KRIBATTA PRIVACY POLICY- LWG TRUST SERVICES LIMITED LIABILITY COMPANY
Effective Date: 1 October 2023
Introduction
LWG Trust Services Limited Liability Company (referred to as "LWG Trust Services," "we," "our," or "us") is responsible for processing your personal data when you use our products or services under the commercial name "KRIBATTA Wallet." Our company number is 3-102-812820, registered in the Republic of Costa Rica.
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 the following information:

• Technical information: IP address, login information, browser type and version, time zone setting, device language, operating system and platform, device type, unique device identifier, mobile network information, mobile operating system, and mobile browser type.
• Information about your visit: Links clicked, services viewed or searched for, page response times, download errors, length of visits, page interaction information, methods used to browse away from the page.
• Information on transactions: Payments into and out of your account, transaction details (date, time, amount, currencies, exchange rate, beneficiary details, merchant or ATM details), IP address of sender and receiver, sender's and receiver's name, messages sent or received, device used for the transaction, payment method.
• Information stored on your device: Contact information (with your permission), location information (if location services are enabled).

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. This includes credit record, late payments, identity verification, spouse and family information (for credit applications), transaction-related information.
Information from Social Media
We use publicly available information from social media websites or apps for enhanced due diligence checks and general searches to comply with anti-money laundering or sanctions screening obligations.

 

Information from Publicly Available Sources
We collect information and contact details from publicly available sources such as media stories, online registers, directories, and websites for enhanced due diligence checks, security searches, and KYC purposes.
4. What is Your Legal Basis for Using My Personal Data?
Our legal basis for processing your personal data includes:

• 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 for the following purposes:
Checking Your Identity
We use your personal data to verify your identity during account registration and KYC checks, including biometric data (photo, video, facial scan data).
Providing Our Services
We use your personal data to:

• Approve your applications
• Fulfill our contractual and legal obligations
• Process transactions and manage your account
• Provide customer support services
• Understand your spending behavior and improve our services
• Recover debts and exercise other rights under our agreements

Protecting Against Fraud
We use your personal data to verify your address and identity, prevent fraud, comply with financial crime laws, and assess fraud risks related to your account.
Marketing and Providing Products and Services
We use your personal data to:

• Personalize your experience and marketing messages
• Inform you about our partners’ promotions or offers
• Allow our partners to provide information about their products or services (with your consent)
• Ask for your opinion about our products or services

Managing Our Services
We use your personal data to:

• Manage and improve our website and app
• Authenticate you as an authorized user
• Allow you to participate in interactive features
• Inform you about changes to our services
• Ensure the security of our website and app

 

Helping with Social Interactions
We use your personal data to enhance social interactions and provide better services. For example, with your permission, we access your contacts list for easy payments and messaging through the KRIBATTA Wallet app.
Providing Location-Based Services
If you enable location services, we use your personal data to:

• Provide location-based services and advertising
• Protect against fraud

Preparing Anonymous Statistical Datasets
We prepare anonymous statistical datasets about customer spending patterns for forecasting, compliance with governmental requirements, and internal research. This data is not personal and cannot be linked back to you.
Improving Our Products and Services
We use your personal data to develop and improve our current products and services, including conducting focus groups and user testing.
Meeting Our Legal Obligations, Enforcing Our Rights, and Protecting Our Business
We use your personal data to:

• Share it with government authorities, law enforcement, and fraud prevention agencies
• Recover debts and enforce our rights
• Identify and support vulnerable customers
• Protect our rights, property, and personnel
• Prevent and fight harmful or unlawful behavior

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 to send marketing messages, we’ll do so in advance.
We use your personal data to personalize marketing messages about our products and services so they are more relevant and interesting to you (where allowed by law). This may include analyzing how you use our services and your transactions.
You can object to profiling for direct marketing purposes. You can also adjust your preferences or tell us you don't want to receive direct marketing at any time. Just use the privacy settings in the KRIBATTA Wallet app or tap the unsubscribe links in any marketing message we send you.
If you do not want to receive personalized marketing messages and opt out from receiving them, you will not receive any marketing communications. However, you may still receive generic information about our products and services in the KRIBATTA Wallet app.
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. You can find out more in the Do you share my personal data with anyone else? section below.
Our legal basis is:

• Consent: Where we are required by law to collect your consent.
• Legitimate Interests: To send you marketing and to provide information relevant to your interests.

9. What Are My Rights?
Your rights regarding your personal data include:
Right to Be Informed
You have the right to be informed about how we use your personal data. This privacy notice aims to provide you with that information.
Right of Access
You have the right to request access to the personal data we hold about you. We will provide a copy of your personal data unless it affects the rights and freedoms of others or is subject to legal restrictions.

Right to Rectification
You have the right to request correction of any inaccurate or incomplete personal data. We may need to verify the accuracy of the new data you provide.
Right to Erasure
You have the right to request deletion of your personal data if:

• It is no longer necessary for the purposes it was collected.
• You withdraw consent and no other legal basis for processing exists.
• You object to processing, and there are no overriding legitimate grounds.
• Your data has been unlawfully processed.
• Erasure is required to comply with legal obligations.

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 as outlined in this policy, 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.
If a third party exercises one of these rights on your behalf, we may ask for proof of authorization. Once we receive your request, we will respond within one month. In most cases, we will not charge a fee for your request. However, if your request is manifestly unfounded or excessive, we may charge a reasonable fee or refuse to act on the request.
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?
Within LWG Trust Services
We share your personal data within the LWG Trust Services group of companies to provide you with the best service, protect against fraud, facilitate your use of other products or services, improve existing services, and send you information about products and services.
Other KRIBATTA Wallet Customers
If you sync your phone contacts with the KRIBATTA Wallet app, we will help you identify which of your contacts are also KRIBATTA Wallet customers. Your contacts will see basic details about you if they are also KRIBATTA Wallet customers. You can change your discoverability preferences in the app.
Suppliers and Partners
We share your personal data with suppliers and partners to:

• Provide services (IT, payment, delivery, customer service)
• Verify your identity (KYC service providers)
• Manufacture and deliver your KRIBATTA Wallet card
• Improve our website or app (analytics providers)
• Send communications (email, push notifications, SMS)
• Manage and recover debts (debt collection agencies)

Credit Reference Agencies
We share your personal data with credit reference agencies for credit checks if you apply for a credit product. This includes verifying your identity, assessing creditworthiness, and monitoring credit agreements.
Other Financial Institutions
We may share your personal data with other financial institutions if you ask us to, for example, when you activate Open Banking or if a payment is made to your account by mistake.
Legal and Regulatory Authorities
We share your personal data with legal and regulatory authorities to comply with laws, investigate or protect against fraud, confirm eligibility for products and services, and in connection with legal claims.
Social Media and Advertising Companies
We may share your personal data with social media and advertising companies for marketing purposes. This includes using social media platforms to send you adverts for KRIBATTA Wallet products and services. You can manage your marketing preferences through the KRIBATTA Wallet app.
At Your Direction
If you direct us to share your personal data with a third party, we will do so. This may include authorizing third parties to act on your behalf.
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?
We use a variety of security measures to protect your personal data, including:

• 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. Please read our Cookies Policy for more information. 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.