Privacy Policy

1. About Us

LWG Trust Services Limited Liability Company provides various financial services, including the KRIBATTA Wallet. We are the controller of your personal data and are responsible for ensuring it is processed in accordance with applicable laws.

2. Why Do I Need to Read This Notice?

This notice explains what personal data we collect, how we use it, and your rights regarding your data. We collect your personal data when you interact with us, use our website, applications, or any of our services.

3. What Personal Data Do We Collect About You?

Information You Give Us — We collect information you provide when you:

• Fill in forms
• Correspond with us
• Respond to surveys
• Register for KRIBATTA Wallet
• Open an account or use our services
• Grant us access to your financial accounts
• Participate in promotions or discussions
• Contact our customer support teams
• Enter competitions or share information on social media

We collect the following information:

• Name, address, date of birth
• Email address, phone number, device details
• Registration information
• Bank account details, including account number, sort code, and IBAN
• Debit and credit card details, including card number, expiry date, and CVC
• Identification documents (passport or driving license)
• Country of residence, tax residency information, and tax identification number
• Income and financial obligations (for credit applications)
• Employment and salary information (for wealth and trading products)
• Records of our discussions, including phone calls
• Biometric data (photo, video, facial scan data)
• Information about other people (joint account holder, spouse, family)

Information Collected from Your Use of Our Products and Services — Whenever you use our website or the KRIBATTA Wallet app, we collect technical information (IP address, login information, browser type and version, time zone, device language, operating system and platform, device type, unique device identifier, mobile network information), information about your visit (links clicked, services viewed or searched for, page response times, download errors, length of visits, page interaction information), information on transactions (payments into and out of your account, transaction details, IP address of sender and receiver, names, messages, device used, payment method), and information stored on your device (contact information and location information, with your permission).

Information from Others — We collect personal data from third parties such as credit reference agencies, financial or credit institutions, official registers, joint account holders, fraud prevention agencies, and partners. We also use publicly available information from social media and other publicly available sources for enhanced due diligence checks, security searches, and KYC purposes.

4. What is Your Legal Basis for Using My Personal Data?

• Contractual Obligations: To provide our services and fulfill our contracts with you.
• Legal Obligations: To comply with laws and regulations, such as anti-money laundering laws.
• Legitimate Interests: To manage our business, improve our services, prevent fraud, and protect our interests.
• Consent: Where you have given us explicit consent.

5. How Do You Use My Personal Data?

We use your personal data to check your identity (including biometric data during account registration and KYC checks), provide our services (approve applications, fulfill contractual and legal obligations, process transactions, manage your account, provide customer support, understand spending behavior, recover debts), protect against fraud, deliver marketing and provide products and services, manage and improve our website and app, help with social interactions, provide location-based services, prepare anonymous statistical datasets, improve our products and services, and meet our legal obligations, enforce our rights, and protect our business.

6. Do You Make Automated Decisions About Me?

We may use technology to make automated decisions about you for efficient service delivery. This includes credit checks, identity verification, and fraud detection. You have the right to request a manual review of such decisions.

7. Do You Run Credit Checks on Me?

We use credit reference agencies to run credit checks if you apply for a credit product. This includes verifying your identity, assessing your creditworthiness, and monitoring your credit agreements.

8. How Do You Use My Personal Data for Marketing?

If you sign up to our services, and where national laws allow, we'll assume you want to be contacted by post, push notification, email, and text message with information about KRIBATTA Wallet products, services, offers, and promotions. Where national laws require us to get your consent, we'll do so in advance. You can object to profiling for direct marketing purposes and adjust your preferences or unsubscribe at any time using the privacy settings in the KRIBATTA Wallet app or the unsubscribe links in any marketing message. We won't pass your details on to any organizations outside the LWG Trust Services group of companies for their marketing purposes without your permission.

9. What Are My Rights?

• Right to Be Informed: You have the right to be informed about how we use your personal data.
• Right of Access: You have the right to request access to the personal data we hold about you.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances.

We may not be able to comply with your request in certain circumstances, such as when legal or regulatory obligations require us to retain your data.

10. How Do I Exercise My Rights?

To exercise any of your rights, you can contact us through the KRIBATTA Wallet app or send us an email at privacy@kribatta.com. For security reasons, we may need to verify your identity before processing your request. Once we receive your request, we will respond within one month. If you are unhappy with how we have handled your request, you have the right to lodge a complaint with your local data protection authority.

11. Do You Share My Personal Data with Anyone Else?

We share your personal data within the LWG Trust Services group of companies, with other KRIBATTA Wallet customers (if you sync your contacts), with suppliers and partners (IT, payment, delivery, customer service, KYC verification, card manufacturing, analytics, communications, debt recovery), with credit reference agencies, with other financial institutions (if you ask us to, e.g. Open Banking), with legal and regulatory authorities, with social media and advertising companies for marketing purposes, and at your direction.

12. Will My Personal Data Go Outside the United Kingdom or Europe?

As we provide international services, your personal data may be transferred outside the UK or EEA. This includes sending funds to banks outside these regions, complying with global legal requirements, providing support services, and fraud prevention. We ensure your data is protected through contracts with strict data protection safeguards.

13. How Do You Protect My Personal Data?

• Organizational measures: Data protection policies, employee training, and access controls.
• Technical measures: Encryption, secure storage, and HTTPS for secure communication.
• Vetting third parties before sharing your data.

While we take reasonable steps to protect your data during transmission, we cannot guarantee its security. Keep your KRIBATTA Wallet app credentials confidential and do not share them with anyone.

14. How Long Will You Keep My Personal Data?

We retain your personal data as long as necessary for the purposes it was collected, in line with relevant laws. This includes complying with KYC, anti-money laundering, banking, and e-money regulations. We may retain your data for a longer period if required for legal claims or other legal reasons.

15. How Will You Keep Me Updated About How You Use My Personal Data?

If we change the way we use your personal data, we will update this notice and, if appropriate, inform you via email, the KRIBATTA Wallet app, or our website.

16. Do You Use Cookies?

We use cookies to analyze how you use our website. We also use pixels or web beacons in marketing emails to track delivery, opens, and link clicks. You can control whether you receive marketing emails through the KRIBATTA Wallet app's privacy settings.

At LWG Trust Services, your privacy and data security are our top priorities. We are dedicated to protecting your information and maintaining your trust. If you have any questions or concerns about your personal data, please reach out to us at support@kribatta.com.