Suni Wallet

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Effective date: January 19, 2024

Privacy Policy

  1. Introduction
  2. Online Communications
  3. Principles
  4. Collected Information
  5. Purpose of the collected information
  6. Transfer of data
  7. User Authorization and Consent
  8. Authorization Withdrawal
  9. Right of access, correction, disposal and transferability
  10. Cookies Policy
  11. Data retention period
  12. Alternatives about how we use and disclose your information
  13. Security and Confidentiality Commitment
  14. Policy Amendments
  15. Minors
  16. Contact Information

1. Introduction

This Privacy Policy describes how Suniwallet Corp, registered under Folio 155729130, No. 1 of the electronic folio opening, duly incorporated before the Public Registry of Panama and domiciled in Panama, Panama City, (hereinafter, “SW”, the “Company” or “we”) in its capacity as data controller, collects, uses, shares and processes your information as well as your rights and choices related to such information.

This policy describes the types of information we may collect or that you may provide when you visit the www.suniwallet.com website and/or download, install and register before the Suni Wallet mobile application (hereinafter “Suni Wallet”, the “Platform” or the “Suni Wallet Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing such information.

This policy applies to the information we collect:

  • On our Platform.
  • Via email, text and other electronic messages that are exchanged between users of the Platform and the Platform.

It does not apply to information collected by:

  • SW offline or by any other means, including on any other website or platform operated by SW or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), which includes through any application or content that may link to or be accessible from or on the Platform.

Please read carefully this policy to understand our policies and practices regarding the collection of your data and information and how we will handle it. If you do not agree with our policies and practices, please do not use the Platform. 

By registering, accessing and/or using the Platform, you agree to our Privacy Policy. This policy may be amended at any time, in which case your continued use of the Platform after such amendments have been made shall be deemed acceptance thereof, so please check the policy periodically for updates according to the date we indicate at the top of this page or section.

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2. Electronic Communications

By using the Platform or communicating with us electronically, you agree and acknowledge that we may communicate with you electronically through the Platform, by push notifications (which may be disabled by the user) or by email, and you agree that all agreements, notices, disclosures and other communications that we provide to you by electronic means shall comply with any legal requirements.

3. Principles

When collecting, processing, retaining and protecting the information provided by our users, SW will abide by the following principles:

  1. Principle of fairness: we inform our users of the data we collect and obtain it without deception, fraudulent, unfair or unlawful means.
  2. Principle of purpose limitation: we collect information for specific purposes and use it only for such purposes.
  3. Principle of proportionality: we only collect data that is adequate, relevant and limited to the minimum necessary in relation to the purpose for which it is required.
  4. Principle of truthfulness and accuracy: personal data will be accurate and up to date.
  5. Principle of data security: the required measures will be taken to ensure the security of the data under the custody of SW and the owner will be informed, as soon as possible, when the data has been removed without authorization or there are sufficient grounds to believe that its security has been breached.
  6. Principle of transparency: all information or communication made to the user will be made in simple and clear language.
  7. Principle of confidentiality: SW, its subsidiaries, affiliates, subcontractors, staff and suppliers will maintain the appropriate confidentiality in accordance with applicable law, implementing the necessary measures to prevent unauthorized access or use thereof.
  8. Principle of lawfulness: SW collects information and processes it with the prior consent of users.
  9. Principle of portability: The owner of the data has the right to obtain a copy of the personal data we keep, in a structured manner in a generic and commonly used format.

4. Collected Information​

SW must receive or collect certain information to operate, provide, improve, understand, customize, support and promote the services and functionalities offered by Suni Wallet, thus, the types of information we receive and collect depend on the way you use our services. The Platform collects various types of information or data, among which we can point out:

  • Information as a whole will be referred to as “personal information”, which will identify the user and will consist of: first and last names; the company he/she represents (if applicable); the user’s position within the company (if applicable); telephone number; email address, pseudonym, bank accounts, credit information, time zone, address and/or residence, photos, downloaded files, music, videos, among others, and any other additional information that the user wishes to provide.
  • Information about the type of internet connection, device used and details of use of the Platform.
  • The Internet Protocol (IP) address used to connect your computer or mobile device to the Internet. The metrics of the Platform services (e.g., occurrences of technical errors, your interactions with the Platform and the content of the service and your configuration preferences).

The Platform collects the above information:

  • Directly from the user, when you provide it to us.
  • Automatically as you use the Platform. Information collected automatically may include usage details and data collected through cookies, web beacons and other monitoring technologies.

For the proper functioning and use of the services by the user, we must collect the following information directly related to:

  •  Identity and Payment Data: You may be required to provide us with personal identification or other necessary documents in order to verify your identity on a voluntary basis. Such information required to verify the user’s identity might include: (i) full name, (ii) date of birth, (iii) country of residence and citizenship, (iv) geolocation, among other data. Verification may also include the mandatory provision of additional identity information when there is suspicion of misuse of the Platform or the commission of criminal activity, money laundering or fraud.
  • Cryptocurrency Buy/Sell P2P Information: Refers to data related to peer-to-peer (“P2P”) cryptocurrency sale and acquisition transactions made on the Platform, such as trades made, offers created, value of transactions in cryptocurrencies and coins, wallet addresses, cryptocurrency prices, type of currency used, timestamps of transactions, records of conversations during transactions, buyer and seller pseudonyms, payment methods, records of transactions initiated, transaction identifiers, billing information (if applicable), interest rate, loan term, and any other relevant information.
  • Communications: Refers to interactions and messages shared. Any communication with us may be stored and analyzed, including communications during transactions with other users, attachments, conversations with customer service through the support system, emails or the dispute resolution process, as well as any other form of communication with our customer service.
  • Biometric information: This case refers to data or information relating to facial recognition and facial geometry derived from photographs or videos that you submit to us or that are produced during the identity verification process or for Know Your Client (“KYC”) purposes. Such biometric information will be used for identity verification.
  • Information from transactions with Sellers and Services Providers: In this case it refers to information or data relating to transactions between product sellers or service providers to the general public and users of the Platform, to whom the aforementioned service providers or vendors may offer financing for payments of services or products offered in cryptocurrencies (“B2C”).

The above information is collected directly by the Platform when:

  • The user completes sign up forms on the Platform. This includes information provided at the time of signing up to the Platform, completing forms or requesting any additional service, as well as when you sign up for our newsletter (if applicable). We may also ask you for information when you report a problem with our Platform.
  • Records and copies of your electronic communications (including email addresses), if you communicate with us.

Additionally, third parties other than yourself may provide us with information about yourself, which implies that:

  • Other users or companies may provide us with information about yourself, your nickname, e-mail address and other data. Users can also inform us that you use our services by inserting it, for example, in their address book. All users and companies will be legally entitled to use, collect and share your information before providing it to us.
  • We may collaborate with service operators who may provide us with information about you to improve our operations, and to help us provide our services, personalization, understanding, as well as to provide support, research and surveys, market our services.

5. Purpose of the Collected Information

The information we collect or that you provide to us is used mainly for the following purposes:

  1. Enable access to the Platform and its contents.
  2. To enable the use of Suni Wallet’s functionalities and services.
  3. To provide information, products or services requested from us.
  4. To fulfill any other purpose for which the user provides it.
  5. To notify about changes made to our Platform or any product or service we offer or provide through it.
  6. To permit participation in interactive features on the Platform.
  7. Fulfilling obligations or duties that are required by applicable law.
  8. Any other purpose, for which the user will always be warned and will have your consent.

We may also use your information to contact you about our own and third party services that may be of interest to you. If you do not want us to use your information for this purpose, please let us know by using the means we make available and in accordance with this policy.

6. Transfer of Information

SW does not commercialize personal information. SW may share any type of information that is not capable of identifying its users and therefore cannot be considered as personal information, without any restriction and for any purpose, such is the case and for information purposes only, the dissociated data.

SW may disclose personal information about its users:

  • To its affiliates or subsidiaries.
  • In addition, when necessary SW may subcontract with third parties, such as software providers or telematics systems, computer support services, hosting service providers, information storage, among others. These third parties will process personal data on our behalf and following our instructions, whereby it is pertinent to point out that these third parties will apply the corresponding level of diligence.
  • To comply with the purpose for which the user entrusted the information.
  • With the consent of the user or following his instructions
  • We may also disclose personal information about users to comply with any court order, Decree, Law, Providence or to respond to any governmental or regulatory request.
  • With identity verification services offered by third parties. SW may share user information with identity verification service providers for purposes of corroborating user identity, fraud prevention and minimizing money laundering or terrorist financing risks. These service providers confirm the identity of the user by comparing the information provided to us with public records and other third party databases. These providers may create derivative data based on personal information that may be used for identity verification services; SW does not control the privacy policies of these providers. SW uses the services of MetaMap, Inc. to identify and authenticate its users when you create or create an account for the execution of certain services.
  • With credit scoring or rating services. SW may share user information with providers of credit scoring services in order to generate a score relating to transactions, which may serve as an indication of the user’s trustworthiness on the Platform. SW uses the services of CredoLab Pte. Ltd. for these activities.
  • For advertising purposes when accepted by the user.
  • With financial institutions. Your information may be shared with financial institutions in order to process payments.
  • With businesses affiliated to the Platform whose B2C services are required by the user.
  • With other Platform users. A user’s information may be shared with other users when performing rating or rating activities of the user for the use of Platform services, or in the case of sending, requesting, receiving o lending cryptocurrencies. In the case of cryptocurrency loans through P2P transactions, the user acting as the borrower, by executing the transaction, expressly authorizes SW to provide the lender user with their contact information such as: (i) email address and (ii) phone number.
  • In the event of mergers, spin-offs or acquisitions, bankruptcies or change of address or control of SW.
  • Aggregate Data. SW may create anonymized or de-identified data from personal information by removing components that allow for identification. We may share aggregated and/or anonymous data with third parties for their own uses.

Additionally, in order to provide the services required by the user, it may be necessary to transfer the information provided to a jurisdiction other than the user’s jurisdiction, with the possibility that the applicable legislation may be different from the Panamanian and/or yours. In the case of residents of the European Union, the European Economic Area (EEA) or other jurisdictions with special legislation on the matter, it should be considered that this might differ from Panamanian law, in this sense, please take into consideration that you could be transferring information to a law and a jurisdiction different from yours.

As we indicated in advance, SW may subcontract for data processing, collection, provision or management of data and information to third parties or transfer personal information to other affiliated entities, related or linked to SW; service providers, and business partners located in countries other than the user, for example, the United States of America, Guatemala, among others in accordance with applicable law and taking appropriate precautions.

These third parties, among other possible functions, are primarily for the purpose of providing services to users, processing certain transactions and computer support activities.

BY PROVIDING US WITH YOUR PERSONAL INFORMATION AND ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY AUTHORIZE SUCH TRANSFERS, STORAGE OR USE. UNDER NO CIRCUMSTANCES SHALL THIS IMPLY A BREACH OR VIOLATION OF THE RIGHTS OF USERS IN TERMS OF PRIVACY PROTECTION AND THE PROPER TREATMENT OF THE DATA PROVIDED.

7. Customer Identity Verification

Users who wish to use certain functionalities of the Platform, which are indicated on the Platform, must adhere to the KYC principles, as well as the international standards and principles on anti-money laundering, anti-terrorist financing and legal compliance practices set forth in this policy:

Compliance with the platform’s KYC policy may be mandatory for accessing to certain services offered on the platform. Compliance with the KYC policy may involve verification of users’ real name and accounts associated with P2P and/or B2C transactions, including cryptocurrency accounts and fiat currency accounts, (all collectively “Accounts”). In addition, Users must ensure that the Accounts they use on the Platform for the use of P2P and/or B2C services are properly registered and that only they use them.

In accordance with the Terms of Use of the Platform, all users are responsible for ensuring that they have the legal rights and authorizations to carry out transactions in accordance with applicable laws.

SW IS NOT RESPONSIBLE FOR THE LEGALITY OR ILLEGALITY OF TRANSACTIONS MADE BY USERS. ALTHOUGH THE PLATFORM IS NOT A PARTY TO P2P TRANSACTIONS BETWEEN USERS, IT RESERVES THE RIGHT TO REVIEW (BUT IS NOT OBLIGATED TO REVIEW) THE LEGALITY OF SUCH TRANSACTIONS AND TAKE APPROPRIATE ACTION IN COMPLIANCE WITH APPLICABLE LAWS AND REGULATIONS.

It is the responsibility of users to comply with applicable laws regarding the lawful use of the Platform in their jurisdiction, as well as other applicable regulations.

8. Privacy Policy for Third Party Services

To enable the performance of P2P operations, B2C and other services of the Platform, SW relies on third party services who offer identity verification mechanisms, generation of score or credit ratings, data storage, among others. These providers have their own privacy and data management policies, which comply with international standards and the corresponding legal and sub-legal regulations, thus, in accordance with Clause 6 of this Privacy Policy, in order to consult the management, handling and data collection carried out by our suppliers you can consult the following links:

By accessing, registering and using the Platform the user and / or owner of the data or personal information gives SW free, prior, express and informed consent for the processing of their data. Such consent is granted by the holder, who proves his identity sufficiently by the means provided by SW in the Platform, as well as the representative and / or attorney of the holder, upon proof of representation.

The aforementioned authorization is granted by means of any format that allows obtaining it, through unequivocal conduct that allows concluding that without such consent the data would not have been handled or processed.

The authorization will be requested, accepted and understood in the user’s record at the time of the creation of the profile or account and at the time of acceptance of the Terms of Use and this policy. Therefore, SW will be able to have physical or electronic files directly or through third parties for evidentiary purposes related to the provided authorizations.

10. Revocation of authorization

The user as the owner of the data and information may at any time revoke the authorization granted for the processing thereof or request, free of charge, the deletion of the same, provided that it is not prevented by a legal or contractual provision.

However, the revocation of consent may imply the impossibility of being able to use Suni Wallet services and therefore would imply the termination of the use of the same as provided in the Terms of Use.

11. Right of Access, Rectification, Deletion and Portability

We take reasonable measures to ensure that the information provided to us is updated, correct and complete, in this sense, under Panamanian law and specifically in accordance with Act 81-2019 and its corresponding Regulations, you are entitled to the following rights:

  • Right of access: You have the right to access your personal data available to us.
  • Right of rectification: You have the right to complete, rectify, delete or block your personal data whenever you wish.
  • Right of revocation: If you so provide and give us your consent to process your data, you have the right to revoke such consent and have your personal data deleted.
  • Right of objection: You can refuse to the processing of your data. We will carry on this action, unless there are justified grounds for the processing.
  • Right of portability: You have the right to obtain a copy of the personal data we handle about you in a structured manner, in a generic and commonly used format, which allows it to be operated by different systems and/or transmitted to another controller.

SW will consider all requests related to the fulfillment of the aforementioned rights within the deadlines and timeframes stipulated by the applicable law. However, it is possible that certain information may not be subject to certain requests or inquiries by the user; such is the case in which we must process your information for our legitimate interests or to comply with some kind of legal provision. 

To enforce the aforementioned rights, please contact us at contacto@suniwallet.com or through the mechanisms provided by the Platform. In order to enforce the aforementioned rights, it will be necessary to demonstrate your identity, as well as the contact details required to answer your request, when processing such request.

12. Cookies and Geolocation Policy

The Platform may use small files or archives that are sent along with the pages or sections that are part of the Platform and that browsers store on the hard drive of computing devices. These monitoring technologies allow us and our technology partners to collect information, including your IP address, mobile device identifier, the type of Internet browser you are using, operating system, referring URLs, date/time stamps, pages visited and tags. We may also use web beacons or pixels to analyze usage patterns on our Platform.

Technologies we may use for this automatic data collection can include:

  • Cookies (or browser cookies). A cookie is a small file that is placed on your computer’s hard drive. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may not be able to access certain sections of the Platform.
  • Flash Cookies. Certain features of the Platform may use locally stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on Suni Wallet. Flash cookies are not managed with the same browser settings that are used for browser cookies.
  • Web Beacons. Pages, sections or sections of the Platform and our emails may contain small electronic files known as web beacons (also known as clear gifs, pixel tags and single pixel gifs) that allow SW, for example, to count users who have visited certain pages and for other statistics related to the Platform (for example, to record the popularity of certain pages or Platform content and to verify system and server integrity).
  •  Analytics. we may use third party service providers to monitor and analyze the use of Suni Wallet. We may use Google Analytics. Google Analytics is a web analytics service provided by Google LLC (“Google”) that tracks and reports site traffic. For more information about Google’s privacy practices, please visit Google’s Privacy and Terms webpage: https://policies.google.com/privacy?hl=eng . The Google Analytics opt-out browser add-on offers visitors the ability to prevent Google Analytics from collecting and using their data, available at: https://tools.google.com/dlpage/gaoptout.
  • Geolocation. The Location feature allows the Platform or third party services to collect and use information based on the user’s current location to provide location-based services. To access these features, the user must enable the location option on their mobile device. The location feature may use GPS and Bluetooth (if available), along with data from cellular antennas and active Wi-Fi hotspots, to determine the user’s approximate location.

It is possible to disable the location feature at any time by accessing the device settings or adjusting the location settings. However, disabling such functionality may result in the inability to access certain functionalities offered by the Platform. The information collected by SW or by third parties providing services to SW (in relation to the geolocation function) will always be treated in accordance with this Privacy Policy. Under no circumstances will SW trade or commercialize the information related to the location of its users.

Some content or functionality on the Platform may be provided by third parties, which may use cookies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. These third parties may use this information to provide you with interest-based (behavioral) advertising or other targeted content. SW does not control the monitoring technologies of these third parties or how they may be used. If you have any questions about any specific advertising or other content, you should contact the provider responsible for that advertising directly.

13. Data retention period

We store the personal information provided for the necessary period of time to fulfill the purposes for which it was provided by the user. Consequently, the time of storage and maintenance of the information depends on the purpose for which the information was provided by the user pursuant to the applicable legislation.

14. Options About How We Use and Disclose Your Information

We strive to offer you options with respect to the information you provide to us. We offer mechanisms to give you the following control over your information:

  • Monitoring and Advertising Technologies. You can set your browser to refuse all or some browser cookies or to disable our monitoring mechanisms mentioned above, or to notify you when cookies are being sent. If you disable or reject cookies, please note that some functionality may be inaccessible or may not function properly.
  • Promotional offers from SW or its affiliates. If you do not want SW to use your email address to promote its own or third party products or services, you may unsubscribe if you have registered to the relevant list by sending us an email indicating your request to contacto@suniwallet.com using the options we make available on the Platform. If we have sent you a promotional email, you may send us a reply email requesting that we suppress it in future email distributions.

We do not have control over the collection or use of your information by third parties for delivering advertising based on your interests or preferences. However, these third parties may provide you with ways to opt out of having your information collected or used.

15. Commitment to security and confidentiality

SW enforces applicable policies, rules and technical security measures regarding the handling of information to protect users against situations such as unauthorized access, improper use, unauthorized modifications and accidental destruction or loss of data. 

All persons involved in the processing of user data are subject to the duty of secrecy and/or confidentiality with respect to the personal data being processed, to which they have access due to their functions in accordance with the relevant protocols for the appropriate treatment.

SW undertakes the required technical and organizational measures to ensure the confidentiality, integrity, availability and permanent resilience of the systems and services for the processing of personal data, pursuant to national and international standards on the subject. However, the transmission of information over the Internet is not completely secure. Although we do our best to protect user’s personal information, we cannot guarantee the security of such personal information transmitted to our Platform. Any transmission of personal information is at the user’s own risk.

16. Amendments to this Privacy Policies

SW reserves the right to make, at any time, amendments or changes to the provisions contained in this Privacy Policy. In this regard, as a user, you should regularly review them. In any case, SW will display the date of the last amendment made in the upper right corner of this document. Such amendments shall enter into force from the publication of the same on the Platform. The use or access to the Platform by the user shall be considered as proof of the user’s knowledge and acceptance of the Privacy Policy.

17. Underage

The Suni Wallet Platform is not intended for use by persons under the age of 18. No one under the age of 18 may provide personal information on the Platform. We do not knowingly collect personal information from persons under the age of 18. If you are under 18, please do not use or provide information on the Platform. If we discover that we have collected or received personal information from persons under the age of 18 without verifying parental consent, we will delete such information. If you believe that, we might have any information from or about a person under the age of 18 or underage, please contact us.

18. Contact

You may contact us through:

E-mail contacto@suniwallet.com