1. PRIVACY and AML/KYC POLICY STATUS AND ACCEPTANCE
1.1. This Privacy and AML/KYC Policy (hereinafter referred to as the "Policy”) sets forth the general rules of User’s Personal Data collection, processing, distribution, use and keeping by the Company during the use by the User of any features, technologies or functionalities offered by WOROOM.NETWORK through the online platform located at WOROOM.NETWORK website at domain WOROOM.NETWORK including all subdomains (the "Site") and/or use of any Services and/or directly on our request as well as the general rules and procedures governing the implementation and conduction of Know-Your-Customer ("KYC”) procedures in accordance with the relevant Anti-Money Laundering rules ("AML”).
1.2. Each User must carefully read and comply with this Policy. It is understood and presumed per se that by the fact of access to the Site or Platform or use and/or ordering of the Services or otherwise or by providing Us the Personal Data directly on our request, the respective User fully confirms that it has read, understood and accepted this Policy. If any User does not agree with this Policy in general or any part of it, such User must not access and use the Site or Platform or use and/or order the Services.
1.3. The Company reserves the right to modify or amend this Policy at its sole discretion. Any revisions to this Privacy and AML/KYC Policy will be posted on the homepage of our Site. If we make changes, we will notify you by revising the date at the top of this Policy. We strongly recommend You to periodically visit the Site to review any changes that may be made to this Privacy and AML/KYC Policy to stay informed about our information practices and your privacy rights and choices as well as to stay updated on our AML/KYC practices. Your continued usage of the Site and/or services shall mean Your acceptance of those amendments.
2.1. Personal Data shall mean information or totality of information that can be associated with a specific person (the User, as defined in the Terms of Service) and can be used to identify that person.
2.2. Privacy and AML/KYC Policy (also referred to as "Policy”) shall mean this Privacy and AML/KYC Policy posted on the homepage of our Site which may be revised or updated from time to time as stated in subsection 1.2 of this Privacy and AML/KYC Policy.
2.3. Company (also referred to as, "We”, "Us”) shall have the meaning as defined in the Terms of Service.
2.4. User (also referred to as "You”) shall be defined as the “User” in the Terms of Service, published and available at the Site. The Company reserves its right to set forth at any time upon its own discretion special eligibility or other requirements to certain Users to participate in pre-ordering of the Product (i.e. e-gaming industry leaders, etc.) as shall be mentioned on the Site.
2.5. Site shall have the meaning as defined in the Terms of Service.
2.6. Services shall have the meaning as defined in the Terms of Service.
2.7. Terms shall mean the Terms of Service governing the use of the Site.
2.8. All other terms not defined herein shall have the meaning as defined in the Terms.
3. PURPOSE OF PERSONAL DATA USE
3.1. We collect from the Users only the Personal Data that we need for their proper use of the Site or Platform or use and/or ordering of the Services. In particular, we use Your Personal Data to:
administer Our Site and provide the Services;
develop new products and Services;
personalize Our Site for You;
send You technical notices and support and administrative messages;
communicate with You about products, services, promotions, events and other news and information we think will be of interest to You;
monitor and analyze trends, usage and activities in connection with Our Site and services;
provide third parties with non-personalized statistical information about Our Users (but those third parties will not be able to identify any individual User from that information);
detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of the Company and others;
link or combine Personal Data We collect from or about You;
and verify compliance with the terms and conditions governing the use of Our Site (including monitoring private messages sent through the Site private messaging service).
4. PERSONAL DATA COLLECTION AND PROCESSING
4.1. We collect Personal Data from running the Site and use Personal Data, provided to Us by You. We may collect such Personal Data:
full name and surname;
sex and gender;
citizenship and country of residence;
residence and postal address;
date and place of birth;
photo and passport details;
Telegram Messenger User Name;
LinkedIn page address;
Any such other information, which we may additionally require from time to time.
4.2. We reserve the right to collect any Other Data, including data which is not Personal per se such as:
Address of Your digital wallet (vault or other storage outside the Site);
any other information if we deem necessary in accordance with the Privacy and AML/KYC policy set forth herein.
4.3. When You visit the Site or use our products, We automatically collect the Personal Data sent to Us by Your computer, mobile phone, or other access device. This Personal Data may include:
your IP address;
device information including, but not limited to, identifier, name, and type, operating system;
mobile network information and ISP details;
standard web log information, such as Your browser type, and the pages You accessed on Our Site, access times, web-site navigation paths.
The Company collects some data automatically, namely information about devices (including mobile devices), which you may use to access the Site, IP-address of your devices, used browser and operating system, date, time, geographical location data of your access to the Site. However, we will not release Your personally-identifying information of such kind to any third party without Your consent, except as set forth herein.
4.4. We do not process any sensitive Personal Data, such as religion, race, ethnicity and/or political views.
4.5. We also may use third party service providers, which we entrust storing Personal Data, its collection and analysis. This is made in order to enable You to get the best services possible and to make our cooperation the most effective and with the best benefit for You. These third parties have their own privacy policies and their own conditions, whether to collect your data or opt-out from it. Thus, we do recommend You to getting yourself acquainted with the terms of third party service provider, if You use other services on our Site. We will not seek any of your Personal Information through any other software platforms, data web resources etc., even if this information is necessary for You or your usage of the Site.
4.7. You agree to provide the Personal Data specified herein and agree that Your provided Personal Data may be processed and stored by Us or Our counterparties (as specified in clause 4.5 hereof) during the period of time that is practically necessary for the purposes for which the information may be used.
4.8. The components of Personal Data that mentioned herein may be modified from time to time according to the applicable law and our needs that will be reflected in this Policy. We will not collect any other Personal Data except for the mentioned herein until we amend and post these amendments to the Policy on the homepage of our Site.
5. AML/KYC POLICY
5.1. WOROOM.NETWORK is strongly committed to preventing the use of its operations for money laundering or any activity which facilitates money laundering, or the funding of terrorist or criminal activities.
5.2. On a global level, in order to prevent and combat money laundering and terrorism financing, there has been an introduction of the number of laws concerning the customer identification and verification procedures including but not limited to the EU Directives AMLD4 and AMLD5, with the latter being set to take effect in the year 2018 and bring businesses operating with the virtual currencies under the scope of the Anti-Money Laundering Directive.
5.3. In the United States regulation of the AML is carried out by a special government body under the US Treasury - FinCEN. In particular, FinCEN regulates, so-called, "money services business" (MSB). In 2013 FinCEN published the clarification on the regulation of persons administering, exchanging or using virtual currencies bringing the businesses dealing with virtual currencies under the scope of AML/KYC in terms of spotting suspicious financial behavior.
5.4. In order to ensure that our operations are compliant with the AML/KYC rules and procedures, we are implementing the AML/KYC policies detailed below.
5.5. As part of our AML (Anti-Money Laundering) Policy in order to combat money laundering and illegal financing activities WOROOM.NETWORK follows the User risk assessment principles that include but are not limited to the following:
Raise awareness on money laundering issues.
Assist law agencies and authorities to trace, seize, and confiscate the proceed of criminal activities.
Freeze any funds or Assets deemed suspicious and investigate the source of finance.
Introduce a Know-Your-Customer policy (KYC).
Exercise reasonable measures to obtain information about the true identity of the persons on whose behalf a transaction is made.
Record keeping procedures. Maintaining, for a specific time period, all necessary records on transactions, both domestic and international.
Pay special attention to all complex, unusually large transactions.
Adopt economic, administrative, self-regulatory and other measures which can be taken to create an effective shield against money laundering.
Train staff accordingly.
Employ proper care in the hiring of new staff.
5.6. As part of the User risk assessment, the following will act as Money Laundering Warning Signs based on guidance provided by Financial Action Task Force (FATF) - international body set up to combat money laundering:
Customer tells that the funds are coming from one source but then at the last minute the source changes;
Evasiveness or reluctance to provide information;
Incomplete or inconsistent information;
Unusual money transfer or transactions (e.g. when customer deposits unusual amounts so as not to come under the threshold when KYC applies);
Complex group structures without obvious explanation that may be designed to disguise the true source and ownership of money;
When money is coming from the list of high-risk and non-co-operative jurisdictions’ according to FATF;
Negative public information available about the client or company.
5.7. As part of our AML policy WOROOM.NETWORK carries out screening of its Customers and Vendors to identify and flag potential suspicious or unusual activity for review and provide for the timely filing of such activity if ultimately determined suspicious or unusual. This includes identifies specific alert routines developed to screen User and transactional information for potentially suspicious or unusual activity. The alert routines monitor customers for unusual size, volume, or pattern of transactions, taking into account risk factors and "red flags” appropriate to WOROOM.NETWORK's business model. WOROOM.NETWORK carries out screening of its Customers and Vendors against the lists published by the Office of Foreign Assets Control (OFAC) of the United States Department of Treasury, which administers and enforces economic and trade sanctions against targeted foreign countries and groups of individuals, terrorism sponsoring organizations, and international narcotics traffickers based on U.S. foreign policy and national security goals. WOROOM.NETWORK also screens Users against OFAC's Specially Designated Nationals (SDN) List and other watchlists of SDNs. In general, OFAC regulations require the following: (1) Blocking accounts and other property of specified countries, entities, and individuals; (2) Prohibiting or rejecting unlicensed trade and financial transactions with specified countries, entities, and individuals. In the event a match has been determined, WOROOM.NETWORK will contact OFAC via hotline, as well as refuse any pending or future transactions.
5.8. As part of our AML policy WOROOM.NETWORK screens User information and transactional information to determine if it involves individuals and entities with ties to OFAC-sanctioned geographic regions and governments (e.g., address and government-issued identification). OFAC administers a number of U.S. economic sanctions and embargoes that target geographic regions and governments. Some programs are comprehensive in nature, block the government, and include broad-based trade restrictions, while others target specific individuals and entities. The above principles and warning signs are aimed at determining the User’s risk in terms of propensity to commit money laundering, terrorist financing or identity theft.
5.9. WOROOM.NETWORK adopts the KYC (Know-Your-Customer) policy and reserves the right to undertake KYC in order to verify the identity of its customers (Vendors and Customers) at any point.
5.10. As part of the exercise of this right and WOROOM.NETWORK’s KYC check, WOROOM.NETWORK will require the following information, documents to be sent by the Vendor:
Full name and surname;
Permanent residence address;
Copy of unexpired/valid passport, signed by the Vendor;
Date of birth;
Photo and passport details, including issuance and expiry date;;
Recent utility bill;
Additionally we will request the Vendor to have a Skype or Zoom call with Us to confirm the proof of identity and passport.
5.11. As part of the exercise of this right and WOROOM.NETWORK’s KYC check, WOROOM.NETWORK will require the following information to be sent by the Customer:
Full name and surname;
Permanent residence address;
Copy of unexpired/valid passport, signed by the Vendor;
Date of birth;
Photo and passport details, including issuance and expiry date;
Recent utility bill;
5.12. We may request the Customer to send us all, or part of the information, and will assign a certain access level for such Customer to the amount of Services, which such Customer may use on the Site (the “Verification Level”).
5.13. ‘Recent’ means no longer than 3 months from date of issue.
5.14. Please note that the list above is not exhaustive and we reserve the right to require additional information at any time to verify the client’s identification and to fully satisfy the latest Anti-Money Laundering rules.
5.15. If any of the above documents are requested, prior to sending them to us we may require them to be certified as a true copy of the original by a Solicitor or a Lawyer who must use their company stamp. We require the documents to be sent to us in high quality color format. We reserve the right to reject any documents, which do not comply with the above or if we have doubts as to their veracity.
5.16. WOROOM.NETWORK will fully decline in Services under the following circumstances: (1) the Customer or Vendor is unable to provide the requisite information, (2) the Customer or Vendor is unable to present an unexpired government-issued photo identification when required, or (3) Customer or Vendor is unfamiliar with the type of identification presented. If a prospective or existing Customer or Vendor is either refuses to provide the information described above upon request or appears to have intentionally provided misleading information, WOROOM.NETWORK, once identified, shall suspend all Services and, after considering the risks involved, may block all future provision of Services for such Customer or Vendor.
5.17. If any doubt arises we reserve the right to check the information provided, as part of the KYC Policy, using non-documentary methods including but not limited to contacting the customer directly.
SECTION 6. PERSONAL DATA PROTECTION AND SHARING
6.1. We will do any and all efforts and actions prescribed by Applicable Law to store any of Your Personal Data in secrecy, to protect Your Personal Data from accidental loss, disclosure or erasure, from illegal processing or illegal access.
6.2. We store and process Your Personal Data on Our servers in various jurisdictions, where our facilities and/or Our service providers are located. By submitting Your Personal Data, You agree to this transfer, storing, or processing. We will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Policy. We protect Your Personal Data under internationally acknowledged standards, using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure, and alteration. Some of the safeguards We use are firewalls and data encryption, physical access controls to our data centers, and information access authorization controls. We also authorize access to Personal Data only for those employees or contractors who require it to fulfill their job or service responsibilities. All of our physical, electronic, and procedural safeguards are designed to comply with applicable laws and regulations. Third parties may be located in other countries where the laws on processing of Personal Data may be less stringent than in Your country. From time to time, the Personal Data may be also stored in other locations, and in such cases, We will ensure that the Personal Data will be stored and processed with the reasonable level of care and security.
6.3. We are sometimes required to compare the Personal Data You provide to third party databases in order to verify its accuracy and confirm Your identity. This allows Us to comply with relevant AntiMoney Laundering (AML) regulations and “Know-Your-Customer”(KYC) regulations.
6.4. We reserve our right to share Your Personal Data with the following parties and with regard to the following cases:
companies that We plan to merge with or be acquired by (all or a portion of our business);
companies in connection with, or during negotiations of, any sale of company assets or any financing by another company;
service providers that execute any work for us (such as hosting providers, identity verification, support, payment, and email service providers);
in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation or legal process;
if we believe your actions are inconsistent with our Terms of Service, the Policy or any other our policies, or to protect the rights, property and safety of SOTA tokens, Vendor Tokens, Assets or others;
between and among Company and its current and future corporate parents, affiliates, subsidiaries and other companies under common control and ownership;
when we believe, in our sole discretion, that the disclosure of personal information is necessary to report suspected illegal activity or to investigate violations of our Terms and Conditions;
when we are legally obligated to perform a disclosure based on court order, subpoena, or order of other legally binding agency (incl. police, financial crime authority, tax and revenue agency, etc.) as per current law.
6.5. We will not provide Your Personal Data to any other Site users or third parties other than described in clause 6.4. herein without Your consent or direction.
6.6. We will not sell or rent Your Personal Data and/or customer lists to third parties without your explicit consent.
6.7. We may combine Your Personal Data with information we collect from other companies and use it to improve and personalize the Site and our products, as well as our content and advertising.
6.8. We may use Your name and email address to provide You with information about products or Services that may be of interest to You, but we will not use Your Personal Data without complying with applicable laws and, where appropriate, obtaining your consent.
6.9. Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers, and affiliates (including, but not limited to, websites on which the Site is advertised). If You follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that We do not accept any responsibility or liability for these policies or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these policies before You submit any personal data to these websites or use these services.
SECTION 7. DATA STORAGE AND RETENTION
7.1. In accordance with applicable law and as needed to provide services to Our Users, We may store and retain Your Personal Data provided it’s integrity and the appropriate approach to it. This requirement is conditioned by the need of complying with legal obligations and resolving possible disputes. We may retain Your Personal Data for as long as Your account is active. Moreover, Your Personal Data may be hold beyond the above mentioned period till it is indispensable for Us to have relevant information to respond to any issues that may arise later.
SECTION 8. SECURITY
8.1. We use relevant electronic and procedural safeguards to protect the privacy of the information You provide to Us from loss, misuse, disclosure, alteration and destruction. Please note that transmission of data or information (including communications by e-mail) over the Internet or other publicly accessible networks is not one hundred percent secure. Please note that We are not liable for the security of any data You are transmitting over the Internet, or third-party content.
SECTION 9. CORRECT/UPDATE/DELETE PERSONAL DATA
9.1. You have a right to access to Your Personal Data and to require the correction, updating or deletion of incorrect or/and inaccurate data by contacting Us at firstname.lastname@example.org. Nevertheless, this request must comply with Pre-Order agreement and Our legal obligations. We shall delete Your respective Personal Data from any sources within 24 hours from the moment We receive such request from You. At that the Company reserves its right to suspend provision of any services to You referring to WOROOM.NETWORK project and/or delete Your Account on the Site without prior notice, not providing any compensations to You.
9.2. To disable Your account and remove Your Personal Data completely, please email us at email@example.com with a request that complies with Pre-Order agreement.
SECTION 10. CONTACT DETAILS
10.1. If you have any questions regarding these Privacy and AML/KYC Policy, please contact us at firstname.lastname@example.org.