<\/span><\/h4>\nThis privacy policy (the \u201cPrivacy Policy\u201d) gives you an overview of how SILVRR, as a data controller, (SILVRR, \u201cwe\u201d, \u201cus\u201d, \u201cour\u201d) processes your personal data, notably through your use of our mobile application (the \u201cApp\u201d) or website www.wiscartapp.com (the \u201cWebsite\u201d) or your use of our services (the \u201cService(s)\u201d). The purpose of this Privacy Policy is to inform you about our data processing activities and your data protection rights.<\/span><\/p>\nFor the purpose of the relevant data protection legislation, the data controller responsible for your personal data is Akulaku (as further described in section 2. below).<\/span><\/p>\nYou are welcome to contact us (see our contact information below) if you have any questions relating to our data protection activities that are not answered in this data protection declaration.<\/span><\/p>\nOur App or Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies. When you leave our App, Website or Service(s), we encourage you to read the privacy policy of every third-party website you visit.<\/span><\/p>\nWe may also process your personal data using cookies. For a complete overview of our data processing, we recommend you to read also our Cookie Policy, which can be found in our App.<\/span><\/p>\n <\/p>\n
<\/span>2. <\/span>\u00a0<\/span>Who are we?<\/b><\/span><\/h4>\nSILVRR, with registered address [<\/span>xxx<\/span>], email: [<\/span>xxx<\/span>] and phone number [<\/span>xxx<\/span>] is a cross border e-commerce platform connecting consumers with the best goods and services suppliers across the world.<\/span><\/p>\nSILVRR also offers an own brand BNPL service, which facilitates customers\u2019 purchase decision with payment solutions of Pay Later in 14 or 30 days and Pay in 3, among other regular payment options (altogether \u201cpayment solutions\u201d).<\/span><\/p>\n<\/span>3.<\/span>\u00a0<\/span>What personal data do we process and when\/how?<\/b><\/span><\/h4>\n<\/span>3.1<\/b>\u00a0<\/b>What personal data do we process?<\/b><\/span><\/h5>\nPersonal data means any information relating to an identified or identifiable natural person and therefore concerns all information about a (directly identified) customer or on the basis of which the identity of the customer can be derived.\u00a0<\/span><\/p>\nWe collect the following personal data from you when you visit our App or Website and use our Service(s):\u00a0<\/span><\/p>\n\n- \u00a0 \u00a0 <\/span>Device-related information<\/b>: national code, adjust id, Google id, hardware information, display screen information, build information, memory information, system information storage information (like 128G or 256G), Wifi information, Bluetooth information, Internet information, battery information, sensor information,data relating to device ID, IP address, GPS location, language settings, time zone settings, operating system, screen resolution, installed App list, App usage behaviour<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Contact information:<\/b>email address, mobile phone number, billing address;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Information about the goods and services: <\/b>data relating to details of the goods and services that you buy, delivery address, tracking number of the delivery;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Identification information: your first and last name, your date of birth, a copy of your ID card or identification documents, your facial image, your national registration number, your title, your occupation, your gender, your nationality;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Bank account information:<\/b>your bank\u2019s name, your account name and your account statements;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Financial information:<\/b>information relating to your income, any credit obligations that you might have, your negative credit records, your payment history, credits granted to you, your account number, the name of the account holder used for the BNPL services;\u00a0<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Contacts information<\/b>: information relating to reference contacts, including information on your phone contacts;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Additionalinformation<\/b>: information on your behaviour and consumption.<\/span><\/li>\n<\/ul>\n
<\/span>3.2<\/b>\u00a0 <\/b>When\/how do we collect your personal data?<\/b><\/span><\/h4>\nThe personal data described in section 3.1are either directly collected from you via direct interactions or from your devices, by SILVRR or via third parties or publicly available sources, in the following manner:<\/span><\/p>\n\n- \u00a0 \u00a0 <\/span>device-related information is directly collected from your device when you launch our App or visit our Website;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>contact information is directly collected from you when you open an account with us and register to use our Service(s);<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>information about the goods and services is directly collected from you when you place an order or complete an order via our Service(s);<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>identification information is directly collected from you when you apply for BNPL services;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>bank account information is directly collected from you when you apply for BNPL services;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>financial information is collected from third parties when you apply for BNPL services;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>contacts information is directly collected from you and your device when you apply for BNPL services;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>additional information is collected from telecom operators or other e-commerce platforms when you apply for BNPL services;<\/span><\/li>\n<\/ul>\n
<\/span>4. <\/span>On which legal basis and for which purposes do we process your personal data?<\/b><\/span><\/h4>\n<\/span>4.1<\/b>\u00a0<\/b>On which legal basis do we process your personal data?<\/b><\/span><\/h5>\nWe process your personal data only in accordance with the applicable data protection laws. We only process your personal data for the purposes specified in this Privacy Policy.<\/span><\/p>\nUnder this section, we tell on what legal grounds we process your personal data. Depending on this legal basis, your rights with regard to our processing activities may differ.\u00a0<\/span><\/p>\nWe will process your personal data on the basis of one of the following legal grounds:<\/span><\/p>\n\n- \u00a0 \u00a0 <\/span>the processing is necessary for entering into a contract or performing a contract (Article 6(1)(b) of the GDPR);<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>the processing is necessary for the purposes of the legitimate interests pursued by the controller (us) or by a third party (Article 6(1)(f) of the GDPR) and does not unduly affect your interests or fundamental rights and freedoms;\u00a0<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>Please note that, when processing your personal data on this basis, we always seek to maintain a balance between our legitimate interest and your privacy. In order to strike such balance, we do not process sensitive data. This data will remain strictly confidential. Such legitimate interests include fraud prevention, marketing, know your customer (\u201cKYC\u201d). You can contact us for more information on how we strike a balance (see section 12. for our contact details).\u00a0<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>the processing is necessary for compliance with a legal obligation to which Akulaku is subject (Article 6(1)(c) of the GDPR), for example in limited cases with regard to the prevention of money laundering, or to respond to requests from competent authorities in this context;<\/span><\/li>\n
- \u00a0 \u00a0 <\/span>you gave your explicit consent for the processing for one or more specific purposes, it being understood that SILVRR will at all times ensure that your consent is compliant with the applicable laws and regulations (Article 6(1)(a) of the GDPR).<\/span><\/li>\n<\/ul>\n
<\/span>4.2<\/b>\u00a0 <\/b>For which purposes do we process your personal data?<\/b>