Privacy Policy
Hawk Capital Global Ltd is committed to protecting Your privacy.
This Privacy Policy explains how we handle data in accordance with the Virgin Islands Data Protection Act No. 3 from 2021 (hereafter, DPA), including what we collect and how we obtain it, how we use it, when and in what case we disclose it, and some of your options for managing your data with Hawk Capital Global Ltd with regard to:
Purchase of HAWEX tokens (“Purchase”);
our websites.
Who are we and how to contact us?
Hawk Capital Global Ltd is incorporated in British Virgin Islands under registration number 2126321, having registered office at Quijano Chambers, P.O. Box 3159, Road Town, Tortola, British Virgin Islands.
The words “we”, “our”, “us” refer to Hawk Capital Global Ltd.
If you have questions, please contact us at [email protected].
What data, for what purposes, for how long, and based on what grounds do we process as Controller?
Purpose of Processing | How we collect the data | Data Subjects: Categories of Data | Storage Period | Legal Basis |
| Registration | Directly from you
| Our clients: Contact information provided by you within the Purchase, such as email address. | Until the termination of a contract or until the deletion of an account whichever happened earlier, and within the terms specified by law | Processing is necessary to perform a contract to which the Data Subject is a party or to take, at the request of the Data Subject, procedures for concluding, amending or terminating a contract (art. 2(b) of the DPA) We will not be able to provide you with our Purchase process if you fail to provide the data |
| Onboarding | Directly from you
| Our clients: Email; client’s wallet address; name, surname; date of birth; ID; address of residency; country of citizenship; PEP status; US person status; information about economic or personal activities; yearly income; information on the origin of the funds. Authorized persons: Email; name, surname; date of birth; ID; address of residency; country of citizenship; PEP status; US person status; base for authorization. Beneficiaries: Name, surname; date of birth; ID; address of residency; country of citizenship; PEP status; US person status; share in the company. | 5 years after onboarding | The Processing is necessary to fulfil obligations imposed on us by the legislation of BVI (art. 2(c) of the DPA)
|
| Purchase process | Directly from you | Client: Wallet address; transaction amount; currency; network.
| Until the termination of a contract or until the deletion of an account whichever happened earlier, and within the terms specified by law | Processing is necessary to perform a contract to which the Data Subject is a party or to take, at the request of the Data Subject, procedures for concluding, amending or terminating a contract (art. 2(a) of the DPA) We will not be able to provide you with our purchase process if you fail to provide the data |
| In-service communication, such as communication with the support team | Directly from you Automatically through your use of our service | Our users: Data about your account and data from the message to the support; email.
| Until the termination of a contract or until the deletion of an account whichever happened earlier, and within the terms specified by law | Processing is necessary to perform a contract to which the Data Subject is a party or to take, at the request of the Data Subject, procedures for concluding, amending or terminating a contract (art. 2(a) of the DPA) We will not be able to provide you with our purchase process if you fail to provide the data |
How do we store your personal information?
Your information is securely stored on our services located in British Virgin Islands.
We keep your personal information for the time period specified above for each type of data. We will then dispose this information by deleting rows from the database.
In cases specified by the legislation of BVI or other applicable law we may store and handle your personal information after achieving the original purposes of data processing or the end of time period specified above.
According to art. 2(d) of the DPA we reserve the right to extend the term of storage your data if we have any reasons to consider that the processing is necessary to initiate or defend against any actions to claim rights or legal proceedings, or related to judicial or security procedures. According to the section 4(1)(a) of the BVI Limitation Act 1961 the limitation period for civil claims for rights arising from contractual relationship is six (6) years.
Who do we share your data with?
We use third-party service providers to help us provide the Services and give support.
They only receive data needed to provide their services to us. We have agreements with our service providers that say they cannot use any of this data for their own purposes or for the purposes of another third party.
We prohibit our service providers from selling data they receive from us or receive on our behalf.
We require service providers to use data only in order to perform the services we have hired them to do (unless otherwise required by law). For example, we may use a company to help us provide client support. The information they may receive as part of providing that support cannot be used by them for anything else.
We contractually oblige our service providers to provide sufficient guarantees to apply technical and organisational measures in a manner that ensures that the processing meets the requirements, rules and controls stipulated in the DPA, and other applicable legislation, statutory instruments, administrative acts and guidelines.
Acting as Controller we share your data with the following processors and categories of processors:
| Processors, their Location and the Link to Privacy Policy / Website if applicable | Purpose of Transfer | Safeguards for restricted transfers (outside the EEA and ‘adequate’ jurisdictions) |
| Microsoft Ireland Operations Limited | Hosting Service Provider | Adequate country (IE) |
| Chainalysis LTD, UK | Transactions monitoring | Adequate country (UK) |
AML/KYC compliance: transaction information storage
| Directly from you Automatically through your use of our service | User: Information about transaction, including sum of transaction, time, corresponding wallet |
| AML/KYC compliance: Suspicious Activity Report (SAR) | Directly from you Automatically through your use of our service | User: Information about transaction, including sum of transaction, time, corresponding wallet |
| AML/KYC compliance: business correspondence with user | Directly from you
| User: Content of the correspondence |
Automated decisions
We do not make any automated decisions about you that would result in legal or other similarly significant effects on you.
Cookies
Please read our Cookie Policy for information about cookies.
Your rights
You have the following rights under the DPA concerning personal data: the right to obtain information (art. 14(1)), right to request personal data transfer (art. 14(2)), right to correction or erasure personal data (art. 18(1)(a)), right to restrict processing (art. 18(1)(b)), right to stop processing (art. 21(1)), right to processing and automated processing (art. 20(1)).
You may also exercise the mentioned rights by contacting us via email at [email protected].
Changes to this Policy
We regularly update this Policy in case there are significant changes in the way we process your personal data.
You will receive a notification prior to such significant changes become effective by email if you provided us with your email address, by our mobile app or by pop-up notice on our website.