Privacy policy

We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share your personal data. It also explains your rights in relation to your personal data and how to contact us or supervisory authorities in the event you have a complaint.

We collect, use and are responsible for certain personal data about you. When we do so we are subject to the UK General Data Protection Regulation (UK GDPR). We are also subject to the EU General Data Protection Regulation (EU GDPR) and UAE DPR (Data Protection Regulations) in relation to the services we offer to individuals and our wider operations in the the United Arab Emirates (UAE).

Key Terms

It would be helpful to start by explaining some key terms used in this policy:

We, us, our	HAQQ Wallet
Personal data	Any information relating to an identified or identifiable individual. Collection of Eth address’ of user accounts which is generated from the public keys of the HAQQ Wallet user."
Special category personal data	Biometric data (where used for identification purposes) Collection of Eth address’ of user accounts which is generated from the public keys of the HAQQ Wallet user.
Data subject	The HAQQ Wallet user who the personal data relates to

Personal Data That We Collect

The personal data we collect about you depends on the particular services we provide to you. We will collect and use the following personal data about you:

Your name and contact information, including email address and telephone number.
Information to check and verify your identity, e.g. your date of birth
Avatars
Behaviour analytics
App crash debug data
Push tokens
Username - unique user ID in Haqq wallet application, Twitter account, email (receive from Twitter) there are no other data we store and process.
Your billing information, transaction, and payment card information.
Collection of the user’s credentials, such as unique user ID in HAQQ wallet application.
Your responses to surveys, competitions, and promotions.
Collection of Eth address’ of user accounts which is generated from the public keys of the HAQQ Wallet user.

How Your Personal Data is Collected

We collect most of this personal data directly from you—in person, by your interactions on the HAQQ Wallet platform, telephone, text or email and our applications. However, we may also collect information:

Information Provided to Us: When the user uses our platform, or engages with us through our newsletter, customer service system, or partakes in our pilot applications. We thereby collect any Personal Data provided to us by the user. For instance, a user’s name, email address, and immigration status.
Cookies: HAQQ Wallet would rely on data providers that may collect information using cookies and other related technology types. In doing so, such data providers may assess and collect data analytics and information about your online activities over time and across different services.
Through Our IT Systems: Through automated monitoring of our websites and other technical systems, such as our computer networks and connections, communications systems, email and instant messaging systems;
Data Collection by Default: HAQQ Wallet would collect information about the user when they use the HAQQ application or website. To this note, we may collect your internet protocol (IP) address, and other related information. This is to enhance the product we provide through the HAQQ Wallet to our customers.

How and Why We Use Your Personal Data

Under the applicable data protection laws of each jurisdiction, we can only use your personal data if we have a proper reason, eg:

Consent: In the circumstances where the user provides HAQQ with consent.
Compliance: For HAQQ to be in continuous compliance with all the relevant legal and regulatory obligations.
Debugging Protocol: To provide and carry out the necessary debugging services to enhance the service output of the HAQQ Wallet application.
Risk and Fraud Assessment: To identify, locate and detect security incidents, possibilities of fraud and to swiftly respond to any instances of security breaches.
Personalized Data Creation: Data is also collected for the purposes of personalizing the user’s experience on the HAQQ platform.

The table below explains what we use your personal data for and why.

What we use your personal data for	Our reasons
Providing services to you	To perform our contract with you or to take steps at your request before entering into a contract
Preventing and detecting fraud against you or us	For our legitimate interest, i.e. to minimize fraud that could be damaging for you and/or us
In order to conduct checks to identify our customers and verify their identity Screening for financial and other sanctions or embargoes Other activities necessary to comply with professional, legal and regulatory obligations that apply to our business, e.g. regulations that cover digital assets or applicable laws issued by our professional regulator in each applicable jurisdiction.	Depending on the circumstances: - to comply with our legal and regulatory obligations - for our legitimate interests
To enforce legal rights or defend or undertake legal proceedings	Depending on the circumstances: - to comply with our legal and regulatory obligations; - in other cases, for our legitimate interests, i.e. to protect our business, interests and rights
Ensuring business policies are adhered to, e.g. policies covering security and internet use	For our legitimate interests, i.e. to make sure we are following our own internal procedures so we can deliver the best service to you
Operational reasons, such as improving efficiency, training, and quality control	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Ensuring the confidentiality of commercially sensitive information	Depending on the circumstances: - for our legitimate interests, i.e. to protect trade secrets and other commercially valuable information; - to comply with our legal and regulatory obligations
Statistical analysis to help us manage our business, e.g. in relation our financial performance, customer base,	For our legitimate interests, i.e. to be as efficient as we can so we can deliver the best service to you at the best price
Preventing unauthorized access and modifications to systems	Depending on the circumstances: - for our legitimate interests, i.e. to prevent and detect criminal activity that could be damaging for you and/or us; - to comply with our legal and regulatory obligations
Protecting the security of systems and data used to provide the services	To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, i.e. to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Updating and enhancing customer records	Depending on the circumstances: - to perform our contract with you or to take steps at your request before entering into a contract. - to comply with our legal and regulatory obligations. - for our legitimate interests, e.g. making sure that we can keep in touch with our customers about existing orders and new products
Statutory returns	To comply with our legal and regulatory obligations
Ensuring safe working practices, staff administration and assessments	Depending on the circumstances: - to comply with our legal and regulatory obligations; - for our legitimate interests, e.g. to make sure we are following our own internal procedures and working efficiently so we can deliver the best service to you
Marketing our services to: - existing and former customers; - third parties who have previously expressed an interest in our services; - third parties with whom we have had no previous dealings.	For our legitimate interests, i.e. to promote our business to existing and former customers
External audits and quality checks, e.g. for ISO or Investors in People accreditation and the audit of our accounts.	Depending on the circumstances: - for our legitimate interests, i.e. to maintain our accreditations so we can demonstrate we operate at the highest standards; - to comply with our legal and regulatory obligations
To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency. In such cases information will be anonymized where possible and only shared where necessary	Depending on the circumstances: - to comply with our legal and regulatory obligations. - in other cases, for our legitimate interests, i.e. to protect, realize or grow the value in our business and assets

Marketing

We will use your personal data to send you updates by email, text message or telephone about our services, including exclusive offers, promotions, or new services.

We have a legitimate interest in using your personal data for marketing purposes). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.

You have the right to opt out of receiving marketing communications at any time by:

contacting us at privacy@boredgen.net
using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts.
updating your marketing preferences on our HAQQ Wallet platform.
We may ask you to confirm or update your marketing preferences if you ask us to provide further services in the future, or if there are changes in the law, regulation, or the structure of our business.

Who We Share Your Personal Data With

We routinely share personal data with:

Third Parties: HAQQ Wallet may use third parties to help deliver its services to the user. Examples to this note would be payment service providers, warehouses and delivery companies, marketing agencies or website hosts, social media accounts linked to the HAQQ platform by the user.
Legal Disclosure: HAQQ Wallet would be positioned to access and disclose your Personal Data, if it is understood that doing so would be required to comply with the applicable laws; (ii) respond to law and to ensure the safety of HAQQ Wallet’s overarching interests, its customers and other related entities.
Disclosure to Credit and Broker Lines: HAQQ Wallet may provide data collected to its credit lenders and bankers, if and when deemed necessary.

Data Retention

Personal data may be retained through third party agencies, service providers, representatives, and agents. Some of these third parties may be based outside the UAE, UK/EEA. For more information, including on how we safeguard your personal data when this happens.

Furthermore, Data would be retained We as long as it would be deemed necessary for the purpose of providing the user with the required customer support. Alternatively, a long retention period may be required in the cases required or permitted by law.

Transferring Your Personal Data Out of a Jurisdiction

The EEA, UK and other countries like the UAE have differing data protection laws, some of which may provide lower levels of protection of privacy. It is sometimes necessary for us to transfer your personal data to countries outside the UK, UAE and EEA. In those cases, we will comply with the applicable UAE, UK and EEA Data Protection laws designed to ensure the privacy of your personal data.

Your rights

You have the following rights, which you can exercise free of charge:

If you would like to exercise any of those rights, please:

Access	The right to be provided with a copy of your personal data
Rectification	The right to require us to correct any mistakes in your personal data
Erasure (also known as the right to be forgotten)	The right to require us to delete your personal data—in certain situations
Restriction of processing	The right to require us to restrict processing of your personal data in certain circumstances, e.g. if you contest the accuracy of the data
Data portability	The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations
To object	The right to object: at any time to your personal data being processed for direct marketing (including profiling); in certain other situations to our continued processing of your personal data, e.g. processing carried out for the purpose of our legitimate interests unless there are compelling legitimate grounds for the processing to continue or the processing is required for the establishment, exercise or defense of legal claims"
Not to be subject to automated individual decision making	The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
The right to withdraw consents	If you have provided us with a consent to use your personal data, you have a right to withdraw that consent easily at any time You may withdraw consents by by sending a request to privacy@boredgen.net Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn

If you would like to exercise any of those rights, please:

complete a data subject request form—available on our website at [insert relevant webpage on HAQQ Wallet platform or website; or
email, call or write to us—see below: ‘How to contact us’; and
provide enough information to identify yourself (e.g. your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you;
let us know what right you want to exercise and the information to which your request relates.

If the user wishes to exercise any of these rights, they must contact us via the “Contact Information” provided above. To this note, the request must clearly describe the type of Personal Data concerned and the infringed rights. Likewise, it must be understood that there are exceptions and limitations to each of these rights

Personal Data Security Structure

HAQQ Wallet have the appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it. Those processing your personal data will do so only in an authorized manner and are subject to a duty of confidentiality. We continually test our systems and are ISO 27001 certified, which means we follow top industry standards for information security.

We also have procedures to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Complain Protocol

Please contact us if you have any queries or concerns about our use of your personal data (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have. [Insert Applicable Contact Information]

Changes to This Privacy Policy

This privacy notice was published on December 23, 2022 and last updated on December 23, 2022.

We may change this privacy policy from time to time. In case of modification, we will change the last update date. We recommend you check the policies to be aware of the latest modifications.

How To Contact Us

United Arab Emirates

You can contact us and/or our Privacy Officer by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.

Our contact details are shown below:

Email: privacy@boredgen.net