The purpose of this policy is for users to know how the personal data they provide to WANYA is processed and protected.
THE METEOR COMPANY S.A.C. (hereinafter, "WANYA") is a company incorporated under the laws of the Republic of Peru, with tax domicile at Avenida José Larco N° 1232, interior 434 (Piso 11), identified with Taxpayer Registry (RUC) N° 20610139869, with Exchange House Registry approved under SBS Resolution No. 04052-2022 and registered in Electronic Item No. 15116890 of the Registries of Legal Entities of Lima.
We are a company dedicated to providing solutions in blockchain and Virtual Assets, we focus on facilitating access and management of virtual assets in a secure and efficient way.
Our platform allows users to buy, sell, and store Virtual Assets, as well as offering trading tools and prepaid cards. We are committed to empowering our customers by providing a trusted bridge to the digital economy (hereinafter referred to as the "Platform").
This policy provides information about how we handle your personal data, your right to privacy, and how the law protects you.
Therefore, before carrying out any interaction or operation on the platform it is essential that you know and agree to all the details of this policy. If you do not agree with it, please do not access this platform, or any linked website.
All user information collected on the platform will be kept protected in accordance with the privacy policies set forth below.
WANYA complies with all current laws related to the protection of personal data in the Republic of Peru, especially with the rules and principles established by Law No. 29733 (Personal Data Protection Law), its regulations and its amendments.
In this sense, all your personal data will be stored in a database of our ownership that is registered in the National Registry of Personal Data Protection of the National Authority for the Protection of Personal Data of Peru.
Likewise, WANYA is an entity obliged to report to the Financial Intelligence Unit (UIF) of the Superintendence of Banking, Insurance and Pension Fund Administrators (SBS) and as such will strictly comply with the requirements that the UIF or any competent authority formulates. This includes that the UIF can request information about users' personal data.
WANYA guarantees that the internal processes of the personal databases comply with the legal obligations of security and confidentiality imposed by the Personal Data Protection Law.
When this policy refers to the "use" or "processing" that WANYA makes of users' personal data, it is understood as any operation or technical procedure, automated or not, that allows the collection, recording, organization, storage, conservation, elaboration, modification, extraction, consultation, use, blocking, deletion, communication by transfer or dissemination or any other form of processing that facilitates, the access, correlation or interconnection of users' personal data.
Users authorise, by means of their signature or any other form of automated express acceptance, the processing of the personal data (including image and voice) that they provide to WANYA, by any physical or electronic means, in accordance with the purposes described in this policy.
This policy covers all information that the user provides to WANYA through the platform, social media pages and any other means or websites associated with the use and promotion of our products and services.
Any natural or legal person who accesses or uses in any way the services of WANYA (hereinafter, the "services"), will be considered as a user and consents to their information being collected, used and disclosed in accordance with the provisions of this Policy.
WANYA will not disclose the information provided to any external organization, unless it previously has the authorization of the client and/or is required by Law or by resolution of a competent authority.
According to Law No. 29733, personal data is all information that identifies the user. When using the WANYA platform, we will ask users to provide us with the following information:
Nickname or pseudonym to trade on the platform
Names and surnames
Personal image or selfie
Identity Document
Sex
Nationality
Marital status
Spouse's first and last names
Photograph of the front and back of the Identity Document
Contact information (phone, address, email, etc.)
Occupation, profession or economic activity (includes PEP or obligated subject status)
Internet Protocol
IP address
Platform usage statistics
Documentation that justifies the operation above the limits established by the regulatory entities, if applicable.
In case of finding or suspecting any improper transaction, WANYA may request additional information from the user. Likewise, the user will be required to provide their personal data with a certain frequency to carry out new identity verifications.
Not updating personal data can limit the use of the platform and may even be grounds for terminating the account.
To use the WANYA platform, the user must create an account and complete a registration.
User account: The user will have a pseudonym and a personal password to use the platform. The user must keep this data under absolute confidentiality and must not reveal or share it with other people.
Registration form: It is a questionnaire that the user must complete and that has the character of an affidavit. When filling out the form, users are obliged to provide true, accurate, complete and updated data.
Users assume responsibility for updating the modification of their personal data on the platform and assume responsibility for failing to comply with this obligation. In addition, the inaccuracy or falsehood of the personal data provided may be grounds for WANYA to suspend the account immediately.
Usage statistics: WANYA collects the statistics of the use of the platform, i.e. it collects the Internet Protocol (IP address, browser type and version, time and date of use of the platform, cookies, etc.) of the user.
Other means: WANYA may collect personal data from users through email, contact forms and/or other means of communication.
AUTOMATIC DATA REVIEW MECHANISMS
WANYA may use automated systems, including artificial intelligence, for identity verification and monitoring of user activities. These systems are mainly used to prevent fraud and validate the identity of users.
Users have the right to request a manual review of automated decisions if they believe there has been an error in the process. To do so, users must contact WANYA through the email address provided in this policy.
We do not collect data from children under the age of eighteen (18) without verified parental consent. If we discover that we have collected personal data from a person under the age of eighteen (18) without parental consent, we will delete that information immediately.
WANYA uses users' personal data only for the following purposes:
Identity Validation: This refers to the personal data necessary to log in and verify that only the user can access their account. This helps prevent account theft and impersonation.
Platform services: Refers to the personal data necessary to contract and use the services of the WANYA platform.
Improve user experience: This refers to personal data necessary to improve the user experience.
Supervisory Bodies: Refers to the personal data that may be required by the competent authorities of the Republic of Peru according to the laws and regulations in force.
Marketing and Promotions: Optionally, users may authorize to receive promotions, offers, and other communications from WANYA.
In the event that WANYA needs to use users' personal data for a purpose other than those mentioned, this Policy will be updated and the reasons for the requirement will be explained, obtaining the consent of the users for such purposes.
WANYA is governed by the provisions of Law No. 29733, in that sense, the services we provide on our platform are carried out under the following principles:
Lawfulness: We do not collect personal data from our users by fraudulent, unfair or illicit means.
Consent: We do not collect personal data from our users without their consent.
Purpose: Our users' personal data is collected for the purposes described in this policy and will not be used by WANYA without the user's consent.
Proportionality: WANYA will only use its users' personal data in an appropriate, relevant and not excessive manner according to the purpose for which it was collected.
Quality: Personal data will be truthful, accurate, up-to-date, necessary, pertinent and appropriate with respect to the purposes for which they were collected.
Security: Personal data will be kept in such a way as to guarantee its security and only for the time necessary to fulfill the purposes for which it was collected.
WANYA declares that it has appropriate security measures in place for the purposes described in this policy. Likewise, WANYA adopts the necessary technological and legal measures to guarantee the confidentiality and security of its users' personal data.
The personal data that WANYA collects will be disclosed only to the following companies:
ZECH TECHNOLOGIES is our strategic ally, who provides us with the development and maintenance service of our website and mobile application. ZECH TECHNOLOGIES implements technological solutions that guarantee fast and secure transactions. ZECH TECHNOLOGIES will also take care of resolving any technical issues that may arise, such as system glitches or vulnerabilities, so that users have a smooth and reliable experience when using WANYA's platform.
SUM AND SUBSTANCE is our strategic ally, who provides us with the "Know Your Client" (KYC) Compliance service. KYC Compliance is a set of measures to prevent crimes. SUM AND SUBSTANCE provides us with a variety of tools to validate documents, perform facial authentications, and continuously monitor our users, ensuring fraud protection and compliance with international regulations.
AMAZON WEB SERVICES is our strategic ally, who provides us with the storage service of the personal database. AMAZON WEB SERVICES allows us to implement advanced security measures, complying with international regulations on data protection and privacy.
Personal data will also be shared with the Supervisory Bodies in the following situations:
When the law and/or the regulations require it.
When WANYA must protect itself from claims against it or third parties.
Periodically to prevent fraud, money laundering and terrorist financing
Periodically for security reasons.
Others provided for by laws and/or regulations
Finally, WANYA may share with any company that purchases, or to which all or a substantial part of WANYA's assets and business are transferred, including the stage to facilitate such purchase or sale of all or part of WANYA' s business.
For example, if a company wishes to become a shareholder of WANYA, personal data will be shared with it in order to enable it to conduct compliance and corporate governance audits.
In the event of such a sale or transfer, all reasonable efforts will be made to ensure that the company to which users' personal data is transferred is used in compliance with this policy. WANYA will require companies to sign a confidentiality agreement regarding the personal data they access, in accordance with applicable legislation
Under no circumstances will we transfer users' personal data to third parties other than those mentioned in this policy. Exceptions are those cases in which it is necessary to share them in order to continue providing the services of the platform or to comply with current data protection regulations.
WANYA is aware that security is essential to ensure the integrity, confidentiality and availability of users' personal data. That is why we have implemented the following protection measures:
Automated Data Extraction: Use OCR to quickly extract and process data from multiple documents, reducing manual entry.
Customer Accounts: Automate KYC checks to verify and monitor customer accounts, ensuring compliance and reducing fraud.
Email Verification: Confirm the validity of email addresses to prevent fraud and improve data accuracy.
Facial Authentication: Uses biometric verification with liveness detection to ensure that the user is real, preventing identity fraud.
Continuous PLAFT Monitoring: Continuously reviews users on global sanctions lists to ensure compliance with PLAFT regulations.
Phone Verification: Validates phone numbers and detects fraudulent or disposable numbers to maintain accurate user data.
Address Verification: Verifies user addresses by analyzing supporting documents such as utility bills or bank statements.
Questionnaire: Customizable questionnaires built into verification flows to collect additional information from users.
SMS Notification Service: Sends automatic SMS updates to users about their verification process and account status.
User Verification: Combines document verification, biometric liveness detection, and address verification to confirm the user's identity.
Data encryption: Protects personal data in transit and at rest using advanced encryption.
IAM (Identity and Access Management): Securely controls and manages access to personal data.
AWS Shield: DDoS protection for applications hosted on AWS.
AWS CloudTrail: Continuous monitoring of activity on the platform.
AWS Key Management Service (KMS): Secure management of encryption keys.
Real-time monitoring: From the hand of our strategic ally ELLIPTIC ENTERPRISES LTD., WANYA's platform performs real-time monitoring of the operations that are carried out. This way, we can identify suspicious and fraudulent activity to protect users.
Code of Ethics: We train our workers and suppliers to comply with the standards of conduct outlined in the WANYA Code of Ethics. The Code of Ethics ensures that everyone involved in WANYA's operation handles information responsibly, ethically, and minimizes the risks of data breaches, fraud, and other harmful behavior.
Manual to prevent PLAFT: We train our workers and suppliers to comply with the policies and procedures of the Manual for the Prevention of Money Laundering and Terrorism Crimes (PLAFT). This manual serves as a guide for WANYA to identify and report suspicious transactions to the appropriate authorities. By doing so, WANYA minimizes the risk of being used for illicit activities and protects both its customers and its reputation.
HOW LONG IS USERS' PERSONAL DATA STORED?
Users should note that WANYA is obliged to retain personal data for as long as users' accounts are active.
If users decide to delete their accounts, the laws of the Republic of Peru require WANYA to retain personal data for a period of five (5) years, after which WANYA will permanently destroy all personal data it has retained
In exceptional cases, such as legal proceedings or compliance with legal obligations, the data may be retained for an additional time, always under the guarantees established in Peruvian regulations.
In compliance with the Quality Principle established in the Personal Data Protection Law, WANYA will not store users' personal data when any of the following events occur:
When you become aware of the inaccurate or incomplete nature of the personal data collected. Without prejudice to the user's rights in this regard, WANYA will delete, replace or complete the personal data of the users.
When the personal data is no longer necessary or relevant for the purpose for which it was collected.
When the period for their conservation has expired, unless there is an anonymisation or dissociation procedure.
LINKS TO EXTERNAL WEBSITES
The WANYA platform contains links to external websites. Such websites have their own privacy policies, and we recommend that users carefully review those policies if they visit such websites.
WANYA assumes no responsibility for the content of external websites or the privacy practices of external websites.
In accordance with the provisions of Law No. 29733, Personal Data Protection Law, users of the WANYA platform have the right to exercise their ARCO rights (Access, Rectification, Cancellation and Opposition) over their personal data, as follows:
Access to personal data: Users have the right to access the personal data they have provided to the WANYA platform. This information will be available in their profile tab, where they will be able to view all the data that the platform stores about them. They may also request additional information about how their data is being used and for what purpose.
Rectification of personal data: Users have the right to request the correction of any personal data that is inaccurate, incomplete, outdated or erroneous. To rectify their data, users can enter the profile tab and edit the relevant information using the "edit" button. If there is data that cannot be modified directly on the platform, they may request rectification by sending a request to the indicated email.
Cancellation of personal data: Users may request the cancellation or deletion of their personal data when it is no longer necessary for the purposes for which it was collected, or when they wish to withdraw their consent to its processing. This includes the ability to request the complete deletion of your account on the platform and all associated data. WANYA will proceed to delete the data, unless there is a legal obligation to keep it for longer.
Opposition to the processing of personal data: Users have the right to object to the processing of their personal data at any time, when there are legitimate and justified reasons related to their personal situation, or when the data is being used for purposes other than those for which it was initially collected.
Inclusion of personal data: The personal data provided by users will be included in the WANYA database and will be subject to the security measures established in this policy, guaranteeing their protection in accordance with Law No. 29733.
Portability of personal data: Users have the right to request the portability of their personal data. This allows users to receive a structured copy of their data in an interoperable and reusable format, which can be transferred to another service provider. To exercise this right, the user must send a request to the email wanya@suport.io specifying the personal data they wish to port. WANYA will have a period of 10 business days to process such a request.
Revocation of consent: Users have the right to modify or revoke at any time the consent granted for the processing of their personal data. WANYA will ensure that the user is informed of the implications of the revocation of consent, especially with regard to restrictions or limitations on the use of the services.
In addition to the above, users may exercise the rights indicated in accordance with the provisions of the Personal Data Protection Regulations, by email, by sending a message to suport@wanya.io and attaching a digitized copy of their national identity document and/or the documentation that allows corroborating their identity.
To request the change of email in WANYA, users must send the request from the registered email to suport@wanya.io and indicate the new email (which must not be previously registered in WANYA) and attach a selfie with their ID and a signed note that says: "I request to change my WANYA email".
In case of not having access to the registered email, users must write to us at suport@wanya.io from a new email that has not been previously registered in our database, attaching photographs of the ID card front and back, selfie holding it next to a note that says "I request to change my WANYA email".
"Cookies" are small text files located in the browser directory of users' computer or mobile device.
When users visit the WANYA platform, information is sent to the browser which then creates the cookies. Each time users revisit the WANYA platform, the information stored in the cookies is accessed.
Cookies store user preferences and other information that helps improve the experience on the platform.
By accessing and logging into the WANYA Platform without disabling cookies, users agree to receive a more personalized browsing experience and authorize the storage of the information mentioned above.
Users can set their browser to disable or reject all cookies or to be notified when a cookie is being sent. However, some features or services of the WANYA platform may not function properly without cookies.
WANYA reserves the right to modify this policy when it deems it necessary and complies with immediately informing users of the changes made. Users agree that use of the WANYA Platform after notification constitutes full acceptance of the changes to this policy. To be consistent with the dynamics of the platform, WANYA grants time for users to adapt to changes. It is the responsibility of users to review this and other WANYA policies in their entirety before accepting them. If users do not agree with the changes implemented, they must immediately delete their account on the WANYA platform and refrain from using it. If users do not delete their account and continue to use the WANYA platform, they will be deemed to have agreed to the changes to the policy.
WANYA and its policies are subject to the laws, agencies, and jurisdiction of the Republic of Peru:
Law No. 29733 (Personal Data Protection Law), its regulations and amendments.
Law No. 29038 (Law incorporating the Financial Intelligence Unit of Peru into the Superintendence of Banking, Insurance and Private Pension Fund Administrators), its regulations and amendments.
Law No. 29571 (Consumer Protection and Defense Code) and its amendments.
Directorial Resolution No. 019-2013-JUS/DGPDP (Security Directive for the Processing of Personal Data) and its amendments.
Other Applicable Laws.
National Authority for the Protection of Personal Data (for the protection of personal data).
National Superintendence of Banking, Insurance and Pension Fund Administrators (for Virtual Asset services).
INDECOPI (to attend to user complaints).
Jurisdiction: Users and WANYA will submit to the competence and jurisdiction of the judges and courts of Lima - Peru to resolve any controversy that may arise from this policy.
CONTACT INFORMATION
If you have any questions regarding the privacy and/or security of the personal data provided to WANYA, you may contact us directly through the following email address support@wanya.io