1.  Introduction

The WrappedCBDC Limited (referred to here as we, us, our, WrappedCBDC, ASC, Company) is a Nigerian Company developing digital tokens pegged to CBDCs, that will facilitate seamless transactions between holders of the token and users of other cryptocurrencies, i.e. would run on diverse supported blockchains, to ensure ease of use.

2.  Overview

This Privacy (“Privacy Policy”) describes how we collect, use, store, share, and protect personal data from Website Visitors and Users (“Data Subjects”) who engage with our services and products. It applies to our website and all related sites, applications, services and tools (collectively, our “Services”).

By using or accessing our Services, you agree to the collection, use, and disclosure of your personal data as described in this Privacy Policy. Your use of our Services is also subject to our Terms of Use.

3.  Information We Collect

The personal data we collect depends on how you interact with us, the services you use, and the choices you make. We may collect information from different sources and in various ways, including information you provide directly, information collected automatically, third-party data sources, and data we infer or generate from other data.

3.1  Personal Data You Provide 

We collect the personal data you provide to us. For example:

• Basic Customer information: As part of our operations, we may collect information such as your name, telephone numbers, email, address, date of birth, nationality etc;

• Identification information: Utility bills (for your billing address), Photographs and/or videos, Government-issued identity details (e.g. passport, driver’s license, NIN, or BVN), Employment information (e.g. company name), Proof of residency, including visa information;

• Corporate Information: In providing our services to a corporate entity, we may collect corporate information such as certificate of incorporation, memorandum and articles of association, identity details of directors and controlling shareholders etc;

• Financial Information: Bank account number, debit/credit card details, Trading and investment experience, Tax identification number, bank statement, Income/net assets/wealth verification statements;

• Wallet Information: We collect your wallet address information when you use our services to enable us to process your transactions;

• Communications. If you contact us directly, for example, with an inquiry or a support request, we may receive additional personal data about you, including your email address and the content of your communications.

• Referral Information: Name, phone number or email addresses if you choose to invite friends.

3.2  Personal Data We Collect Automatically

• Device Information. We receive information about the device and software you use to access our Services, including Internet Protocol (IP) address, web browser type, operating system version, and device identifiers.

• Usage Information. To help us understand how you use our Services, and to help us improve them, we automatically receive information about your interactions with our Services. This information includes records of your transactions and information about your other activities related to our services, such as the date and time of your sessions, the pages you view, links to/from any page, and time spent in a session. Some of the data we gather through the use of cookies and similar technologies is discussed below.

• Location Information. When you use our Services, we may collect or infer your general location information. For example, your IP address may indicate your general geographic region.

3.3  Personal Data That We Receive from Others or Infer

• Partners. We may retrieve additional personal data about you from third parties and other identification/verification services such as your financial institution and payment processor. We may combine that data with other information we have about you.

• Blockchain data: We may analyze public blockchain data, including timestamps of transactions or events, transaction IDs, digital signatures, transaction amounts, and wallet addresses

• Publicly available sources. Public sources of information such as open government databases.

• Inferences. We may infer additional Personal Data based on the Personal Data described above. For example, for site visitors, we may infer your interests based on the web pages you view.

When you are asked to provide personal data, you may decline, you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

4.0 How we use your personal information

We use the Personal Data we collect to:

1. Establish and maintain a commercial relationship with you (creation and management of your account with us.

2. Deliver our services to you.

3. Respond to your questions or requests.

4. Improve features, website content, and analyse data to develop products and services

5. Address inappropriate use of our website.

6. As may be required by applicable laws and regulations, including for compliance with Know Your Customers and risk assessment, Anti-Money Laundering, anti-corruption and sanctions screening requirements, or as requested by any judicial process, law enforcement or governmental agency having or claiming jurisdiction over WrappedCBDC or WrappedCBDC’s affiliates.

7. Prevent, detect and manage risk against fraud and illegal activities using internal and third-party screening tools.

8. Send you marketing content, newsletters and service updates curated by WrappedCBDC (only with your explicit consent).

9. Verify your identity and the information you provide in line with WrappedCBDC’s statutory obligations using internal and third-party tools.

10. Maintain up-to-date records.

11. Resolve disputes that may arise.

12. Any other purpose that we disclose to you in the course of providing WrappedCBDC services to you.

5.0  How We Share Your Personal Information

As necessary, we may share your Personal Information with:

1. Our service providers, to the extent necessary to supply the Services to you

2. Selected third parties, including analytics and search engine providers that assist us in the improvement and optimization of the Services.

3. Advisors, regulators, tax authorities, law enforcement, government agencies, and industry partners to:

• respond pursuant to applicable law or regulations, court orders, legal process or government requests; 

• comply with our reporting and information-sharing obligations with industry partners, including other Virtual Asset Service Providers (“VASPs”) and regulatory authorities; 

• detect, investigate, prevent, or address fraud and other illegal activity or security and technical issues; and 

• protect the rights, property, and safety of our Customers, WrappedCBDC and its Affiliates, or others, including to prevent death or imminent bodily harm.

We may also disclose your Personal Information to third parties:

1. In the event that WrappedCBDC or substantially all of its assets are acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets.

2. If we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or in order to enforce or apply our Terms of Service and other agreements; or to protect the rights, property, or safety of us, our clients, or others, including to defend ourselves from legal claims.

WrappedCBDC reserves the right to share current and historical bids, asks, and market prices; opening and closing range prices; high–low prices; trade prices; estimated and actual trade volumes; settlement prices; and other aggregate data and information related to the digital tokens traded on the Site.

6.0  Cookies

Similar to other websites, we use cookies to distinguish you from other users and to customize and improve our services.

Some browsers may automatically accept cookies while some can be modified to decline cookies or alert you when a website wants to place a cookie on your computer. If you do choose to disable cookies, it may limit your ability to use our website.

7.0  Minors’ Personal Information

WrappedCBDC’s services are not directed to persons under the age of 18, and we will not deliberately request or collect any information about persons under the age of 18. If you are under the age of 18, please do not provide any personal information to us. If a User or Customer submitting personal information is suspected of being younger than 18 years of age, We will require the relevant Customer or User to close his or her account and will take steps to delete the individual’s information as soon as possible.

Where you have any belief that WrappedCBDC has mistakenly or unknowingly collected information from a minor, please contact us at contact@asc.africa to enable us to investigate and restrict such data.

8.0  Data Security

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. We maintain adequate controls in order to protect the integrity and confidentiality of personal data, both in digital and physical format and to prevent personal data from accidental or deliberate breach. 

Other security measures include but are not limited to, secure servers, firewalls, data encryption and granting access only to employees in order to fulfil their job responsibilities. Employees may have access to personal data only as is appropriate for the type and scope of the task in question and are contractually forbidden to use personal data for their own private or commercial purposes to disclose them to unauthorised persons, or to make them available in any other way.

When you use a password for any of your Accounts, please ensure that the password is unique, that you do not share this with anyone, and the password is kept confidential at all times.

Two-factor authentication (“2FA”) is an added layer of security for your account. When 2FA is enabled, you will be required to enter a One Time Password (OTP) (which you get via email or text or from a 2FA Application), each time you are logging in to your account or carrying out transactions. We encourage you to enable this feature. However, if you choose to disable this feature, you agree that We shall not be liable for any loss or damages incurred as a result of your action.

9.0 Data Retention

We will only retain personal information on our servers for as long as is reasonably necessary as long as we are providing Services to you. Where you close your Account, your information is stored on our servers to the extent necessary to comply with regulatory obligations and for the purpose of fraud monitoring, detection and prevention. Where we retain your Personal Information, we do so in compliance with limitation periods under the applicable law.

Our third-party identity verification service providers retain this information for as long as set out in their applicable notices/policies. 

10.0 Data Transfer

As part of our service provision, we may rely on third-party servers, databases co-located with hosting providers, residents in foreign jurisdictions, which constitutes the transfer of your personal data to computers or servers in foreign countries. We take steps designed to ensure that the data we collect under this Privacy Policy is processed and protected according to the provisions of this Policy and applicable law wherever the data is located.

Where personal data is to be transferred to a country outside Nigeria, WrappedCBDC shall put adequate measures in place to ensure the security of such personal data. Any transfer of personal data out of Nigeria will be in accordance with the provisions of relevant data protection regulations. In particular, WrappedCBDC shall, among other things, use contractual terms to ensure the protection of the data.

Should you wish to transfer personal data to a country deemed to have inadequate data protection laws, WrappedCBDC will take all necessary steps to ensure that informed consent is obtained from you, and that you are aware of the risks entailed with such transfer. In any instance, We will ensure personal data is transmitted in a safe and secure manner. Details of the protection given when your personal data is transferred abroad, and details of the basis of such transfers shall be provided to you upon request.

11.0  Data Protection Rights

You have a number of rights in relation to how we process your Personal Information. These include the right to:

1. access your Personal Information that we may hold;

2. rectify any inaccurate Personal Information that we may hold about you;

3. have your Personal Information deleted in certain circumstances, for example, where it is no longer necessary for us to process your Personal Information to fulfill our processing purposes; or where you have exercised your right to object to the processing;

4. restrict the processing of your Personal Information where, for example, the information is inaccurate or it is no longer necessary for us to process such information or where you have exercised your right to object to our processing;

5. object to the processing of your Personal Information which may be exercised in certain circumstances, for example, where we are processing your Personal Information for direct marketing purposes, or where your own legitimate interests outweigh ours;

6. submit a complaint to the National Data Protection Commission (NDPC).

If you wish to exercise any of the above rights, you may contact us at contact@asc.africa

12.0  Changes to this Privacy Policy

We are constantly trying to improve on our services and incorporate changes in laws and regulations into our service delivery. Thus, we may change, amend or review this Privacy Policy from time to time to reflect new services or changes in our Privacy Policy and place any updates on this page. All changes made will be posted on this page and where changes will materially affect you, we will notify you of this change by placing a notice online or via mail. If you keep using our Services, you consent to all amendments of this Privacy Policy.

13.0  Contact Us

If you have any enquiries about this Privacy Policy, you may contact us at: contact@asc.africa