Privacy Policy - Walleon

The terms used in this Privacy Policy shall have the same meaning as in the Terms of Use, unless noted otherwise.

We respect your privacy and are committed to protecting it through our compliance with this policy. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you disagree with our policies and procedures, do not download, register with, access, or use the Walleon Services. By downloading, registering with, accessing, or using the Walleon Services, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of the Walleon Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

IF YOU DISAGREE TO THIS POLICY, PLEASE DO NOT USE THE SERVICES. We will post any modifications or changes to the Privacy Policy on the website of Walleon. We reserve the right to modify this Privacy Policy at any time, so we encourage you to review it frequently. If we make a material change to this Privacy Policy, we will notify you by email or by means of a notice on the website of Walleon before the changes taking effect. Your continued use of the Services signifies your acceptance of our Privacy Policy as modified.

Contact Us

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, please contact us through the following contact information.
Email: [email protected]

Data We Collect and How Do We Collect It

We collect information from and about users of the Walleon Services:

Directly from you when you provide it to us;
Automatically when you use the Walleon Services;
Data we collect from our partners;

Information You Provide to Walleon

When you download, register with, access, or use the Walleon Services, we may ask you to provide information (a) by which you may be personally identified, such as name, email address, telephone number, or any other personal or personally identifiable information under applicable law (“personal information”), and/or (b) that is about you but individually does not identify you.

This information includes, without limitation:

Information that you provide by filling in forms in the App or otherwise when using the Products and Walleon Services. This includes information provided at the time of registering to use the Products, subscribing to a service, and posting material. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the Products;
Records and copies of your correspondence (including email addresses and phone numbers), if you contact us;
Your responses to surveys that we might ask you to complete for research purposes;
Details of transactions you carry out through the App, the Products, or otherwise through the Walleon Services, and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Walleon Services; and
Your search queries on the Walleon Services.

Your User Contributions may be published or posted publicly and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking

When you download, register with, access, and/or use the Walleon Services, it may use technology to collect automatically:

Usage Details. When you access and use the Walleon Services, we may automatically collect certain details of your access to and use of the Walleon Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Walleon Services.
Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
Stored Information and Files. The Walleon Services also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
Location Information. The Walleon Services may collect real-time information about the location of your device and/or the Products you use.

When in Lost Mode, the Products may also take photographs with the camera embedded in the Products, which will be automatically transferred to us. We may keep these photographs for as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you do not want us to collect this information, do not download, register with, access, and/or use the Walleon Services. Certain features may be opted out of.

We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioural tracking). Please note, that your use of the Walleon Services through the Platforms will also be subject to the respective terms of use and privacy policies of the online and offline platforms which host such Platforms.

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your device. Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Walleon Services, analyze use, target advertisements and prevent fraud. You can disable cookies in your settings, but some parts of the Walleon Services may then not function properly;
Web Beacons. Pages of the Walleon Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an email and for other related Walleon Services statistics (for example, recording the popularity of certain Walleon Services content and verifying system and server integrity).

Data we collect from our partners

We also collect the following data from our partners:

Data we receive if you link a third party tool with the Walleon Services (such as Facebook, WeChat, or Google)
Data to fight fraud (such as refund abuse in purchases or click fraud in advertising)
Data from platforms that the Walleon Services run on (such as to verify payment)
Data for advertising and analytics purposes, so we can provide you with better service

Third-Party Information Collection

When you use the Walleon Services or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include, without limitation: social media platforms, advertisers, ad networks, and ad servers; analytics companies; your mobile device manufacturer; your mobile service provider.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Walleon may provide paid products and/or services through the Walleon Services. In such case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their respective privacy policy. Any and all payments associated with your use of the SIM card embedded in the wallets is handled through the respective telecommunications provider, not through us.

Why Do We Collect Your Data

To make the Walleon Services work. To perform the contract, we process data necessary to:

Create User Accounts and allow you to use our Products, access the App, access the functions of the Products, and use our services,
Provide and deliver products, services, and any other information you request
Send you Walleon-related communications, such as when updates are available, and of changes to any products or services we offer or provide
Fulfil any other purpose for which you provide the information
Give you notices about your User Account
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us

To make the Walleon Services more suitable for our users.
To provide great Products to our users, we have a legitimate interest to collect and process necessary data to:

Develop and improve the Walleon Services and user experience
Manage our relationship with you
Provide social features as part of the Walleon Services
Customize your Walleon experience according to your individual interests, such as through storing information about your preferences and recognizing you when you use the Walleon Services
Respond to your comments and questions and provide support
Provide you offers through the Walleon Services as well as in other websites and services, and by email
Send you related information, such as updates, security alerts, and support messages
Speed up your searches

To show personalized advertisements.
To show you personalized advertisements through the Walleon Services as well as in other websites and services (including email) we have a legitimate interest to process necessary data to:

Track the content you access in connection with the Walleon Services and your online behaviour
Deliver, target and improve our advertising and the Walleon Services

This may include advertisements on third parties’ goods and services, which we believe may be of interest to you. For information on how to opt-out from personalized advertisements, see section “Your rights and options” below.

To analyze, profile, and segment.
In all of the above cases and purposes, we may analyze, profile and segment all collected data, including for the purpose of estimating our audience size and usage patterns.

With your consent.
With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose personal information that we collect or you provide:

To our subsidiaries and affiliates;
To contractors, service providers, and other third parties we use to support our business, who may access your data and operate under their own privacy policies. One such entity is the telecommunications provider that services the SIM card embedded in the Products. We encourage you to check the privacy policies of such third parties to learn more about their data processing practices;
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Walleon Inc’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Walleon about its users is among the assets transferred;
To third parties to market their products or services to you if you have not opted out of these disclosures;
To fulfill the purpose for which you provide it;
For any other purpose disclosed by us when you provide the information;
With your consent;
To comply with any court order, law, or legal process, including to respond to any government or regulatory request, including in order to combat fraud and illegal activity;
To enforce our rights arising from any contracts entered into between you and us; and
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Walleon Inc., our customers, users or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Data Security

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Walleon Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Your Rights and Options

Opt-out of marketing emails and other direct marketing. You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Opt-out of targeted advertising. You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest based ads” (Android).
Access the personal data we hold about you. If you request, we will provide you a copy of your personal data in an electronic format.
Your other rights. You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings. We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third-party dispute resolution provider (free of charge). You may also contact your local data protection authority within the European Economic Area for unresolved complaints.

Data Retention

We retain your data for as long as your User Account is active or as needed to provide you the Walleon Services. Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Age Limits

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 18 or knowingly allow such persons to use or access the Walleon Services. If you are under 18, please do not send any data about yourself to us, including your name, address, or email address. No one under the age of 18 may provide any personal data. If we learn that we have collected personal data about a child under age 18, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 18, please contact us.

Changes to Our Privacy Policy

We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page.
The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting this privacy policy to check for any changes.