Privacy Policy
Novex 360 S.R.L.
This Privacy Policy describes the types of personal data that Wallex 360 S.R.L. (“Novex 360”, “we”, or the “Company”) may collect through its website and mobile application (the “Platform”), how we process such data, with whom we share it, and what rights are granted to data subjects (“USER” or “data subject”). It also explains the security measures implemented and the contact channels available for exercising rights or submitting inquiries about our privacy practices.
By using the Platform, the USER declares that they have read, understood, and accepted this Policy. If you do not agree, you must refrain from using the Platform.
1) DATA CONTROLLER AND CONTACT INFORMATION
Novex 360 S.R.L.
Address: Av. San Martín, Edificio Manzana 40, Oficina 1605, Santa Cruz de la Sierra, Bolivia
Email for Privacy/ARCO matters: privacidad@wallex360.com (alternative: soporte@wallex360.com)
Regulatory Transparency: Novex 360 S.R.L. is not a financial institution regulated by ASFI. It operates as a technology platform applying KYC, KYB, KYT, and AML/CFT compliance standards in accordance with Bolivian regulations and international best practices.
2) LEGAL BASIS AND PRINCIPLES APPLICABLE IN BOLIVIA
We process personal data in accordance with Law No. 164 (Telecommunications and ICT) and related regulations, following the principles of lawfulness, purpose limitation, proportionality, confidentiality, security, and transparency.
The main legal bases for processing are:
- Contractual performance and pre-contractual steps (account registration, Platform operations).
- Legal and regulatory compliance (anti-money laundering and counter-terrorist financing, UIF/ASFI or other authority requirements).
- Legitimate interest (fraud prevention, security, and service improvement).
- Consent (marketing or use of certain sensitive data such as biometrics, where applicable).
3) PERSONAL DATA WE COLLECT
We may collect the following categories of data, as applicable:
- Identification and contact data: name, surname, document number (ID/passport/NIT), date of birth, address, email, phone.
- KYC/KYB data: facial photographs (biometrics), selfie and/or live video verification, photo of ID document, company incorporation data, and ultimate beneficial owner details (for corporate clients).
- Financial/operational data: bank accounts, payment methods, transaction history, wallet addresses, hashes, transaction references, receipts, support tickets.
- Technical/telemetry data: IP address, device identifiers, access logs, operating system, app version, cookies, and similar technologies.
- Preferences and support data: language, survey responses, and communications with support.
Accuracy: The USER is responsible for the accuracy and updating of the information provided.
4) PURPOSES OF DATA PROCESSING
We use the collected data to:
1. Provide and operate the Platform (account opening, authentication, transaction processing).
2. Ensure AML/CFT compliance: identity verification (KYC/KYB), transactional monitoring (KYT), risk analysis, fraud prevention, and response to requests from UIF/ASFI or other competent authorities.
3. Support and communication: respond to inquiries, send notifications, security alerts, and operational messages.
4. Service improvement: analytics, performance, usability, and abuse prevention.
5. Marketing (where applicable and with your consent/opt-out): product information, updates, and promotions.
6. Legal and contractual compliance: invoicing, accounting, complaint handling, and defense of rights.
If we need to process your data for purposes different from those listed, we will notify you in advance and, when applicable, request your explicit consent.
5) COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES
We use cookies and analytics tools (own or third-party) to understand Platform usage and improve user experience. You may configure your browser to manage or block cookies (some features may be affected).
By using the Platform, the USER declares that they have read, understood, and accepted this Policy. If you do not agree, you must refrain from using the Platform.
1) DATA CONTROLLER AND CONTACT INFORMATION
Novex 360 S.R.L.
Address: Av. San Martín, Edificio Manzana 40, Oficina 1605, Santa Cruz de la Sierra, Bolivia
Email for Privacy/ARCO matters: privacidad@wallex360.com (alternative: soporte@wallex360.com)
Regulatory Transparency: Novex 360 S.R.L. is not a financial institution regulated by ASFI. It operates as a technology platform applying KYC, KYB, KYT, and AML/CFT compliance standards in accordance with Bolivian regulations and international best practices.
2) LEGAL BASIS AND PRINCIPLES APPLICABLE IN BOLIVIA
We process personal data in accordance with Law No. 164 (Telecommunications and ICT) and related regulations, following the principles of lawfulness, purpose limitation, proportionality, confidentiality, security, and transparency.
The main legal bases for processing are:
- Contractual performance and pre-contractual steps (account registration, Platform operations).
- Legal and regulatory compliance (anti-money laundering and counter-terrorist financing, UIF/ASFI or other authority requirements).
- Legitimate interest (fraud prevention, security, and service improvement).
- Consent (marketing or use of certain sensitive data such as biometrics, where applicable).
3) PERSONAL DATA WE COLLECT
We may collect the following categories of data, as applicable:
- Identification and contact data: name, surname, document number (ID/passport/NIT), date of birth, address, email, phone.
- KYC/KYB data: facial photographs (biometrics), selfie and/or live video verification, photo of ID document, company incorporation data, and ultimate beneficial owner details (for corporate clients).
- Financial/operational data: bank accounts, payment methods, transaction history, wallet addresses, hashes, transaction references, receipts, support tickets.
- Technical/telemetry data: IP address, device identifiers, access logs, operating system, app version, cookies, and similar technologies.
- Preferences and support data: language, survey responses, and communications with support.
Accuracy: The USER is responsible for the accuracy and updating of the information provided.
4) PURPOSES OF DATA PROCESSING
We use the collected data to:
1. Provide and operate the Platform (account opening, authentication, transaction processing).
2. Ensure AML/CFT compliance: identity verification (KYC/KYB), transactional monitoring (KYT), risk analysis, fraud prevention, and response to requests from UIF/ASFI or other competent authorities.
3. Support and communication: respond to inquiries, send notifications, security alerts, and operational messages.
4. Service improvement: analytics, performance, usability, and abuse prevention.
5. Marketing (where applicable and with your consent/opt-out): product information, updates, and promotions.
6. Legal and contractual compliance: invoicing, accounting, complaint handling, and defense of rights.
If we need to process your data for purposes different from those listed, we will notify you in advance and, when applicable, request your explicit consent.
5) COOKIES, ANALYTICS, AND SIMILAR TECHNOLOGIES
We use cookies and analytics tools (own or third-party) to understand Platform usage and improve user experience. You may configure your browser to manage or block cookies (some features may be affected).
6) DATA SHARING
We share personal data strictly with:
- Identity verification providers (KYC/KYB) and transaction monitoring providers (KYT).
- Technology providers (hosting, messaging, notifications, support, analytics).
- Operational partners (payment gateways, processors, correspondent banks, exchanges, liquidity providers) as required for authorized transactions.
- Competent authorities (e.g., UIF/ASFI, judicial, police, or administrative bodies) when legally required, upon legitimate request, or to protect rights, prevent harm, or investigate fraud.
- Corporate operations (merger, acquisition, restructuring) under confidentiality safeguards.
Our providers act as data processors, under instructions and confidentiality agreements. They are not authorized to use data for purposes other than service provision or legal compliance.
7) INTERNATIONAL DATA TRANSFERS
We may transfer data to other countries (e.g., for verification, hosting, analytics, or payment processing). When the destination country lacks an equivalent level of protection, we will implement reasonable contractual and organizational safeguards (contractual clauses, security standards, audits) and, where applicable, obtain your consent. By using the Platform, you acknowledge that such transfers may be necessary to provide the service.
8) DATA RETENTION
We retain personal data for the duration of the user relationship and for the additional time necessary to:
- Comply with legal/regulatory obligations (including AML/CFT and UIF/ASFI requirements).
- Address potential claims and defenses of the Company.
Once applicable retention periods expire, we securely delete or anonymize data.
9) DATA SECURITY
We implement technical, organizational, and administrative measures to protect data against unauthorized access, use, alteration, disclosure, loss, or destruction.
However, no method is entirely secure. If you believe your account or data has been compromised, please contact us immediately at privacidad@wallex360.com.
10) DATA SUBJECT RIGHTS (ARCO AND OTHERS)
Under Bolivian law, you may request:
- Access to your data;
- Rectification/Update;
- Cancellation/Deletion, where legally applicable;
- Objection to processing, in permitted cases;
- Restriction of certain processing activities;
- Withdrawal of consent (without retroactive effects);
- Portability, where technically and legally feasible.
To exercise these rights, email privacidad@wallex360.com, attaching identification and details of your request. We may ask for additional information to verify your identity and will respond within reasonable timeframes as established by law.
Note: Certain data cannot be deleted when required for legal/AML-CFT obligations or the exercise/defense of rights.
11) MINORS
The Platform is intended for users aged 18 and above. We do not knowingly collect data from minors. If a minor has provided data, please contact privacidad@wallex360.com to request deletion.
12) THIRD-PARTY LINKS
The Platform may contain links to third-party websites or services that have their own privacy policies.
Novex 360 assumes no responsibility for their content, use, or privacy practices. We recommend reviewing such policies when leaving our Platform.
13) CHANGES TO THIS POLICY
We may update this Policy to reflect changes in practices, services, or applicable laws.
Substantial changes will be notified via a visible notice on the Platform and/or by email. The current version will always be available on the Platform.
14) CONTACT
To exercise rights, ask questions, or file privacy-related complaints:
- Email: soporte@wallex360.com
- Address: Av. San Martín, Edificio Manzana 40, Oficina 1605, Santa Cruz de la Sierra, Bolivia
We share personal data strictly with:
- Identity verification providers (KYC/KYB) and transaction monitoring providers (KYT).
- Technology providers (hosting, messaging, notifications, support, analytics).
- Operational partners (payment gateways, processors, correspondent banks, exchanges, liquidity providers) as required for authorized transactions.
- Competent authorities (e.g., UIF/ASFI, judicial, police, or administrative bodies) when legally required, upon legitimate request, or to protect rights, prevent harm, or investigate fraud.
- Corporate operations (merger, acquisition, restructuring) under confidentiality safeguards.
Our providers act as data processors, under instructions and confidentiality agreements. They are not authorized to use data for purposes other than service provision or legal compliance.
7) INTERNATIONAL DATA TRANSFERS
We may transfer data to other countries (e.g., for verification, hosting, analytics, or payment processing). When the destination country lacks an equivalent level of protection, we will implement reasonable contractual and organizational safeguards (contractual clauses, security standards, audits) and, where applicable, obtain your consent. By using the Platform, you acknowledge that such transfers may be necessary to provide the service.
8) DATA RETENTION
We retain personal data for the duration of the user relationship and for the additional time necessary to:
- Comply with legal/regulatory obligations (including AML/CFT and UIF/ASFI requirements).
- Address potential claims and defenses of the Company.
Once applicable retention periods expire, we securely delete or anonymize data.
9) DATA SECURITY
We implement technical, organizational, and administrative measures to protect data against unauthorized access, use, alteration, disclosure, loss, or destruction.
However, no method is entirely secure. If you believe your account or data has been compromised, please contact us immediately at privacidad@wallex360.com.
10) DATA SUBJECT RIGHTS (ARCO AND OTHERS)
Under Bolivian law, you may request:
- Access to your data;
- Rectification/Update;
- Cancellation/Deletion, where legally applicable;
- Objection to processing, in permitted cases;
- Restriction of certain processing activities;
- Withdrawal of consent (without retroactive effects);
- Portability, where technically and legally feasible.
To exercise these rights, email privacidad@wallex360.com, attaching identification and details of your request. We may ask for additional information to verify your identity and will respond within reasonable timeframes as established by law.
Note: Certain data cannot be deleted when required for legal/AML-CFT obligations or the exercise/defense of rights.
11) MINORS
The Platform is intended for users aged 18 and above. We do not knowingly collect data from minors. If a minor has provided data, please contact privacidad@wallex360.com to request deletion.
12) THIRD-PARTY LINKS
The Platform may contain links to third-party websites or services that have their own privacy policies.
Novex 360 assumes no responsibility for their content, use, or privacy practices. We recommend reviewing such policies when leaving our Platform.
13) CHANGES TO THIS POLICY
We may update this Policy to reflect changes in practices, services, or applicable laws.
Substantial changes will be notified via a visible notice on the Platform and/or by email. The current version will always be available on the Platform.
14) CONTACT
To exercise rights, ask questions, or file privacy-related complaints:
- Email: soporte@wallex360.com
- Address: Av. San Martín, Edificio Manzana 40, Oficina 1605, Santa Cruz de la Sierra, Bolivia