Data and Privacy Policy

Wallbit provides a technological platform between its "Users" and its "Strategic Partners" (which include Treasury Prime, Bangor Savings Bank and Atomic Invest LLC) to access certain financial services.

This privacy policy (the "Privacy and Data Use Policy" or the "Policy" or "Privacy Policy") applies to all Users who use Wallbit's Services or Platform.

By using our Services, you agree to the Policy. We may update this Policy from time to time, and your continued use of our Services constitutes acceptance of this Policy. If you do not agree with the Policy, do not use (or continue to use) the Services (as defined in the Terms and Conditions).

As a technology company in the financial services and technology sector, privacy and security are crucial aspects of our Services, as outlined in this document. To that end, we have developed this Privacy Policy to explain how we may collect, retain, process, share, and transfer your information. This Policy includes provisions from Wallbit and our partners, in their roles as Strategic Partners.

1.1. In this Policy, "Services" refer to any product, service, content, features, technologies, or functions made available to you by Wallbit, in conjunction with our Strategic Partners, as a provider of technology services offered through the Platform (as defined in the Terms and Conditions).

1.2. We may, at our sole discretion, change or modify this Policy, and any policies or agreements incorporated into it, at any time, and such changes or modifications will become effective immediately upon their posting on the Platform. No revision or update will apply to a dispute of which we had actual knowledge before the date of publication of the changes or modifications. We will notify you of such changes or modifications on the Platform, and your use of the Services after such changes or modifications have been posted (indicated by a "Last Revised" date) will constitute your acceptance of the Policy as last revised. If you do not agree with the Policy in its last revised form, do not use (or continue to use) the Services.

2.1. This Privacy Policy applies to your information when you use the Platform or use the Services and does not apply to websites or online services that we do not own or control.

2.2. Information provided to third parties, such as our Strategic Partners, will be governed by their respective privacy policies. We encourage you to review the privacy policies or notices of the Platform or other third parties for information about their practices.

3.1. We collect public and non-public information (i) when you visit our website; (ii) when you communicate with us through our customer support channels; (iii) when you request or sign up to use any of our Services through the Platform; (iv) through third-party service providers and other sources; (v) through online research on social networks and websites that may not be publicly available (such as professional networking platforms or subscription-based databases); and (vi) when you use any of our Services directly or through a Platform.

3.2. As a third-party service provider, we collect data on behalf of the Strategic Partners or affiliates to comply with applicable laws and regulations.

4.1. The information we collect may vary depending on the Service we will provide to you and your use of the Services through the Platform.

4.2. We may collect the following information about individuals or companies ("Data"):

4.2.1. Individual Information: name or alias, physical address, work address, phone number, email address, IP address, date of birth, gender, CUIL, CUIT or other tax identification number, results of sanctions screening, government identification, identification photo, selfie or video authorization, images of your face on your identification document (e.g., government-issued ID card), your biometric facial identifiers, and any additional information you may provide or that we may request additionally;

4.2.2. Company Information: legal name of the entity or alias, including "doing business as" names, physical address, phone number, type of legal entity, industry, organizational documents (e.g., articles of incorporation and bylaws), employer identification number, or other information related to authorized signatories or beneficial owners, which may include individual information as mentioned above or additional information we may request you to provide;

4.2.3. External Bank Account Information: external financial institution name, account name, account type, branch number, account number, routing number, international bank account number ("IBAN"), information, data, passwords, authentication questions, materials, or other content, transaction information, and available balance;

4.2.4. Financial Data from your account with us and our affiliated bank: transactions and transaction history, including, among others, ACH transactions, bank transfers, and card transactions, account balance, card data, debit amounts, linked bank accounts, salary, and other income, sources of wealth, and other assets;

4.2.5. Background Check Data: background check information, including credit and criminal checks, support and review investigations, to the extent required or allowed by local law;

4.2.6. Sender or Receiver Data: when you send or request money through the Platform, we may collect data such as the name, postal address, phone number, IP address, date of birth, and financial account information of the recipient or sender of the funds. The scope of data required about a recipient or sender may vary depending on the Services you are using to send or request money;

4.2.7. Third-Party Sources: we may obtain information from third-party sources, such as the Platform, merchants, fund recipients and senders, data providers, identity verification providers, and credit agencies, where permitted by law.

4.2.8. Digital Identity Information:

4.2.8.1. Service Metadata: when you interact with the Service, metadata is generated that provides additional context about how you interact with the services.

4.2.8.2. Log Data: we may automatically collect information about your visit to the Wallbit website or your use of the Platform, including IP addresses and associated information, the website visited before using the Wallbit website, browser type and settings, date and time of access and use of the Service, information about browser settings and plugins, language preferences, and any other metadata that may be useful.

4.2.8.3. Device Information: the "fingerprint" of your device (e.g., hardware model, operating system and version, unique device identifiers, and mobile network information) when you access our website or use a service through a platform.

4.2.8.4. Location Information: we may receive information from you to help approximate your location, such as using an IP address received from your browser to determine an approximate location. Additionally, we may also collect location information from devices in accordance with the consent process provided by your device.

5.1. Collected Data will be retained to comply with our legal and/or regulatory obligations, as well as for business purposes. Data will be retained even for periods exceeding those required by law, to the extent not prohibited.

5.2. Even when you stop using the Services or close your Account, we reserve the right to retain and access Data as provided in this Policy, until an explicit request of the User to delete their Account data.

5.3. All data is stored encrypted in the Wallbit tech ecosystems.

6.1. We use the Data and information to operate, improve, and protect the Services we provide and to develop new Services.

6.2. The collected information is used for:

6.2.1. Providing the Services, fulfilling obligations under our agreements, and conducting related business functions, including data and transaction processing, performing credit checks, handling user inquiries, and managing relationships;

6.2.2. Developing, enhancing, modifying, adding to, and further developing our Services;

6.2.3. Complying with applicable legal and regulatory obligations relating to the Services and our associated bank(s), including, among others, "know your customer" obligations based on applicable anti-money laundering and terrorism financing requirements, economic and trade sanctions, customer due diligence, suspicious activity reporting, foreign exchange, and international trade, tax reporting, and other applicable laws, regulations, ordinances, and obligations or requirements;

6.2.4. Confirming an individual's authority as a representative or agent of a user;

6.2.5. Keeping records and managing the business in accordance with market practices;

6.2.6. Verifying your identity, the credibility of the provided data, and fraud prevention;

6.2.7. Protecting you, our Platforms, or our Strategic Partners from fraud, malicious activity, and other privacy and security-related issues;

6.2.8. Providing customer support or assistance related to our Services or the Platform;

6.2.9. Sending technical notices, updates, security alerts, and administrative messages;

6.2.10. Investigating any misuse of our Services or applications or our Platform, including criminal activities or unauthorized access to our Services;

6.2.11. Any other purpose with your consent.

6.3. We may use raw or aggregated and anonymized data for the purposes outlined in this Policy.

6.4. We use machine learning and facial recognition to verify the legitimacy of your identification documents, check the accuracy and credibility of the information you provide, and prevent fraud, including comparing biometric data with data obtained previously or separately. Like with all data, Wallbit does not sell or rent the image, likeness, or vector to anyone, including vendors or other third parties, and do not use your data for commercial purposes other than identity verification, loss mitigation, and compliance with regulations.

7.1. Wallbit takes your privacy seriously. We do not sell or rent your information to marketers or third parties.

7.2. We share your information with third parties as described in this Policy. We may share some of your information:

7.2.1. With the Platform you are using to access our Services in order to provide services to you and provide customer service. You understand that the Platform may have access to all Data;

7.2.2. With our associated bank(s) to comply with regulations and the bank's regulatory obligations and know-your-customer requirements. You understand that the associated bank may have access to all data and the bank's data privacy policy or notice will apply;

7.2.3. For our everyday business purposes, such as processing your transactions, maintaining your account(s), or reporting to credit agencies;

7.2.4. With other companies that provide services to us, such as identity verification service providers, fraud prevention service providers, credit agencies, or collection agencies;

7.2.5. With other parties in transactions when you use the Services, such as other users, merchants, and their service providers. We may share your information with other parties involved in processing your transactions. This may include information necessary to facilitate the transaction, information to help other participants resolve disputes, and detect and prevent fraud;

7.2.6. With information technology providers or other service providers worldwide that act on our instructions in relation to the processing of certain data ("Vendors"). Vendors will be subject to contractual obligations to apply appropriate technical and organizational security measures to safeguard the information and process the information only as instructed;

7.2.7. With card networks if our associated bank(s) or third parties with whom we have agreements issue you a card. You understand that the card network may have access to all Data and the applicable card network's data privacy policy or notice will apply;

7.2.8. To independent external auditors or other service providers worldwide. Such service providers will be subject to necessary contractual obligations regarding the protection and processing of such data;

7.2.9. In connection with a change of ownership or control of all or part of our business (such as a merger, acquisition, reorganization, or bankruptcy);

7.2.10. To support our audit, compliance, and corporate governance functions; and

7.2.11. With your consent or direction.

7.3. Subject to applicable law, we may disclose the Data as required or permitted by law or applicable regulations, including laws and regulations of the United States and other countries, or if we believe in good faith that such action is necessary to (a) comply with a legal obligation or in response to a request from law enforcement or other public authorities in any place where Wallbit or our Strategic Partners may do business; (b) protect and defend Wallbit and/or our Strategic Partners rights or property; (c) act in urgent circumstances to protect the personal safety of users, Platform’s or our Strategic Partners’ contractors/employees, or others; or (d) protect against any legal liability. Additionally, our Strategic Partners may share your data with U.S. regulatory agencies and other self-regulatory bodies to which we are subject, wherever our Strategic Partners do business.

8.1. Wallbit takes commercially reasonable steps to help protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. In addition, we implement policies designed to protect the confidentiality and security of your non-public personal information.

8.2. Unless otherwise specified in this Policy, our Strategic Partners limit access to your information to employees who have a business reason to know such information and implement security practices and procedures designed to protect the confidentiality and security of such information and prevent its unlawful disclosure in accordance with its policies.

9.1. This Website and the Services are not directed at children under the age of 13. We do not knowingly collect data from children under 13. If a parent or guardian becomes aware that their child has provided us with Data without their consent, they should contact us using the information below ("Contact").

Contact Wallbit LLC, 2261 Market Street #5062, San Francisco, CA 94114, or email compliance@wallbit.io