Last Updated: 13 July 2023
Forward Enterprise Ltd. (collectively refer to “FWX” “we” “us” and “our”) respects your privacy. Please read this privacy notice (the “Privacy Notice”) together with the Terms of Service carefully as it applies to our services, products (collectively, the “Services”) and fwx.finance or any associated websites including APIs (collectively, the “Interface”).
This Privacy Notice explains how we collect, process, transfer, and store your personal data, including informing you of your rights with respect to the processing of your personal information.
1. PERSONAL DATA THAT WE COLLECT FROM YOU
“Personal Data” refers to any information that relates to an identified or identifiable natural person directly or indirectly.
We may collect and process your Personal Data as followings:
- Identity Information: includes your name, government identification number, passport number, tax identification number, social security number, nationality, username or similar identifier;
- Contact Information: includes mailing address, email address, telephone numbers;
- Financial Information: includes details about payments, your trade history, transaction history and balance information, associated fees paid, digital wallet addresses;
- Correspondence: includes your interests or preferences, feedback or survey responses, any communications provided to FWX team or legal team;
- Usage Data: We may collect your certain information automatically including IP addresses, operating system type, network information, browser information (e.g., URL, browser type, name and version, date/time of access), cookies, activity logs, unique device identifiers, geo- location or tracking details, photographs, videos, and voice recordings;
- User Behavioral Information: We may collect some of your behavior information when you use and interact with the Interface, channels, applications, or social media, such as the content response times, the type, size and filenames of photos you upload to the Interface, or other similar information;
- Information we will never collect from you: We do not and will never ask you to share your private key or seed phrase. Never trust any websites that ask you to enter your private key or seed phrase.
2. WHERE WE COLLECT THE PERSONAL DATA FROM
We obtain your information from various ways as follows:
- Information that you provide to us: You may provide Personal Data to us when you register for an account on the Interface, or for using the Services, contact us with inquiries or otherwise communicate with us, submit web forms or use interactive features on the Interface, connect the Services with another websites or services (for example, when you choose to connect a non-custodial wallet with the Interface.);
- Information we collect from other sources: We may obtain information about you from third-party sources. This includes the information received from our business partners and any information that you share publicly on social network platforms such as Twitter, Facebook, Discord. When you interact with our social media pages, we will collect Personal Data that you choose to provide to us;
If you choose not to provide the necessary information including Personal Data or give consent to us, we may not be able to provide you with the Services, or meet all our obligations we have with you, or enter into a contract with you. In such cases, the Services to you may be limited, restricted, suspended, canceled, prevented or prohibited.
3. WHY WE PROCESS PERSONAL DATA
We may collect, use and store (“process”) your Personal Data for various purposes based on several legal bases as the followings:
- Performance of a Contract, in order to:
- process and complete your transactions;
- provide our Services to you;
- provide technical and customer support for you;
- Legitimate Interest, in order to:
- enhance and develop the Services including the Interface;
- personalize and manage your experience of the Interface;
- diagnose and fix any errors when you send us error reports;
- provide you with news and notify you any changes, updated of our Services including the amendment of Terms of Service, and changes of the Interface;
- analysis and research to help us improve our Services;
- ensure security measures and measures against unauthorized use;
- process your current location data while accessing the Interface to provide location-based Services;
- Consent, we may process your Personal Data when you consent us to:
- send gifts, rewards, or giveaways to you;
- conduct surveys related to our Services and get feedback from you;
- communicate with you via any means (including via email, telegram, text message, social media, post or in person);
- Legal Obligations, in order to:
- verify your identity to fulfill our obligations under the anti-money laundering laws of various jurisdictions;
- comply with any applicable laws or regulations;
- enforce compliance with our Terms of Service and other agreements we made with you.
4. HOW WE SHARE PERSONAL DATA
We may share your Personal Data only for the purposes described in this Privacy Notice with:
Service Providers: We may share your Personal Data with third-party service providers to provide website and application development, hosting, maintenance, backup, storage, payment processing, analysis and other services for us, which may require them to access or use your Personal Data. We will ensure that these third parties have the appropriate safeguard to protect your Personal Data.
Affiliated Companies: We may share your Personal Data with our affiliates, subsidiaries, joint ventures, or other companies under common control with us, to improve Services, marketing, and advertising to you.
Law Enforcement: To comply with any applicable laws, we may share your Personal Data with the law enforcement, regulatory agencies or courts when we believe that it is necessary, for example, to protect our rights, protect you from illegal activities, prevent physical harm or financial loss, investigate violation of our Terms of Service and other policies or agreements.
5. CHILDREN’S PRIVACY
We do not intend to provide the Services to, and do not knowingly collect Personal Data from children under the age of 18, or under the legal age of your country. Any Personal Data from children will only be collected only if they are verified with an approved consent letter from their parent or guardian.
If we notice that we have collected the Personal Data of a child under the age of 18, or under the legal age without parental consent, we will take reasonable steps to delete such Personal Data as soon as possible.
6. INTERNATIONAL TRANSFERS OF PERSONAL DATA
We may transfer and process your Personal Data to our affiliates, subsidiaries, service providers, and other third parties located outside of your country or outside of the European Economic Area. We will take the appropriate security measures to protect and secure your Personal Data, and in accordance with the applicable data protection laws.
7. HOW WE STORE YOUR PERSONAL DATA
We securely store your Personal Data on secure servers as long as it is necessary to carry out the purposes as set out in this Privacy Notice, or keep it for a longer period if it is required by applicable laws. Personal Data that we are processing based on your consent will be kept for an unlimited period of time unless the consent is revoked.
We are taking strict technical and organizational security measures, to protect your Personal Data from loss, misuse, damage, alteration, and unauthorized access or disclosure. These security measures include but are not limited to, limiting access to data, using technology measures like firewalls, malware protection and intrusion detection, and maintaining policies that are aligned to a wide variety of legal requirements. However, no electronic transmission of data or data storage is fully secure or impenetrable; therefore, we cannot guarantee or warrant the security of your Personal Data that you share to the Interface.
9. YOUR PRIVACY RIGHTS
Under the applicable data protection law, you have significant rights related to your Personal Data including:
- Right of access.
You have the right to receive information and request a copy of your Personal Data;
- Right to obtain rectification.
When you discover that your Personal Data that we may hold about you is inaccurate, you have the right to seek rectification;
- Right to erase Personal Data.
You have the right to request us to erase your Personal Data if further processing is no longer necessary;
- Right to restrict Personal Data processing.
You have the right to restrict the processing of your Personal Data, in particular when the accuracy of the Personal Data is contested;
- Right to data portability.
The right to receive the Personal Data which you have provided to us, commonly used and machine-readable format. This right applies exclusively to the Personal Data which processing is carried out by automated means;
- Right to object data processing.
You have the right to object us to process your Personal Data which we collect based on our legitimated interest and we are required to assess the processing in order to ensure compliance with applicable laws;
- Right to withdraw consent.
You can withdraw your consent to process your Personal Data at any time. Your withdrawal will not affect any processing of your personal data based on your consent prior to your withdrawal;
- Right to contact the supervisory authority.
If you believe that we have not complied with this Privacy Notice, you may contact and lodge a complaint with the supervisory authority, your local authority or a relevant court.
11. GOOGLE ANALYTICS
FWX uses Google Analytics which is a web analytics service offered by Google. Google Analytics uses the cookies that are stored to your computer in order to analyze your use of our Services, and Sites, so that we can optimize and improve your user experience. You can find more details about how Google Analytics use your data here: https://www.google.com/analytics/terms/us.html, and you can opt out of Google Analytics by visiting: https://tools.google.com/dlpage/gaoptout?hl=en.
12. THIRD-PARTY SITE
13. DO NOT TRACK
Some internet browsers and mobile applications include “Do Not Track” or “DNT” features. Since uniform standards for “DNT” signals have not been adopted, we do not currently respond DNT signals.
14. ANONYMIZED AND AGGREGATED DATA
This Privacy Notice does not apply to non-personally identifiable information. We may aggregate your Personal Data and other data captured by us, including transaction data, click-stream data so that it no longer identifies you as an individual. specific person. We may also use, and share aggregated data for any purposes as we consider appropriate.
15. CHANGES TO THIS PRIVACY NOTICE
We may update or change this Privacy Notice from time to time. We will post on the Interface if there are any updates or modifications including the effective date of the updated Privacy Notice.
16. CONTACT US
If you have any questions about this Privacy Notice, or you wish to exercise your privacy rights, please contact us at [email protected].