Waterfort Bahrain BSC (c) Privacy Statement

Last updated: 7, June 2023

Waterfort Bahrain BSC (c) (“Waterfort”, “we” or “us”) takes its data protection responsibilities very seriously and is committed to protecting the privacy of its customers. Please read this privacy policy carefully as it contains important information on who are and how and why we collect, store, use and share your personal data in connection with the provision of Waterfort Bahrain BSC (c) Services. 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.

Waterfort Bahrain BSC (c) (Closed) is registered under Commercial Registration number 158099-1, and its registered address is at Flat 302, Building 551, Road 4612, Block 346, Manama Waterfront, Kingdom of Bahrain.

1. Personal Data we collect about you

The personal data we collect about you depends on the services we provide to you. Failure in providing the data required implies that Waterfort Bahrain BSC (c) will not be able to offer you our services. We will collect the following personal data, in the ways described below:

Information collected directly from you:

This is information you provide to us directly, for example when you open an account with us or access our services. This information is either information required by law (when for example we need to verify your identity and comply with “Know Your Customer” obligations), necessary to provide the requested services (for example your email when we need to open your account), or other cases as described below.

  • Personal Identification InformationSuch as full name, email address, date of birth, home address, phone address, nationality, signature, utility bills, photographs, and in some cases video recordings of you.
  • Government issued identity documentsSuch as copies of your passport, national identification number, national identity cards, drivers licences and any other required document to prove you are eligible to use our services.
  • Institutional InformationSuch as proof of address, personal identification information for all material beneficial owners, personal information about the board of directors, senior persons responsible for the operations of the body corporate.
  • Financial Information bank account informationPayment card information, source of funding, source of wealth.
  • Employment InformationSuch as job title, salary wage rate and company.
  • Transactional InformationWe get information about how you use our services, any transactions made and your device.

Information collected automatically:

To the extent permitted under the applicable law, we may collect certain types of information automatically, for example whenever you interact with us or use the services. This information helps us address customer support issues, improve the performance of our sites and services, maintain and or improve your user experience and protect your account from fraud by detecting unauthorised access.

  • Browsing InformationDevice ID, browsing information such as name and version, IP address.
  • Usage dataAuthentication data, security questions, and other data collected via cookie or similar technologies. We can also collect information about how our services are performing when you use them.
  • Marketing and research information

Information we collect from our affiliated and third parties:

From time to time, we may obtain information about you from our affiliates, or third parties’ sources as required or permitted by applicable law.

  • Affiliates
  • Third partiesWe may collect personal data from third parties, such as credit reference agencies, financial or credit institutions, official registers, and databases, as well as fraud prevention agencies and partners who help us to provide services.
  • Blockchain DataWe may analyse public blockchain data, such as transaction ID’s, transactions amounts, wallet address, wallet address, timestamps or transactions or events.

2. How do you use my personal data?

Below you will find information about the way we use your personal data and why we do this.

What we use your personal data forOur Legal Basis for using your personal data
Managing our contractual relationship with you. To create and maintain your account and provide our services

If you apply to use Waterfort Bahrain BSC (c) products or services, we will use your personal data to take and handle orders and process payments.

The type of personal data processed is Personal Identification Information, Institutional Information, Financial Information. The consequences of not processing your personal data for such purposes is the inability to open an account with us or the termination of your account where one is already open.

Processing is necessary for the performance of a contract of which you are a party.

To maintain legal and regulatory compliance

Most of our services such as the liquidity and trade services are subject to strict and specific laws and regulations requiring us to collect, use and store certain personal data and process Personal Identification Information and in some cases sensitive personal data (including biometrics). For example, to comply with our Know Your Customer (“KYC”) obligations under applicable laws and regulations, and to comply with Anti-Money Laundering laws and regulations.

The personal data processed is Personal Identification Information, Institutional Information, sensitive and biometric Personal Information, Government Issued Identity documents, Financial Information.

If you do not provide personal information required by law, you may be unable to open an account, or we may have to close your account where it is already opened.

Processing is necessary to comply with our legal obligations under applicable laws and regulations, and Anti-Money Laundering laws and regulations.

Communicate with you on service and transaction- related matters

We use your personal data to communicate with you in relation to our services on administrative or account-related information. We will communicate with you to keep you updated about our services, for example, to inform you of relevant security issues, updates, or provide other transaction-related information. Without such communications, you may not be aware of important developments relating to your account that may affect how you can use our services.

You may not opt-out of receiving critical service communications, such as emails or mobile notifications sent for legal or security purposes.

Processing is necessary for the performance of a contract of which you are a party.

To provide customer services

We process your personal data when you contact us to provide support with respect to questions, disputes, complaints, troubleshoot problems, etc.

The personal data processed is Personal Identification Information, Institutional Information, Transactional Information, Financial Information, Browsing Information, Usage Data.

Without processing your personal information for this purpose, we can’t respond to your requests.

Processing is necessary for the performance of a contract of which you are a party.

Processing is necessary for the purpose of the legitimate interest pursued by us to improve our services and enhance our user experience.

To promote safety, security, and integrity of our platform

We process your personal data to enhance security, monitor and verify identity or service access, combat malware or security risks and to comply with applicable security laws and regulations.

We process your personal data to verify accounts and related activity, find and address violations of our Terms and Conditions, investigate suspicious activity, detect, prevent, and combat unlawful behaviour, detect fraud, and maintain the integrity of our Services.

The Type of Information processed is Personal Identification Information, Institutional Information, Transactional Information, Contact Information, Financial Information, Browsing Information, Usage Data.

Without processing your personal information, we may not be able to ensure the security of our services.

We use your personal information to provide functionality, analyse performance, fix errors, and improve the usability and effectiveness of our services.

Processing is necessary for the performance of a contract of which you are a party.

Fraud prevention and detection and credit risks

We process Personal Identification Information to prevent and detect, prevent, and mitigate fraud and abuse of our services and in order to protect you against account compromise or funds loss and in order to ensure the security of our users, our services, and others. We may also use scoring methods to assess and manage credit risks.

The personal data processed will be Personal Identification Information, Institutional Information, Transactional Information, Financial Information, Browsing Information, Usage Data.

Processing is necessary for the purpose of the legitimate interests pursued by us and the interests of our users when, for example, we detect and prevent fraud and abuse to protect the security of our users, ourselves, or others.

To comply with other legal and regulatory obligations

We may access, read, preserve, and disclose information when we believe it is reasonably necessary to comply with law, legal obligations, regulations, law enforcement, government, and other legal requests, court orders, or disclosure to tax authorities.

The Type of personal data processed is Personal Identification Information, Institutional Information, Financial Information, Transactional Information, Browsing Information, Usage Data, Blockchain Data.

Processing is necessary to comply with our legal obligations under applicable laws and regulations.

We may also rely on legitimate interests in responding to legal requests where we are not compelled by applicable law but have a good faith belief it is required by law in the relevant jurisdiction.

Recommendations and personalisation

We use your personal data to recommend features and services that might be of interest to you, identify your preferences, and personalise your experience with our services.

Processing is necessary for the purpose of our legitimate interest to provide a personalised service to our customers.

Processing is necessary for the performance of a contract of which you are a party.

To provide you with promotions

We use your information to provide you with promotions, including offers, rewards, and other incentives for using our Services.

The Type of Information processed is Personal Identification Information, Institutional Information, Transactional Information, Browsing Information, Usage Data.

Processing is necessary for the purpose of our legitimate interest and your interest to reward your customer loyalty.

To provide marketing communications to you

We use your information based on your consent to send you targeted marketing communications through email, mobile, in-app, and push notifications.

We also use your information to carry out profiling for marketing purposes.

The Type of Information processed is Personal Identification Information, Institutional Information, Transactional Information, Browsing Information, Usage Data, Marketing and Research Information, Communications.

Where required by applicable law, we rely on your consent to process your personal information for marketing purposes. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time and we will stop processing your personal information for that purpose. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

Where we carry out profiling for marketing purposes, for example to establish what Services or promotions you may be interested in, this processing is based on legitimate interest.

Cookies

Where we use cookies and similar technologies as part of our Service. The type of Information processed is Information from Cookies.

Where required by applicable law, we rely on your consent to place cookies and similar technologies. When you consent to processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop processing your personal information for that purpose.

The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

3. What about cookies and other identifiers?

Our website uses cookies and similar tools to enhance your user experience, provide our services, enhance our marketing efforts, and understand how users use our services to enable us to make improvements. A cookie is a small piece of data that a website stores on a user/ visitor's computer or mobile device.

4. Do you share my personal data with third parties?

We may share personal information with the following persons or in the following circumstances:

  • AffiliatesPersonal data that we process and collect may be transferred between affiliates as a normal part of conducting business and offering our services to you.
  • Third party service providersWe employ other companies and individuals to perform functions on our behalf. Examples include analysing data, providing marketing assistance, processing payments, transmitting content, and assessing and managing credit risk. The third-party service providers only have access to personal data needed to perform their functions but may not use it for other purposes. Further, they must process the personal information in accordance with our contractual agreements and only as permitted by applicable data protection laws.
  • Legal AuthoritiesWe may be required by law or by Court to disclose certain information about you or any engagement we may have with you to relevant regulatory, law enforcement and/or other competent authorities. We will disclose information about you to legal authorities to the extent we are obliged to do so according to the law. We may also need to share your information to enforce or apply our legal rights or to prevent fraud.
  • Business transfersAs we continue to develop our business, we might sell or buy other businesses or services. In such transactions, user information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Privacy Notice (unless, of course, the user consents otherwise). Also, in the unlikely event that Waterfort Bahrain BSC (c) or substantially all of its assets are acquired by a third party, user information will be one of the transferred assets.
  • Protection of Waterfort Bahrain BSC (c) and othersWe release accounts and other personal data when we believe release is appropriate to comply with the law or with our regulatory obligations; enforce or apply our Terms of Use and other agreements; or protect the rights, property or safety of Waterfort Bahrain BSC (c), our users, or others. This includes exchanging information with other companies and organisations for fraud protection and credit risk reduction.

5. International transfers of personal data

To facilitate our global operations, we may transfer your personal information outside the Kingdom of Bahrain. We put in place suitable safeguards to ensure that such transfers are carried out in compliance with applicable data protection laws.

Where we transfer personal data to affiliates or service providers, Waterfort Bahrain BSC (c) relies on the latest standard contractual clauses of Bahrain Data Protection Law'.

6. How secure is my data?

We design our systems with paramount importance placed on the security and privacy of your data. We have appropriate security measures in place to prevent your information being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed.  We work to protect the security of your personal data during transmission and while stored by using encryption protocols and software.

We maintain physical, electronic, and procedural safeguards in connection with the collection, storage, and disclosure of your personal data. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.

Our security procedures mean that we may ask you to verify your identity to protect you against unauthorised access to your account password. We recommend using a unique password for your account that is not utilised for other online accounts and to sign off when you finish using your shared computer.

7. What about advertising?

In order for us to provide you with the best user experience, we may share your personal data with our marketing partners for the purposes of targeting, modelling, and/or analytics as well as marketing and advertising.

You have a right to object at any time to processing of your personal data for direct marketing purposes. 

8. What rights do I have?

When you consent to our processing your personal information for a specified purpose, you may withdraw your consent at any time, and we will stop any further processing of your data for that purpose.

As outlined below, you have a number of rights in relation to your privacy and the protection of your personal data. You have the right to be informed, rectify, and erase your personal information and to ask for data portability. You may also object to our processing of your personal information or ask that we restrict the processing of your personal data in certain instances. In addition, when you consent to our processing of your personal information for a specified purpose, you may withdraw your consent at any time. you have the rights enumerated below. If you wish to do any of these things, please contact info@waterfort.io. These rights may be limited in some situations - for example, where we can demonstrate we have a legal requirement to process your personal data.

  • Right to be informedYou have the right to be informed about the processing activities related to your personal data.
  • Right to rectificationYou can request the rectification of your personal data, which is inaccurate, or incomplete. You can also change your personal data in your account at any time.
  • Right to erasureYou can, in some cases, have your personal information deleted.
  • Right to objectYou can object, for reasons relating to your situation, to the processing of your personal information. For instance, you have the right to object where we rely on legitimate interest or where we process your data for direct marketing purposes.
  • Right to restrict processingYou have the right, in certain cases, to temporarily restrict the processing of your personal information by us, provided there are valid grounds for doing so. We may continue to process your personal information if it is necessary for the defence of legal claims, or for any other exceptions permitted by applicable laws.
  • Right to withdraw your consentFor processing requiring your consent, you have the right to withdraw your consent at any time. Exercising this right does not affect the lawfulness of the processing based on the consent given before the withdrawal of the latter.

9. Notices and revisions

If you have any concerns about privacy at Waterfort Bahrain BSC (c), please contact us. Our business changes regularly, and our Privacy Notice may change also. You should check our websites frequently to see recent changes.

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Waterfort Bahrain BSC (c) is Licensed by the Central Bank of Bahrain as a ‘Category 3’ Crypto Asset Service Provider.