Last updated: 11 September 2025

1. INTRODUCTION

Waml (“we”, “our”, “us”), operated by PROCESSIO LTD, is committed to protecting the privacy and personal data of all individuals who interact with our services, website, applications, and digital platforms (collectively, the “Services”).

This Privacy Policy explains in detail how Waml collects, uses, stores, shares, and protects your personal data in the operation of the wamlapp.com website and associated webpages (the “Waml Website”). It also describes your rights as a data subject and how you can exercise them. Waml determines the purpose and methods for processing your personal data as described in this Privacy Policy, acting as the controller of this data. This Privacy Policy does not apply to the company’s processing activities in its capacity as a processor or service provider.

We process personal data in compliance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and other applicable data protection and privacy laws where relevant (“Data Protection Laws”).

By using our Services, you acknowledge that you have read and understood this Privacy Policy and you are bound by this Privacy Policy. We may change this Privacy Policy from time to time. If you do not agree with the policy, please refrain from using our websites and Services.

2. THE DATA WE COLLECT ABOUT YOU

Waml collects information necessary to provide our services, understand how users interact with our websites, and improve the content and functionality of our offerings. The types of information we collect include:

Name and email address;
Information related to Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance, including blockchain addresses and transaction data;
Payment Data, such as credit card number, expiration date, and billing address;
Technical Data includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Waml Website.

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

Other than as allowed by the Data Protection Laws, we do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) nor do we collect any information about criminal convictions and offences.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

Direct interactions. Information you affirmatively choose to submit to us (such as your name, surname and email address) for the purpose of accessing various downloads, viewing specific content, subscribing to Waml newsletters, registering for your preferences in receiving marketing from Waml and its third-party partners and your communication preferences, etc;
Automated technologies or interactions. As you interact with Waml Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.
Publicly available sources. We may partner with publicly available sources (like content providers and analytics companies e.g. Google Analytics) to help us improve the services of the Waml Website and better understand how you interact with the Waml Website, as well as support our initiatives. These companies may collect information from you automatically in connection with your visit.
Third party sources. We may also collect personal data from third party sources, including data companies, publicly accessible databases, joint marketing partners, social media platforms and other third parties. We may also receive personal data about you from third parties when we need to confirm your contact details or even certain financial information. Should this be the case, and when acting as a data controller, we will take all measures as required by Data Protection Laws to further inform you about the source of such personal data as well as the categories of personal data we collect and process. There are certain instances at Data Protection Laws where we are specifically forbidden from disclosing to you such activity.

For information/personal data that we may collect automatically via the Waml Website (as a data controller), please see the Cookie Policy.

Social Media. If you choose to connect one or more of your social media accounts with Waml Website (if this option is available) to enable the sharing of personal data via social media platforms, certain categories of personal data relating to you from your social media account(s) will be shared with us.

4. HOW WE USE PERSONAL DATA

Any personal information collected by Waml shall be processed in accordance with Data Protection Laws. The purposes for which Waml collects and uses personal information include, but are not limited to:

Business and Operational Purposes

Enhancing business decisions and operational efficiency;
Supporting the services and activities you elect to engage in;
Developing and delivering improved products, solutions, and services to Waml customers.

Personalization and User Experience

Using location information and other relevant data to tailor your experience on Waml Website;
Employing non-personal or anonymized data to improve website functionality, content, and user interface;
Utilizing IP addresses and related Technical Data for website diagnostics, administration, and security purposes.

Marketing and Communications

Collecting and using personal information for marketing purposes, including informing you of products, services, and promotional materials that may be of interest;
Sending newsletters, updates, and other communications to users who have opted in;
Gathering and analyzing statistical information regarding your interaction with our communications and platforms to guide future marketing strategies.

CRM and Analytics

Personal data may be stored in Waml’s Customer Relationship Management (CRM) system and used to manage communications, track engagement, and provide a more personalized experience.

Data collected for analytical purposes may include responses to emails, interactions with content, and other engagement metrics to optimize Waml’s services and marketing initiatives.

Waml ensures that all processing of personal information is carried out lawfully, fairly, and transparently, consistent with the principles of data minimization, accuracy, purpose limitation, storage limitation, and confidentiality.

5. CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or where the law otherwise requires, as may be the case.

Please note that we may process your personal data without your knowledge or consent in the limited situations where this is required or permitted by law.

6. HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria we use to determine what is ‘necessary’ depends on the personal data in question and the specific relationship we have with you (including its duration).

Our normal practice is to determine whether there is/are any specific EU and/or local law(s) permitting or even obliging us to keep certain personal data for a certain period of time (in which case we will keep the personal data for the maximum period indicated by any such law).

We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are (this is usually five (5) years, in line with prevailing and relevant legislation). In the latter case, we will keep any relevant personal data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as is necessary.

Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In the case we do not delete your data, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. HOW WE SHARE PERSONAL DATA

We may share your personal data in the circumstances outlined below. We may also share your personal data among other subsidiaries or affiliates that either are subject to this Privacy Policy or have practices at least as protective as those described in this Privacy Policy.

Third-Party Service Providers and Vendors

Third-party service providers or vendors that Waml has engaged to perform business functions on our behalf might have access to your personal data. Such parties may include:

Service and hosting partners to provide the necessary hardware, software, networking, storage, and other services we use to operate the Service and maintain a high-quality user experience;
Bank(s); and,
Professional advisors, such as accountants, lawyers, consultants, and tax specialists.

Third-Party Partners

We may make available to you services or products in collaboration with third parties, for example, those that are jointly offered by Waml and its third-party partners or other businesses.

Payment Processors

We may share personal data with, or direct customers to provide such data, to payment processors who process payment for services on our behalf.

Marketing Partners

In some instances, we may share personal data with our marketing partners, including ad networks, social networks, retargeting partners, and marketing communication providers, in order to communicate with you about our products and services.

Business Transactions

Waml may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may assign or transfer this Privacy Policy and your personal data to a third party in connection with such a corporate business transaction, for example, during negotiations. Personal data may also be disclosed in the event of insolvency, bankruptcy, or receivership.

Legal Obligations and Rights

We share personal data with third parties, such as legal advisors and law enforcement, to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share personal data if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our agreement for services, or as otherwise required by law.

Transfers Directed or Permitted by You

We may share personal data about you to certain other third parties at your direction or with your consent or permission.

8. THIRD-PARTY SERVICES VIA LINKS

The Waml Website and/or the Service may contain links to websites and applications other than the Service, including websites, services, and applications operated by affiliates and other third parties. The Waml Website sometimes may also include third-party Social Media features, such as the Facebook Like or Share buttons and Widgets or interactive mini-programs, that run on our site. These third-party features may collect your IP address and which web page you are visiting on the Waml Website, and may set a cookie to enable the feature to function properly. Social Media features and Widgets are either hosted by a third party or hosted directly on the Waml Website.

If you choose to interact with any third parties or through third-party services or applications, whether through us or on your own, your data will be subject to their privacy practices and terms and conditions.

Waml Website contains links, plug-ins and applications to various third-party websites. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. Waml has no control over, and is not responsible for the content, privacy policies or reliability of such third-party connections. When you leave Waml Website, Waml encourages you to read the privacy notice and privacy policy of every website you visit.

9. INTERNATIONAL TRANSFERS

As a general rule, the data we process about you (collected via the website, any of our apps or otherwise) will be stored and processed within the European Union (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the European Commission to offer an adequate level of protection.

In some cases, it may be necessary for us to transfer your personal data to a non-EEA country not considered by the European Commission to offer an adequate level of protection (for example to one or more of our data processors located there). In such cases, you are assured that we have contractually bound such third-parties to adhere to EU laws pertaining to the protection of personnel including but not restricted to the General Data Protection Regulation (Regulation 2016/679(EU)).

10. LEGAL BASIS WE RELY ON

In the case the information you provide to Waml qualifies as personal data under applicable Data Protection Laws, Waml’s legal basis for collecting and processing such personal data will depend on the specific categories of data involved and the context in which the data is obtained. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

However, Waml will generally collect personal data from you only in the following circumstances:

(a) where such data is necessary for the performance of a contract with you;

(b) where the processing is required to pursue Waml’s legitimate business interests, provided that such interests are not overridden by your fundamental rights and freedoms;

(d) where Waml is under a legal or regulatory obligation to collect and process the data.

Please contact us if you need details about the specific legal ground we are relying on to collect, use and process your personal data using the contact details provided under the “HOW CONTACT US” heading below.

11. COOKIES AND SIMILAR TECHNOLOGIES

To help us identify your browser or device and to enhance, personalize, and improve our Services, Waml uses cookies and similar tracking technologies. These technologies enable us to provide core functionalities, analyze website traffic, and deliver relevant content, including interest-based and targeted advertising. For detailed information about the types of cookies we use, the purposes for which we use them, and the options available to manage your preferences, please refer to our Cookies Policy.

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies some parts of the Waml Website may become inaccessible or not function properly.

12. DATA SECURITY

Waml strongly follows the provisions of GDPR in its information security practices, ensuring robust technical and organisational measures are in place to protect your personal data. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. We also take measures to ensure our subcontractors, service providers and other partners that process your personal data on our behalf also have appropriate security measures in place.

Waml protects your personal information in the same way that it protects its other confidential information, such as storing it on secure servers that only select Waml personnel have access to, and by encrypting it to help prevent access by any unauthorized parties. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

13. YOUR LEGAL RIGHTS

You have certain rights under the law with regards to how your personal information is processed. These rights are:

The right to be informed how your personal information is being used.
The right of access to your personal information.
The right to rectification if your personal information is incorrect.
The right to erasure your personal information. (Where the law permits this)
The right to restrict processing of your personal information.
The right to data portability.
The right to object to how your personal information is used.
Rights in relation to automated decision making and profiling.

You have the right to opt out of marketing communications that Waml sends you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing emails Waml sends you or by using the relevant opt-out mechanism for non-email-based marketing.

if we have collected and processed your personal information based on your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing Waml conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

If you would like to make a request for information, please do not hesitate to contact us.

For individuals in the European Economic Area (EEA), you have the right to lodge a complaint with your local data protection authority. You can find the contact details for your national data protection authority here:

https://edpb.europa.eu/about-edpb/board/members_en

Before lodging a complaint, we would appreciate the chance to deal with your concerns, so please contact us first at support@wamlapp.com. Please note that lodging a complaint will not affect any other legal rights or remedies that you have access to under applicable data protection laws.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

WHAT WE MAY NEED FROM YOU

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

TIME LIMIT TO RESPOND

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you wish to access, correct, update, or request the deletion of any personal data we hold about you, you may contact us at any time using the details provided in this Privacy Policy. Where technically feasible, Waml will provide you with a copy of your personal data or, at your request, transmit it directly to another data controller.

You also have the right to object to the processing of your personal data for direct marketing purposes and may request that we restrict the processing of your data in certain circumstances.

If you believe that your privacy rights under Data Protection Laws have been violated, we encourage you to contact us first so that we may address your concerns. However, you also have the right to lodge a complaint with the relevant data protection authority.

For more information about your rights and how to exercise them, we recommend visiting this resource from the European Commission, which is available in many languages.

14. HOW TO CONTACT US

If you have any questions, you can reach out through the DPO or privacy request below by mailing your request to the following address:

Data Protection Officer – Waml

Email: dpo@wamlapp.com

Please note, Waml may ask for more information to verify your identity before releasing any personal data. The information you provide will be used solely for the purpose of identity verification related to your privacy request, and will be processed and stored in accordance with our Privacy Policy.