Last updated: July 10, 2018
Personal data and the information we collect
For us to be able to provide you with our services, we must collect personal information. It is either by law that we are required to obtain certain information from users or it is relevant for specified purposes. Information that you provide to us that is not required is classed as voluntary. Users are free to choose whether to provide us with voluntary information that may be requested, but without this information we may not be able to serve you as effectively or offer and provide all the services available on the Commwea Marketplace and associated services.
Below is the type of information we may collect
Personal Identification Information: Full name, age, date of birth, nationality, gender, utility bills, photographs, phone number, signature, home address, and/or email.
Formal Identification Information: Tax ID number, passport number, driver’s license details, photograph identification cards, national identity card details, and/or visa information.
Employment Information: Office location and job title.
Transaction Information: Information about the transactions you make on the Commwea Marketplace and associated services, such as the recipient, your name, the amount, and/or time of transaction.
Cookies and how we use them
How we use your personal information
Providing a secure, frictionless and enjoyable experience is our primary reason for collecting users’ personal information. We may use your data to provide customer service, engage in marketing activities and to ensure quality control, including network and information security. We may also use personal information for research and development purposes, aiming to enhance user experience.
User information from third parties
In some cases, as required or permitted by applicable law, we may obtain personal information from third parties sources. These sources include but are not limited to public databases. Identification (ID) verification partners, marketing partners and social media platforms. Third parties such as ID verification partners will only receive your personal information to prevent fraud. Through such third parties, we can confirm your identity by comparing all the information we have obtained both from you and the third parties.
Your information may be shared with third party service providers, under partnership or contract who assist with some aspects of our operations, including but not limited to financial institutions, marketing, technical and technology services. Such service providers are prohibited from using your information outside of the instructed guidelines and/or selling your personal information.
In some circumstances, when we are compelled by a court order, subpoena or applicable legal procedure to share your information with third parties such as law enforcement and authorised officials. Disclosure of user information in such cases will always be in good faith, with the intent of preventing harm or loss, physically or financially to users and third parties.
Please note that merchants and third parties you choose to interact with may have their own privacy policies and we are not responsible for their ANY of their operations, such as how they handle their required, volunteered or third party sourced user information. We advise you to thoroughly assess their terms, policies and practices before engaging with such third parties. Regardless, unless you state otherwise or provide further authorisation, such third parties are prohibited from using your information for any purpose other than to facilitate the required purpose using the Commwea Marketplace and associated services, such as a transaction.
Digital currency transfer between you and a third party, such as a merchant, may involve third parties sharing your information with us; including but not limited to your mobile phone number or email address, used to notify you that a transfer has been received or sent by the third party. We may use such information for purposes, including but not limited to confirming your identity and validating your status as a user the InventoryClub Group.
Protection and storage of personal information
Privacy is not simply a feature of our services but a fundamental component. Therefore, we ensure Commwea and associated InventoryClub Group services or third-party partners maintain appropriate safeguards, technical, administrative and even physical to keep your personal information confidential and secure.
However, the misuse, unapproved acquisition or loss of your information cannot be guaranteed not to happen. It is important to also keep in mind that you, the user, play a crucial role in the protection of your own data. During registration for our services and after, while using Commwea, ensure to create a very strong password, of suitable complexity and length. Not revealing your password will be essential to ensure the security of your account. If, for any reason, unauthorised access occurs, you must notify us immediately.
Note, we can only protect your data once we receive the information. Confidentiality and security cannot be guaranteed before and when you send the information, only once we have received. Whether this information is sent to us via the Internet, on a wireless or non-wireless connection and/or whether this information is in the form of an SMS (text message), phone call or email (electronic mail), our protection policy only applies once we receive the information. If, for any reason, you believe the security of your information has been breached, you must notify us immediately.
Access and alterations to your personal information
You have the right to view, access and amend your personal information. Information which is covered by this entitlement can be altered at your convenience via your Commwea Customer account. You can also delete/remove information when it is inaccurate or voluntary.
Closing your Commwea account
Your rights regarding how we use your data
You have the right to access, correct and delete your personal information. Under European data protection legislation, you have the right to access the personal information that Commwea holds regarding you. You may also require any incorrect personal information that we hold about you to be corrected or removed.
You also have the right to object. We may use your personal information for marketing purposes or in other circumstances in which you can object to the use of your data. Ensure to notify us immediately if you wish to exercise either of these rights.
Storage of your personal information
Privacy and direct marketing
We will only contract you for marketing purposes if you have given your consent, we will ensure that the information sent to you about Commwea and/or associated services are familiar to those which you have are currently or have previously engaged with. Customers within the European Economic Area (EEA) will only be contacted by electronic means such as email or text message (SMS).
You have the right of access to your personal information. This means you have the right to request us to provide you with a copy of all the personal formation we hold regarding you. This information will be provided within an appropriate timeframe and may be subject to a fee, as permitted by law, without affecting the rights and freedoms of others.
You have the right to rectify your personal information. This means you have the right to request us to change and update any of the personal information we hold regarding you that is inaccurate. This information will be provided within an appropriate timeframe and may be subject to a fee, as permitted by law, without affecting the rights and freedoms of others.
Your right to access and rectification of your personal information, stated above, will only be limited where the burden or cost of facilitating access is asymmetric to the risks to your privacy in the case in question or the privacy and rights of individuals, other than you, would also be at risk.
You have the right to withdraw consent. This means you have the right to withdraw your consent to the processing of your personal information. This is information we have collected based on your approval during any point in time. Note, withdrawal of your consent will be affect the legitimacy of our processing based on your consent before your withdrawal.
You have the right to erasure. This means you have the right to request us to erase your personal information. This includes personal information which is not required anymore for the purposes for which it was initially collected and/or processed, and information was obtained in relation to processing to which you now object, and there are no legitimate grounds for our processing which negates your right. This also includes information which was obtained in relation to processing that was previously consented by you, but for which consent have now been withdrawn.
Note, subject to limitations by applicable data protection laws, if the personal information we hold regarding you has been made public by us and you request us, thus obligating us to erase your personal information, we will take appropriate action to inform third parties that are processing your personal information, that you have enforced your right and requested the erasure of your personal information in all forms.
You have the right to data portability. This means you may have the right to request to be given your personal information in a structure, which is common and machine-readable. This may be information we processed based on given consent or a contract. This also means you may also have the right to instruct us to transfer your personal information directly to another “handler”, defined as a legal entity, included but not limited to a person, governing body or private company, which solely or in cooperation with others, determines the processing of your personal information. We say “may” for both rights as this right is limited by cost, technical feasibility and potential effects on the rights and freedoms of others.
You have the right to restrict. This means you have the right to limit or object to us processing your personal information if you contest the accuracy of the personal information we hold regarding you, of which we will stop processing while verifying the accuracy. This also means if we no require your person for the initial purposes of the process but note, legal claims are your responsibility. In addition to the above, if the processing of your personal information is unlawful but you oppose the removal of your data, opting for restrictions of its use and if you have objected the processing of your personal data but we are in the process of verifying the legal grounds of which we have processed your personal information, overrule your stated rights.
If restricted information is processed by us, we will inform you; this will only be for reasons such required legal procedure. You will be notified of relevant erasure, rectification and/or restrictions on your personal information and so will corresponding authorised third-parties whom your data have been disclosed.
You have the right to object to processing. This means you have the right to object to the processing of your personal information, at any point in time, as permitted by applicable law. This will be information which we have processed based on contract, consent or legitimate reasons. This means you also have the right to not be subject to a decision, based on your personal information solely determined by an automated process. However, we will continue to process your personal information if required, in good faith, for any omissions permitted by applicable law.
Note, your rights stated above regarding your personal information are NOT absolute and access may be denied when denial of access is required or permitted by law, when providing access would affect the privacy of others, where the request for access is impractical or burdensome and to protect our rights and properties.
Send Email: firstname.lastname@example.org
If you have any serious issues with how we handle your personal information, you can complain to the relevant data protection authority. This may be the in the EU member state in which you live and/or work, or in the place where the alleged breach of data protection law has taken place. The relevant data protection authority in the United Kingdom is the Information Commissioner’s Office.