Please note that should read this policy in conjunction with our Terms and Conditions. References to “us”, “we”, “our” and “Forwell” all refer to the Forwell Investments B.V. (Data Controller).
The controller of your personal data is Forwell Investments B.V., registered under the laws of Curacao under reg. no. 136125 (0) with the registered address Emancipatie Boulevard Dominico F. “Don” Martina 29, Curacao. If you need more information please contact us here at [email protected]
What we collect from you
When you join or contact with EWaffiliates, we may collect personal data including but not limited to:
First and last name;
Contact details (e.g. email address, phone number);
Bank account details;
Personal ID, social security, passport details.
Why we need this data?
We are obliged to process data on the basis of various legal provisions. These include, among other things, tax regulations, anti-money laundering regulations, regulations regarding licenced operators issued by supervisory authorities. We process your data in order to verify if you are operating in legally, fair and open way, comply with marketing, social responsibility and personal data protection rules in order to meet the legal obligations imposed on us or to implement a so-called legitimate interest, understood as a perfectly legitimate purpose of data processing, consistent with your rights.
In addition to that, your data may be used by us for the following purposes:
to provide you with services covered by the operation of EWaffiliates’ website;
in order to communicate with us;
to establish mutual collaboration;
in order to perform a contract;
for tax, legal and billing purposes;
for billing purposes as defined in EU data protection law (GDPR);
for the purposes provided by law, including the law on counteracting money laundering.
Legal basis for processing your data
The legal basis for the processing of your personal data by us are:
the provisions of the law, the legal duty that is imposed on us (art. 6 (1) (c) GDPR);
to perform a contract (art. 6 (1) (b) GDPR);
for the purpose of legitimate interests in establishing business relationship with organisation or person acting on our behalf (art. 6 (1) (f) GDPR);
For how long do we keep your data?
We will only keep your personal data stored for as long as is reasonably necessary to carry out the purposes and legal obligations outlined above in this Privacy and as long as it is necessary to contact with you or for the duration of the contract (in case of established cooperation). After the end of contract personal data will be retained for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements or secure our legitimate interests (retention period depends on the category of retained data). After this period, we will either delete or anonymize your information – If deletion is not possible (e.g. because the data has been stored in backup archives) then we will securely store, isolate, and safeguard your information from any further use until deletion can be possible.
Cookies are small text files that are placed on your computer or mobile device when you access websites on the internet. Cookies help users navigate around our website and allow us to tailor the content of our site to fit the needs and preferences of users. None of the cookies we use to collect your personal information (e.g. names, addresses, telephone numbers, email addresses) and they can’t be used to identify you as an individual. They typically collect anonymous identifiers associated with your device, browser, referring site URLs, time or usage information, Website preferences and settings, etc.
find more information about cookies at http://www.allaboutcookies.org
Sharing and Processing your Personal Data
We share information with third parties that help us operate, provide, improve, integrate, customize, support and market our services. We will ensure that all relationships we enter into that involve the processing of personal data are subject to a documented contract that includes the specific information and terms required by the GDPR.
We may share your Personal Data within our partner in order to maintain business cooperation. If required by law, we may disclose your information to a public authority and share it with these other organisations:
Law enforcement agencies, regulators and other authorities;
Fraud prevention agencies;
Third parties you ask us (or permit us) to share your data with;
Third parties necessary to provide products or services we use.
Transfer outside the EEA
By agreeing to the processing of your personal data, you also agree that your data will be processed outside the EEA. We are focused on the full implementation of GDPR standards to provide the same level of protection as in EEA.
You have rights under the GDPR. These consist of:
The right to withdrawn the consent; however, this will not invalidate any previously consented processing; please note that if you withdraw your consent to process your data in order to perform a contract with you, we will have to terminate the contract and we will not be able to establish mutual cooperation;
The right to be informed - you have the right to be informed about how your personal data are processed and why;
The right of access - you have a right to request a copy of the personal information data that we hold about you;
The right to rectification - where personal data is inaccurate, you have the right to request that it be corrected and incomplete personal data completed based on the information they may provide.
The right to be forgotten - you can request us to erase your personal data where there is no lawful basis requiring us to continue processing this personal data. This right only applies in certain circumstances given that legal obligations include data retention periods.
The right to restrict/object processing - in certain circumstances you have the right to object or restrict the processing of your personal data, where this is processing is based on consent or our legitimate interest.
The right to data portability - you have the right to request that your personal data be provided to you in a “structured, commonly used and machine-readable format” (Article 20 of GDPR) and to transfer that data to another party. This applies only to personal data for which processing is based on your consent.
The right to lodge a complaint with a supervisory authority – If you have a complaint about our use of your personal data, we would prefer you to contact us directly in the first instance so that we can address your complaint. However, you can also contact the supervisory authority.
We may refuse you to implement certain rights from those indicated above in a situation where the implementation of a given right would be in contradiction with the legitimate purpose of data processing or with obligations imposed on us by law.
If you want to use one of your above-indicated rights - please contact us at [email protected]