HaboWallet.com takes privacy seriously and cares about personal information.
We will review this policy regularly, and we may update it from time to time.
We collect personal information about our users in order provide our products, services, and customer support. Our products, services, and customer support are provided through many platforms including but not limited to: websites, phone apps, email, and telephone. The specific platform and product, service, or support you interact with may affect the personal data we collect.
While you use our products and services you may be asked to provide certain types of personal information. This might happen through our website, applications, online chat systems, telephone, paper forms, or in-person meetings. We will give you a Collection Notice at the time, to explain how we will use the personal information we are asking for. The notice may be written or verbal.
We may request, collect, or process the following information:
Users have the ability to start a transaction with non-users by providing contact details such as email address, physical address, and phone number. In these situations, the information will be collected and stored by us to contact the non-user and to prevent abuse of our systems.
Your payment provider may transmit information about the payment that we may collect or process.
In some situations, personal information of users may be collected from public sources.
We may collect or process the following information:
We maintain records of the interactions we have with our users, including the products, services and customer support we have provided. This includes the interactions our users have with our platform such as when a user has viewed a page or clicked a button.
When we are contacted we may collect personal information that is intrinsic to the communication. For example, if we are contacted via email, we will collect the email address used.
We may collect or process the following (mostly non PII) information:
The information we request, collect, and process is primarily used to provide users with the product or service they have requested. More specifically, we may use your personal information for the following purposes:
The 'lawful processing' grounds on which we will use personal information about our users are (but are not limited to):
We may disclose your personal information to third parties that participate in a transaction with you, including but not limited to:
The personal information of users may be held or processed on our behalf outside Australia, including 'in the cloud', by our third party service providers. Our third party service providers are bound by contract to only use your personal information on our behalf, under our instructions.
Our third party service providers include:
We may also disclose your personal information to third parties for the following purposes:
As we are a global company, with offices around the world, your personal information may be processed by staff in any of our offices. Escrow currently has offices in The United States of America, Australia, The Philippines, Canada, and Argentina.
You have the right to request access to the personal information Escrow holds about you. Unless an exception applies, we must allow you to see the personal information we hold about you, within a reasonable time period, and without unreasonable expense for no charge. Most personal information can be accessed by logging into your account. If you wish to access information that is not accessible through the platform, or wish to download all personal information we hold on you in a portable data format, please contact our Privacy Officer.
You also have the right to request the correction of the personal information we hold about you. All your personal information can be updated through the user settings pages. If you require assistance please contact our customer support.
You have a number of other rights in relation to the personal data Escrow holds about you, however, there may be restrictions on how you may exercise the rights. This is largely due to the nature of the products and services we provide. Much of the data we collect is in order to facilitate contracts between users, facilitate payments, provide protection for the legitimate users, and meet our legal obligations - these data uses are protected against the below rights.
You have the right to:
Direct marketing and profiling - users can unsubscribe by following the link included at the bottom of each email.
Erasure - Most personal information cannot be deleted as they are used to support contracts between users, document financial transactions, and are used in providing protection for users on the platform. In the case of non-personal data that can be linked with personal data, it will either be erased or otherwise anonymised from the personal data.
Temporary restriction to processing - under certain circumstances you may exercise this right, in particular if you believe that the personal data we have is not accurate, or you believe that we do not have legitimate grounds for processing your information. In either case you may exercise this right by contacting our privacy officer.
Unless stated above, users may exercise any of the above rights by contacting our Privacy Officer.
If you have an enquiry or a complaint about the way we handle your personal information, or to seek to exercise your privacy rights in relation to the personal information we hold about you, you may contact our Privacy Officer as follows:
By Email: [email protected]
By Mail: Attn: Privacy Officer 180 Montgomery Street Suite 650 San Francisco, CA 94104 United States
For the purposes of the GDPR, our Privacy Officer is also our Data Protection Officer (DPO).
While we endeavour to resolve complaints quickly and informally, if you wish to proceed to a formal privacy complaint, we request that you make your complaint in writing to our Privacy Officer, by mail or email as above. We will acknowledge your formal complaint within 10 working days.
If you are in the European Union, you can choose to lodge a complaint with your local Data Protection Authority (DPA). The list of DPAs is at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.