[Published: October 9th, 2020]
1. GENERAL PROVISIONS
In order to operate the our Services, to meet out regulatory obligations and to reduce the risk of online fraud, RVW Limited (“RVW”, “we”, “our”, “us” or “the Company”), as a data controller, must ask you to provide us with information about yourself, including your personal details, and (if you would like to enter into a transaction with us) information about any financial instruments or payment options that may be connected to your use of RVW website or future transactions, as well as any other types of information specified in this Policy.
Personal information or data refers to any information that can be associated with a specific person and can be used to identify that person, directly or indirectly, in particular by reference to required information that the user provides to RVW to gain access to and use our Services (hereinafter “Personal data” or “personal information”).
RVW is aware of the importance of how Personal data is handled and will observe all applicable data protection laws, in particular the General Data Protection Regulation (EU) 2016/679 (hereinafter: GDPR).
Unless otherwise indicated, terms used in this Regulation shall have the same meaning as under GDPR.
Third Party Websites: Some pages on the RVW website may include links to third-party websites, for example. These sites are governed by their own privacy statements, and RVW is not responsible for their operations, including, but not limited to, their information practices. Users submitting information to or through these third-party websites should review the privacy statements of these sites before providing them with personally identifiable information.
Most web browsers are set to accept cookies by default. You are free to decline most of the cookies if the browser or browser add-on permits. Choosing to remove or disable cookies may interfere with the use and functionality of the Services. Additionally, RVW may use certain persistent cookies that are not affected by browser settings but will use such cookies solely for identity verification and fraud prevention purposes.
3. INFORMATION RVW COLLECTS
Information we collect from users:To register for and use the RVW website or get in touch with us, depending on your intentions and the services you would like to use, you may need provide to us your full name, address, phone number, the details of your identification document, and email address. In order to make certain payments or transactions with us, you must provide (where applicable) your payment instrument or account information details, and other information required to complete the transaction and satisfy all related regulatory requirements.
We may also require you to provide us with other commercial and/or identification information if you send or receive certain high-value transactions or high overall payment volumes s or as is otherwise required in order for us to comply with our anti-money laundering and risk management obligations.
Using your device: When you use RVW website using any device), we may additionally collect and store device sign-on data (including but not limited to device ID) and geolocation data.
Information About You From Third Parties: In order to execute certain transactions with you and protect our Services against potential fraud, comply with our legal obligations and enforce our Service Terms, we verify and validate information provided to us by users with a number of 3rd parties, such as financial partners, fraud agencies, data vendors, as well as using information available through internet and publicly accessible social network data. In the course of such verification, we may receive personally identifiable information about our users from such services and sources.
In some circumstances we will conduct a background check on you by obtaining information about you and your activities, and potentially (if legally permitted) also about your business partners, from a credit reference or fraud agency. If you owe us money, we may conduct a credit check on you by obtaining additional information about you from a credit reference or fraud agency, to the extent permitted by law. RVW , at its sole discretion, reserves the right to periodically retrieve and review a business and/or consumer credit report supplied by such credit reference or fraud agency for any account, and reserves the right to close a user account based on information obtained during this credit review process.
We may also collect information about you from other sources, including from other companies (subject to their privacy policies and applicable law), and from other accounts we have reason to believe you control (whether in part or in whole).
Examples of information we automatically collect about you may include:
the Internet protocol (IP) address used, information about your device and its location, as well as the details about your internet provider or mobile phone operator;
your login, e-mail address, password and the outcome of the strong authentication methods you use;
your interaction with our services, for example, the content you viewed, uploaded or downloaded, your transactional history;
your (URL) clickstream to, through and from our website (including date and time); cookie number, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs);
phone numbers used to call our customer service number.
Communications: When you communicate with us or our respesentatives for customer service or other purposes (e.g., by emails, calls, tweets, etc.), we retain such information and our responses to you in the records of your account.
Questionnaires, Surveys, Sweepstakes and Profile Data: From time to time, we offer optional questionnaires, surveys, online competitions and sweepstakes to our users for such purposes as collecting demographic information or assessing users’ interests and needs. If we collect personally identifiable information from our users in these questionnaires, surveys, and sweepstakes, the users will be given notice of how the information will be used prior to their participation in the survey, questionnaire or sweepstake.
4. HOW RVW MAY USE YOUR INFORMATION
Below is a summary of how RVW may use customer information collected from our users or about our users.
Internal Uses: We collect, store and process your information on servers located in the European Economic Area and Switzerland. Our primary purpose in collecting your information is to make you aware about RVW activities, to offer you RVW tokens for sale and provide you with a safe, smooth, efficient, and customized experience. You agree that we may use your personal information to:
Process and execute your transactions;
Verify your identity, including during account creation and password reset processes with our partners;
Resolve disputes, collect fees, and troubleshoot problems;
Manage risks, or to detect, prevent, and/or remediate fraud or other potentially illegal or prohibited activities;
Detect, prevent or remediate violations of policies or applicable agreements;
Provide you with customer support services;
Improve the RVW website by customizing your user experience;
Measure the performance of RVW website and improve the content and layout of our website and user interfaces;
Manage and protect our or our partner’s information technology infrastructure;
Provide targeted marketing and advertising (if you opted in to receive them), provide service updates, and deliver promotional offers based on the communication preferences you have defined for your RVW account; and
Perform online security, compliance, risk, creditworthiness and solvency checks, compare information for accuracy, and verify it with third parties, as the case may be.
Questionnaires, Surveys and Profile Data: If you choose to answer our optional questionnaires or surveys, we may use such information to improve our Services, send your marketing or advertising profile preferences, or as otherwise explained in detail in the survey or campaign itself.
Our Contact with Customers: We communicate with our users or potential customers on a regular basis via email and chats to provide requested services. We may also communicate with our users by phone or using VOIP technologies to:
Resolve customer complaints or claims made by users;
Respond to requests for customer service;
Inform users if we believe their accounts or any of their transactions have been used for an illegitimate purpose;
Confirm information concerning a user’s identity, business or account activity;
Carry out collection activities;
Conduct customer surveys; and
Investigate suspicious transactions.
We use your email to confirm your transactions, to send you notices and confirmations related to your activities, to send you information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be informational in nature, and not promotional.
We may also use your email address to send you other types of communications that you can control, including “news”, “customer surveys”. You can choose whether to receive some, all, or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account and then selecting settings, and updating your communicational preferences.
In connection with independent audits of our financial statements and operations imposed by applicable law, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
RVW may use your Personal data to form a view on what we believe might enhance your user experience or present you with information that may be of interest to you.
If you don’t wish to receive marketing communications from us, or to participate in our ad-customization programs, simply update your preferences.
If you would like to change your personal communication preferences or opt-out from receiving any marketing communications from us, you can do so by clicking on the opt-out link that is always present and clearly visible in our our marketing messages.
6. DISCLOSURE OF YOUR PERSONAL DATA
We work with third parties to enable you, them and potentially their customers to accept or facilitate payments from or to you. In doing so, a third party may share information about you with us such as your full name, email address or wallet address, when a payment is sent to you or when you are attempting to pay. We use this information to confirm that you are a RVW customer and that RVW can be enabled to make a payment or make a transfer, or where a transfer is sent to you to send you a notification that you have received a payment. Please note that third parties you receive funds or transact with may have their own privacy policies, and RVW is not responsible for their operations, including, but not limited to, their information practices.
How We Share Information with Other Third Parties. RVW works with third-party service providers which provide important functions to us that allow us to be an easier, faster, and safer way to facilitate transactions, display information and otherwise offer our tokens and make payments to you. We need to disclose certain user data to them from time to time, so that the services can be performed.
Some information we collect may be required to be transferred to other entities, in their capacity as financial partners, payment providers, custodians, payment processors, technical service providers or account holders (or similar capacities). You acknowledge that according to their local legislation, such entities may be subject to laws, regulations, inquiries, investigations, or orders which may require the disclosure of information to the relevant authorities in their relevant country.
Specifically, you consent to and direct RVW to do any and all of the following with your information:
Disclose necessary information to: the police and other law enforcement agencies; security forces; competent governmental, intergovernmental or supranational bodies; competent agencies, departments, regulatory authorities, self-regulatory authorities or organizations and other third parties, that (i) we are legally compelled and permitted to comply with, including but without limitation the US Foreign Account Tax Compliance Act (“FATCA Law”) and with the OECD common reporting standard (“CRS Law”) as implemented in the Liechtenstein regulatory framework; (ii) we have reason to believe it is appropriate for us to cooperate with governmental agencies or payment or processing partners in investigations of fraud or other illegal activity or potential illegal activity, to the fullest extent permitted by law, or (iii) to conduct investigations of violations of our Terms and Conditions (including without limitation, your funding source or transactional history). If you are covered by the FATCA or CRS Law, we are required to give you notice of the information about you that we may transfer to various authorities. If we believe your account may be subject to these regulations, we may notify you separately.
We and other organizations, including financial institutions that cooperate with RVW , may also share, access and use (including from other countries) necessary information (including, without limitation the information recorded by fraud prevention agencies) to help us and them assess and to manage risk (including, without limitation, to prevent fraud, money laundering and terrorist financing).
Disclose necessary information in response to the requirements of other financial institutions, credit card associations or a civil or criminal legal process.
Disclose necessary information to the payment processors, financial partners, technical service providers, auditors, customer services providers, credit reference and fraud agencies, financial products providers, commercial partners, marketing and public relations companies, operational services providers, group companies, agencies, marketplaces and other third parties, in order to provide our services to you our pursue our other legitimate interests.
Disclose necessary information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
Disclose aggregated (i.e.: anonymized) statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in a certain city. However, this aggregated information is not tied to personal information.
Share necessary information with unaffiliated third parties for the following purposes:
o Fraud Prevention and Risk Management: to help prevent fraud or assess and manage risk, as permitted by applicable law.
o Customer Service: for customer service purposes, including to help service your accounts or resolve disputes (e.g., billing or transactional).
o Legal & Compliance: to help us and our partners comply with anti-money laundering and counter-terrorist financing verification requirements, as permitted by applicable law.
o Service Providers: to enable service providers under contract with us to support our business operations, namely fraud prevention, bill collection, marketing, customer service and technology services. Our contracts dictate that these service providers only use your information in connection with the services they perform for us and not for their own benefit.
7. STORAGE SECURITY & INTERNATIONAL TRANSFERS
RVW is committed to handling your customer information with high standards of information security. We engage third parties that provide us with information security safeguards such as firewalls and data encryption, we enforce physical access controls to our files, and we authorize access to personal information only for those employees who require it to fulfil their job responsibilities, and who have committed themselves to confidentiality undertakings.
The security of your information also relies on your protection of your password or access credentials when you use our partner’s services. RVW representatives will never ask you for your password, so any email or other communication requesting your password should be treated as unauthorized and suspicious and forwarded to us.
RVW is committed to adequately protecting your information regardless of where the data resides and to providing appropriate protection for your information if your data is transferred outside of the EEA. In this regard, transfers to non-EEA countries may notably be carried out on the basis of adequate contractual arrangements, a copy of which may be obtained by you by simple request sent to RVW .
The Personal data that we collect from you will be transferred to and stored at a destination inside the European Economic Area (EEA) or Switzerland. As we provide an international service, your Personal data may be processed outside of the EEA in order for us to fulfil our contract with you to provide the RVW website.
All information you provide to us is stored on our secure servers, encrypted at rest. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted in transit. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Certain RVW website features may include social networking, chat room or forum capabilities. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by others.
8. DATA RETENTION
RVW and our partners are obligated under the Liechtenstein’s Law of 11th December 2008 on Professional Due diligence for the Prevention of Money Laundering, Organised Crime and Financing of Terrorism, no. 952.1 to retain personal data about you and your RVW transactions for a period of minimum ten years from the conclusion of the transaction or from their preparation. We therefore use this retention requirement as a benchmark for all personal data that we receive from you. In order to not hold your information for longer than is strictly necessary we will not hold any of your personal data for more than 10 years after the termination of our business relationship, unless there are other legal obligations that require us to retain your information longer.
9. YOUR LEGAL RIGHTS
You have a right to:
Access the personal data we hold about you, or to get a copy of it,
Make us correct inaccurate data about you,
Ask us to delete your data, though for legal reasons we might not always be able to do it, due to various AML, data retention and financial reporting requirements applicable to us,
Object to us using your data for marketing communications,
Withdraw any specific consent or permission you’ve previously given us (for example, in relation to a specific promotion).
Please know that if you have any questions or objections as to how we collect and process your personal information, please contact us.
By writing to the above address, and subject to certain conditions set out by applicable data protection laws, you may also exercise your rights to:
– object to the processing of your information;
– ask for erasure of your information;
– ask for portability of your information;
– object to the use of your information for marketing purposes.
10. HOW TO CONTACT US OR RAISE A COMPLAINT
Full name of legal entity: RVW Limited
Registration Number 222444
Registered address:Unit117, Orion Mall, Palm Street, P.O. Box 828, Victoria, Mahe.