1.1

Your privacy is important to us and we have taken steps to ensure that we do not collect more information from you than what is necessary for us to provide you the Services and to protect your account.

1.2

We may process the following categories of personal data about you:

Personal Data means any information relating to an identified or identifiable natural person. This information may include, in particular by reference to an identifier, such information as name, age, e-mail address, location, Personal ID and Driver’s License for verification purposes, payment gateway information, and all information, data and materials as we may deem necessary for provision of the Services. When you contact us through any of the communication modes as mentioned below, your email address may be added to our mailing list from which you can unsubscribe at any time using the unsubscribe link set out in each email or by contacting us at contact@itowu.com.

Communication Data may include any communication that you send to us whether that be through the Contact Form on our website or App, through email, text, social media messaging, social media posting or any other means of communication. We process this data for the purposes of communicating with you, for record keeping and for the establishment, pursuance or defence of legal claims. Our lawful ground for this processing is our legitimate interests which in this case are to reply to communications sent to us, to keep records and to establish, pursue or defend legal claims.

Marketing Data may include data about your preferences in receiving marketing from us and your communication preferences. Our lawful ground for this processing is our legitimate interests which in this case are to study how customers use the Services, to develop them, to grow our business and to decide our marketing strategy. We may send you Promo Codes which you may use to get discounts, In-App wallet credits and other features.

1.3

We may use Personal Data, Communication Data and Marketing Data (the “Data”) to provide you with the Services. We may also use such data to send other marketing communications to you.

2.1

By using the App, you provide us with your consent to use your data as per this Privacy Policy. In order to provide you with the Services, it is necessary for us to collect all relevant and necessary data from you. In addition, by signing up and filling the Forms available on the App, you give us your express consent and permission to use your data.

2.2

We will process the data only after taking written instructions/consent from you mostly in electronic form in the form of Clickable button, a checkbox or through an email.

2.3

If you change your mind, you may withdraw your consent for us to contact you, for the continued collection, use or disclosure of your information, at any time, by contacting us at contact@itowu.com.

3.1

You agree that the App and/or third parties may from time to time send e-mail messages to you which offer products and services, promotions, subscriptions or registration-based services or other material. If you wish to discontinue receiving such emails, you may opt-out by writing us through email at contact@itowu.com. Your preferences will then be updated.

4.1

The Data collected by us from you may be used to provide you with the Services and to better understand your needs related services and programs, to correspond with you and reply to your questions about the Services.

4.2

We will not rent or sell your data to third parties. We may store the data in locations outside our direct control (for instance, on servers or databases co-located with hosting providers).

4.3

If you provide any data to us, you are deemed to have authorized us to collect, retain and use that data for the following purposes:

verifying your identity;

providing you with the Services and responding to your queries, feedback or disputes;

making such disclosures as may be required for any of the above purposes or as required by law, regulations and guidelines or in respect of any investigations, claims or potential claims brought on or against us;

provide and maintain the Services;

notify you about changes to the Services.

4.4

We shall ensure that:

The data collected and processed for and on our behalf by any party is collected and processed fairly and lawfully;

You are always made fully aware of the reasons for the collection of data and are given details of the purpose(s) for which the data will be used;

The data is only collected to the extent that is necessary to fulfil the purpose(s) for which it is required;

No data is held for any longer than necessary in light of the purpose(s) for which it is required;

Whenever cookies or similar technologies are used online by us, they shall be used strictly in accordance with applicable laws;

You are informed if any data submitted by you online cannot be fully deleted at your request under normal circumstances and how to request that we delete any other copies of that data, where it is within your right to do so;

Appropriate technical and organizational measures are taken to protect the Data;

Data is transferred securely, whether it is transmitted electronically or in hard copy;

You can fully exercise your rights with ease and without hindrance.

5.1

We shall not be able to keep your data private in response to legal process i.e., a court order or a subpoena or a law enforcement agency’s request. If, in our view, it is deemed appropriate 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 terms of use or as otherwise required by law, we may be compelled to disclose your data and personal data. Moreover, in case of takeover, merger or acquisition, we reserve a right to transfer your data to new platform.

5.2

We may disclose the data in the good faith belief that such action is necessary to:

comply with a legal obligation;

protect and defend our rights or property;

prevent or investigate possible wrongdoing;

protect the personal safety of users of the Service or the public;

protect against legal liability;

5.3

When necessary, we may also disclose and transfer your data to our professional advisers, law enforcement agencies, insurers, government and regulatory and other organizations.

6.1

Your data may be stored and processed at the servers in the United States, Europe or any other country in which the Company or its subsidiaries, affiliates or service providers maintain facilities.

6.2

The Company through the App may transfer data to affiliated entities or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6.3

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

6.4

We will only retain your data preferably for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any record retention or reporting requirements under applicable laws. When deciding what the correct time is to keep the data for we look at its amount, nature and sensitivity, potential risk of harm from unauthorised use or disclosure, the processing purposes, if these can be achieved by other means and legal requirements.

7.1

We store all the data submitted by you through the App at a secure database.

7.2

We are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any data you transmit to or guarantee that your data may not be accessed, disclosed, altered or destroyed by breach of any of our industry standard physical, technical or managerial safeguards.

7.3

Any data supplied by you will be retained by us and will be accessible by our employees, any service providers engaged by us and third parties.

8.1

We may modify the terms of this Privacy Policy from time to time and any such change shall be reflected on the App with the updated version of the Privacy Policy and you agree to be bound to any such changes when you use the App or the Services.

8.2

You acknowledge and agree that it is your responsibility to review the App and this Privacy Policy periodically and to be aware of any modifications. Updates to this Privacy Policy will be incorporated herein.

8.3

Also, occasionally there may be information on the App that contains typographical errors, inaccuracies or omissions that may relate to Service descriptions, pricing, availability and various other information and we reserve the right to correct any errors, inaccuracies or omissions and to change or update the information at any time without prior notice.

9.1

If you have questions about our Privacy Policy, please contact us via email: contact@itowu.com.