Privacy & Cookie Policy

The WEWE Global is a referral marketing Decentralized Autonomous Organization (hereinafter referred to as “Horus Falcon Limited”, “we”, “us”, “our”) and accessible as a multi service platform of DIGITECH WORLDWIDE INC, incorporated in 2016 of House of Francis, Room 303, Ile Du Port, Mahe, Seychelles, holding the registration number of 188717. Horus Falcon Limited uses partner companies, trade agreements, working agreements to expand the Horus Falcon Limited’s vision in the world. This Privacy policy (“Policy”) governs the clients who are the Independent WEWE Associate (“IWA”, “you”, “your”) of WEWE Global DAO while accessing to www.wewe.global, website and/ or mobile application (herein referred to as “Platform”) and all documents, data materials or other information made available on the Platform. Please take a moment to read this Policy along with the Cookies Policy carefully, and note that by using the Horus Falcon Limited, you are consenting to the collection, storage, processing and transfer of your personal information as described in this Policy. This Policy applies to all visitors, users, IWAs and others who access or use our Platform.

1. DEFINITION
1. “IWA” refers to Independent WEWE Associate, who are known as clients of Horus Falcon Limited. IWAs are categorized into two types as per the Horus Falcon Limited Terms, such as;
• (i) IWA Clients (hereinafter referred as “IWA”) who are users or customers. IWA Client may be a natural person with minimum age of 18 years and/or any legal entity with legal competence who is registered in our Platform. They shall be holding the meaning of promoters of the Horus Falcon Limited. Please note that a user who is a natural person, under the age of 18 years (a “Minor”) may also be considered as an IWA Client, if he/ she registers in our Platform. However, in such circumstances Minors will be subjected to certain conditions, such as Minor will not be required to go through the KYC process in the Platform while registering. Despite that the Minors will be able to share their referral links to invite people in joining business, however an IWA Client who is Minor will not be able to get any referral rewards or commissions from the Platform as applicable.
• (ii) IWA Resellers are IWA Clients who click on the referral link to promote our services.
2. Personal data – means, data consisting of information which relates to a living individual and/or legal person who can be identified from that information (or from that and other information in the possession of the data user), including any expression of opinion about the individual but not any indication of the intentions of the data user in respect of that individual.
3. Services - means the services provided only by the WEWE Global DAO. For detailed information please refer to the terms and conditions on the Platform.


2. ACCEPTANCE
   By accessing and using our Platform, you are consenting and accepting the terms of this Policy. If you do not agree or consent with the details we require with any aspect of this Policy, you shall at any time withdraw your consent and discontinue access or use of our services.


3. THE PERSONAL DATA THE Horus Falcon Limited COLLECTS FROM IWA
   Your Personal data is collected and stored with WEWE Global DAO in order to provide, develop and to enhance our products and Services including technical infrastructure, security, compliance, fraud prevention and customer support. We are committed to exercise due diligence when dealing with you and in the course of conducting business, we ensure that it is able to comply with all the applicable Laws and regulations that require to prevent the facilitation of money laundering and terrorist financing. We collect your information during the onboarding process (Know Your Client (KYC) System).

   CLIENTS
   Natural Person	Legal entity
   1. Full name 2. Date of Birth 3. Email Address 4. Gender 5. Residence Address 6. Nationality 7. Country Code 8. Telephone number 9. Government issued Identity or Driving License 10. Passport details 11. Real time face photo (selfie)	1. Company name 2. Country of Incorporation 3. Country of Operation 4. A copy of Certificate of Incorporation 5. Passport copies of all directors & Shareholders 6. Valid Trade License 7. Memorandum of Association 8. Article of Association 9. Registered Address

   AUTOMATED INFORMATION
   Browser Information	Log information
   1. IP Address 2. Login information 3. Browser type and version 4. Time zone setting 5. Platform 6. Operating System 7. Transaction history 8. Pages accessed and links clicked 9. Public blockchain data	1. Device- specific information 2. Location 3. System activity 4. Uniform Resource Locators [URL] 5. Data collected via Cookies

   *The personal data we collect from IWAs



4. WHY YOUR PERSONAL DATA IS USED BY THE WEWE GLOBAL DAO?
   1. To communicate with you
   2. To comply with legal and regulatory compliance
   3. To detect and prevent frauds and credit risks
   4. To provide, troubleshoot and improve the Horus Falcon Limited Services
   5. To enforce our terms in our user agreement (Terms and Conditions).
   6. To provide customer services
   7. To ensure quality control
   8. To ensure network and information security
   9. To enhance and personalize user experience
   10. To facilitate corporate acquisitions, mergers or transactions
   11. To engage in marketing activities
   12. For Transaction services
   13. Purposes for which we seek your consent


5. DATA TRANSFER
   1. We may share your Personal data with affiliates, selected third parties including business suppliers, distributors and subcontractors, when it is necessary for the delivery of our services, or when there is a legal basis to do so. The aforementioned third parties only collect, use and disclose your information in the ways indicated by us in order to provide adequate services. Please note that, by agreeing to this term in this Policy, you agree to read and acknowledge the terms and conditions and privacy policy of each third party, without prejudice that any of these may require additional consent or validation necessary for the part of the Service they are in charge of.
   2. We further ensure that we comply with the applicable data protection legal norms and we shall only share information in the following circumstances:
      1. With applicable regulatory bodies of the Seychelles.
      2. In the event of suspicious activities or transactions such as any fraud, tax, money laundering or terrorist financing activities, the Horus Falcon Limited is obliged to share the your personal information with the applicable regulatory bodies.
      3. Third party KYC/AML service providers (if applicable) of the Horus Falcon Limited to identity verification services in client onboarding process and in ongoing transaction monitoring process.
      4. The Horus Falcon Limited intends to uphold and implement the strictest standards of compliance, security and transparency in its operation, starting with detailed verification of onboarding clients and ongoing monitoring system to trace the nature of the virtual asset wallet to which each of you are sending to or receiving from. Therefore, the Horus Falcon Limited and/or our third party may share the data as applicable to the third-party service providers and you will be subject to each of the third parties’ terms and policies.
      5. With service providers under contracts to operate the business. For instance; (i) Cloud storage, (ii) Payment process, (iii) Transaction Monitoring, (iv) Network Infrastructure, (v) Security, (vi) Customer Support, (vii) Marketing and (viii) Data analytics.
      6. We transfer only the minimum amount of data necessary for a particular outsourced service provider(s) (if necessary) and we only cooperate with the outsourced service providers who can provide and ensure adequate level of Personal data protection.
      7. With our affiliates/ business partners as a general part of conducting business to offer services. We ensure that the third party and affiliates/ business partners who process personal information to acknowledge the confidentiality of this information and to protect the Client’s right to privacy by complying with all applicable privacy and data protection laws
      8. With financial Institution which we partner to process payments you have authorized


6. PROTECTION AND STORAGE OF PERSONAL DATA
   1. The Horus Falcon Limited maintains physical, technical, administrative and procedural safeguards in connection with the collections, storage and disclosure of your Personal data. We use firewall barriers, encryption techniques and authentication procedures to maintain the security of Client’s online sessions.
   2. You are requested to protect your account password from unauthorized access to avoid unnecessary authentication issues. In order to circumvent loss, misuse, unauthorized acquisition or alteration of your data, you are requested to choose the strongest password and to protect the account privacy data from any third-parties. In the event of unauthorized access, the Horus Falcon Limited insists you to contact us immediately at support@horusfalconlimited.com
   3. Further, we do not ensure the security or privacy of data transmitted via email, phone or SMS, till such data reaches the domain of our network, since we have no access to protect such data until it reaches our network domain.


7. DATA RETENTION
   1. We shall keep the original or a true copy of all KYC Documents, data and information we receive from you in a readily retrievable format for seven [7] years. In the event of any suspicious transaction or activity occurring, the WEWE Global DAO will not destroy any relevant records even though the prescribed period for retention shall have elapsed, for the reason that we are subjected to certain anti-money laundering laws
   2. Further, information or data collected via technical means such as cookies, web page counters and other analytics tools is kept for a period of up to one year from the expiry of the Cookie Policy.


8. GENERAL DATA PROTECTIONS REGULATIONS OF EU
   1. The Horus Falcon Limited is obliged and bound by the General Data Protection Regulation [GDPR]. This regulation came into effect on May 25, 2018.
   2. Under certain circumstances, you have rights under data protection laws in relation to your Personal data which are set out in more detail below
      1. Request access - This enables you to receive copies of your Personal data. We hold about you and to check that we are lawfully processing it. This is also commonly known as a "Data Subject access request". This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
      2. Request erasure - This enables you to request us to delete or remove Personal data where there is no good reason for us continuing to process it. Please note that there may be circumstances where we may be legally entitled to retain your Personal data.
      3. Request to Restrict Processing - This enables you to object to the processing of your Personal data, which is processed based on our legitimate interests. In the event of such an objection, we will no longer process your Personal data, unless we demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defense of legal claims.
      4. Request to transfer - If you request us, we will provide you or a third party you have chosen, your Personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
   3. To exercise these rights, please contact us using the email address indicated in this Policy. We will process this request within 30 (thirty) calendar days and provide an answer.


9. PRIVACY TERMS IN USING CRYPTOCURRENCY AND BLOCKCHAIN
   The cryptocurrency transactions are recorded on a public blockchain. It is a ledger which means a chain of blocks where each block contains the recording of any data transmission. Blockchains are decentralized or third-party networks which are not controlled or operated by any third-party service provider or affiliates or business partners of the Horus Falcon Limited, and we have no access or authority to erase, modify or alter any Personal data from such networks.


10. DATA PROTECTION DECLARATION
    1. The Horus Falcon Limited uses so-called social plugins (“plugins”) from the social network Facebook, which is operated by Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). The plugins are marked with a Facebook logo or by the additional text “social plugin of Facebook” or “Facebook social plugin”. Here you can find an overview of the Facebook plugins and their appearance: http://developers.facebook.com/plugins.
    2. If you access one site of our web presence containing such a plugin, your browser will establish a direct connection to the servers of Facebook. The plugin's content will be directly transmitted from Facebook to your browser, which will integrate it into the website.
    3. By integrating the plugin, Facebook receives the information that your browser has accessed the respective page of our website, even if you do not have a Facebook account or if you are just not logged in to Facebook. This information (including your IP-address) will be directly transferred by your browser to a Facebook server in the USA and stored there.
    4. If you are logged into Facebook, Facebook can directly allocate the visit to your Facebook account. If you interact with the plugins, such as by pressing the "Like" button or by making a comment, the corresponding information is also sent directly to a Facebook server and stored there. In addition, the information is also posted on Facebook and can be seen by your Facebook friends.
    5. Facebook can use this information for the purposes of advertisement, market research and appropriate design of Facebook pages. To this end, Facebook creates usage, interest and relationship profiles, e.g. for analyzing your usage of our website concerning superimposed advertisements on Facebook, to inform other Facebook users about your activities on our website and for providing other services relating to the use of Facebook.
    6. If you do not wish Facebook to allocate the collected data concerning our web presence to your Facebook account, you have to log out from Facebook prior to visiting our website.
    7. The purpose and scope of data collection, further processing and use of this data by Facebook as well as your relevant rights and the setting options aiming at the protection of your privacy can be found under Facebook’s data protection policy: http://www.facebook.com/policy.php
    8. Note concerning the Google +1-button: By means of the Google +1-button you can globally publish information. Via the Google +1-button, you and other users will receive personalized information from Google and our partners. Google will store the information you have given for the content +1 as well as information about the site you have watched when clicking +1. Your +1 can be shown as indications together with your profile name and your photo in the context of Google services, such as displaying it in search results, in your Google profile or at other positions on websites and advertisements on the internet. Google records information about your +1-activities thus aiming at the improvement of Google services for you and other users. For being able to use the Google +1-button, you will need a globally visible, pubWEWE Google profile which has to contain at least the name chosen for the profile. This name will be used with reference to all Google services. In some cases, this name may also replace another name you have been using for sharing content via your Google-account. The identity of your Google profile may be shown to users knowing your email-address or having other personally identifying information from you.
    9. Use of the collected information: In addition to the above mentioned purposes, the information provided by you will be used according to the applicable data protection rules of Google. Google will eventually publish summary statistics on the +1-activities of the users or will pass them on to users and partners – such as publishers, advertisers or linked websites.
    10. On the Platform, functions of the service horusfalconlimited.com. By using Horus Falcon Limited and the “retweet” function the visits by your websites will be linked to your Horus Falcon Limited account and communicated to other users. While doing so, data will also be transferred to Horus Falcon Limited. Please note that we - in our capacity as provider of the sites – are not receiving any information by Horus Falcon Limited about the transferred data’s content and its usage. Further information you will find in the Horus Falcon Limited Privacy Statement under http://horusfalconlimited.com.com/privacy-policy.php Your Horus Falcon Limited data protection settings can be changed in the account settings under http://horusfalconlimited.com.com/
    11. Personal data will only be collected insofar, as the IWA will voluntarily submit them during the ordering or registration process. The Horus Falcon Limited will use these transmitted, personal data (e.g. title, name, address, email-address, telephone number, fax number, bank transfer data) without explicit, separate consent in accordance with the regulations of the relevant data protection laws and only for the purpose of IWA Agreement fulfilling.
    12. For the purpose of fulfilling the agreement with us, e.g. for the settlement accounting or payment of bonuses, for product or marketing information, the IWA’s personal data will be forwarded to third parties, for example the accounting department of an electronic payment platform – to the extent necessary for the fulfillment of the aforementioned, contractual obligations. After complete execution of the IWA Agreement, including full payment of the agreed remunerations, the IWA’s data will be deleted. Data, which has to be stored for tax or commercial reasons, will be blocked after implementation of the agreement, provided that the IWA has not given his/her explicit consent to further use of his/her personal data.
    13. The IWA shall, at all times, be entitled to request free information about his/her data and that his/her personal data will be amended, blocked or deleted. If the IWA wishes to receive further information concerning the storage of his/her personal data or if the interested party wants the data to be deleted, blocked or amended, he/she can contact the support support@horusfalconlimited.com
    14. This Data Protection Declaration is accessible and retrievable on the Horus Falcon Limited at any time.


11. COOKIES
    1. Cookies are small text files that are placed on your device like computer, mobile or any other device by a website, containing details of your browsing history. In simple terms it is explained as that it contains information about your browsing activity. Whenever you visit our Platform, the website sends a cookie to the device you are using to access our Platform. Your device automatically stores the Cookie in a file that’s located within your website browser.
    2. Cookies allow our Platform to recognize your device such as; when you revisit a site, the website will respond in a more personalized way, remembering your preferences, and it will make your page load faster. Cookies set by our operators are called “First party cookies”. Cookies set by parties other than our platforms are called “Third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website for instance such as advertising, interactive content and analytics.
    3. We use the following Cookies to operate our Platform, such as
       1. Session Cookies are temporary and expire once you close your browser. It stores information for the time, or session when you are on our Platform.
       2. Persistent Cookies encompasses all Cookies that remain on your hard drive until you erase or your browser does it. It depends on the Cookie’s expiration date. All persistent cookies have an expiration date written into their code, but their duration can vary.
       3. First-party-cookies are put on your device directly by our Platform you are visiting
       4. Third-party-cookies are placed on your device, not by our Platform, but by a third party like an advertiser or an analytic system. Generally, the Third-Party Cookies consist of tracking Cookies used to identify online behavior, understand interests and then customize advertising the Clients on other websites. Any information obtained from Third-Party Cookies is processed by the respective Collaborative Partners.
          • Google Analytics Cookies to measure our Client’s interactions with the content on our Platform. These Cookies collect information about your interactions with our Platform, such as unique visits, repeat visits, session duration and Website activity;
          • Facebook Pixel to process information about a Client’s activity on our Platform, such as the website visited, Facebook identity, browser data, and more. The information processed from Facebook pixel is used to serve ads based on your interests through Facebook, as well as to measure cross-device conversions and user interactions on our Platform.
       5. Essential Cookies are known as strictly necessary Cookies for you to browse our Platform and use the features of it, such as accessing secure areas of our Platform. These Cookies are generally First-Party Session Cookies. These Cookies do not require consent from you. Essential Cookies helps to make our Platform easy to use by providing basic functions such as page navigation, language selections, authorization and filling in forms. Our Platform will not function without these Cookies and they cannot be disabled. These Cookies do not reveal the Client’s identity or collect information. They are stored on the Client’s device until the browser is closed.
       6. Functionality Cookies allow our Platform to remember choices you have made in the past like what language you prefer, what region you would like or what username and password are so you can automatically log in. We use Cookies for navigation and to facilitate your access to and use of this site. These Cookies are necessary for transmission of communications on the network or to supply services whatever requested by you. Further they help us to know which pages are the most and least popular and see how visitors move around the website. We use Third-Party Cookies, which are set on your device for up to 2 years or deleted, if you erase your browser cookie data.
       7. Performance Cookies collect information about how you use our Platform, like which page you visited and which link you clicked on. None of this type of information can be used to identify you. The sole purpose of performance cookies is to improve our Platform functions. Analytics may collect information through log data, such as; (i) IP address, (ii) Type of browser and device, (iii) Operating system, (iv) Name of the Internet Service Provider, (v) Country information, (vi) Date and time of visit, (vii) Web page origin and exit.
       8. Marketing Cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see and ad. These Cookies can share information with other organizations or advertisers. However, these are Persistent Cookies which are third-party-provenance. These cookies may be set through this Website by our advertising partners. If you do not allow these cookies, you will experience less targeted advertising. These cookies are set on your device for up to 2 years or deleted, if you erase your browser cookie data.
    4. You reserve the right to decide whether to accept or reject Cookies from our Platform. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. However, you will not be able to reject the Essential Cookies, as they are strictly necessary to provide you with our Services. In the event you choose to reject Cookies, you may still use our Platform though your access to some functionality and areas of our Platform may be restricted. You may also set or amend your web browser controls to accept or refuse Cookies. Be conscious of rejecting or disabling Cookies, where it may affect the functionality of our Platform. Therefore, it is recommended that you do not disable cookies.
    5. You can also separately opt-out from having your website activity available to Google by installing the Google Analytics opt-out browser add-on, which prevents sharing information about your website


12. MODIFICATIONS
    We reserve the right, at our sole discretion, to modify, amend, supplement or replace this Policy at any time and such update details shall be indicated at the top of this page. We will review and revise this Policy when there are any material circumstances arisen that may affect our ability to apply this Policy pursuant to the provisions of statutory and law requirements. What constitutes a material change will be determined at our sole discretion. When an updated version of this Policy is released, your continued access to the Platform means that you agree to the updated content and agree to abide by the updated Policy.


13. CONTACT INFORMATION
    In the event of any comments, questions, inquiries or complaints regarding this Policy, please contact us at support@horusfalconlimited.com