct marketing purposes.
Right to withdraw consent (“Opt-out”)
You reserve the right to withdraw your consent at any time where we are relying on it to process your Personal Information.Withdrawing your consent does not affect the lawfulness of our processing of your Personal Information prior to withdrawing and we are entitled to continue processing your Personal Information where we have other legal bases for doing so. If you wish to exercise these rights as aforementioned, please inform and contact us via the Fabwelt Platform as set out below.
Right to lodge a complaint with a privacy regulator
You have the right to make a complaint to your local privacy regulator. If you wish to make a complaint, we would ask that you contact us before you contact the regulator so that we may see if the issue can be resolved first. You can also contact your local privacy regulator if you have any concerns regarding your rights under local law.
The Fabwelt Services are not designed for the individuals who are under the age of 18 or under the legal age to provide consent under the applicable laws of the country or jurisdiction where you are using the Fabwelt Services.
If you are not over 18 or of the legal age of your country, you shall not provide any Personal Information to us, or to engage in the Fabwelt Services. We reserve the right to access and verify any Personal Information collected from you. If we become aware that you are under 18 or under the legal age and you have already shared your Personal Information with us, we shall then discard such information and terminate your Fabwelt Account immediately.
We cannot guarantee that any losses, misuses, unauthorised accession, or alteration of your Personal Information shall not occur. You hereby agree that you play a vital role in protecting your Personal Information, including your credentials. When registering with the Fabwelt Services, you are strongly recommended to choose a password with the sufficient length and complexity and to not reveal this password to any third parties or unauthorised persons. Also, you agree that you shall immediately notify us if you become aware that unauthorised persons have accessed or might access your Fabwelt Account.