Privacy Policy

SECTION B: EXTENSIVE DATA PROTECTION AND PRIVACY POLICY

1. COMPLIANCE WITH GLOBAL PRIVACY STANDARDS

WILDX LIMITED is fiercely committed to safeguarding your privacy. We process personal data in strict adherence to the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the EU GDPR, and the California Consumer Privacy Act (CCPA) where applicable.

2. EXHAUSTIVE LIST OF DATA WE COLLECT

We act as the Data Controller for the following macro-categories of Personal Data:

• Biographical Data: Full legal name, date of birth, gender, nationality, and marital status.
• Contact Data: Primary and secondary email addresses, mobile telephone numbers, physical billing and residential addresses.
• Documentary KYC Data: High-resolution scans of passports, driver's licenses, national ID cards, utility bills, tax statements, and live biometric video selfies.
• Financial and Transactional Data: Linked bank account details (IBAN, SWIFT), credit/debit card partial PANs, crypto wallet public addresses, transaction hashes, merchant category codes (MCCs), payment volumes, and timestamps.
• Technical Data: Static and dynamic IP addresses, MAC addresses, IMEI numbers, browser user-agents, operating system versions, and WebAuthn/Passkey cryptographic signatures.
• Behavioral Data: Mouse movements, keystroke dynamics, and touchscreen interactions (collected exclusively via SDKs to differentiate human users from automated bots).

3. PURPOSE AND LEGAL BASIS FOR PROCESSING

We process your data under the following lawful bases:

• Contractual Necessity: To open your Account, issue Cards, and process your transactions.
• Legal Obligation: To comply with AML/CTF laws, sanctions screening, and tax reporting regulations.
• Legitimate Interest: To detect fraud, improve our AI risk-scoring algorithms, and enhance network security.
• Explicit Consent: For sending marketing communications and deploying non-essential tracking cookies.

4. COMPREHENSIVE DATA SHARING AND SUB-PROCESSORS

We never sell your data to data brokers. We share data strictly via encrypted API channels with the following categories of verified sub-processors:

• Fiat Payment Gateways: Stripe, PayPal.
• Card Issuing Networks: BSICards, Bridgecard, SMOCUP PAY, Mastercard, Visa.
• Crypto Custodians and Node Providers: Binance, CoinPayments.
• Identity Verification (eKYC) Providers: Veriff, Didit.
• Telecom and Gift Card Integrators: Reloadly.
• Cloud Hosting & Security: Amazon Web Services (AWS), Cloudflare.
• Law Enforcement & Regulators: National Crime Agency (NCA), HMRC, Financial Conduct Authority (FCA), Interpol, and equivalent international agencies upon receipt of a valid subpoena or court order.

5. ARTIFICIAL INTELLIGENCE, PROFILING, AND AUTOMATED DECISION MAKING

5.1. We deploy advanced Machine Learning (ML) and Artificial Intelligence (AI) algorithms to monitor transactions in real-time.
5.2. These systems assign a dynamic "Risk Score" to your Account. If the AI determines a transaction presents a critical fraud risk, it will automatically block the transaction.
5.3. Under Article 22 of the UK GDPR, you have the right to contest any purely automated decision that significantly affects you. You may request manual human intervention by contacting our compliance team.

6. DATA RETENTION LIFECYCLE

6.1. Financial Records: Under the UK Money Laundering Regulations 2017, we are legally mandated to retain your KYC documents, identity data, and transaction histories for a minimum of five (5) years following the closure of your Account.
6.2. Deletion: After the legally mandated 5-year period, your data will be permanently purged from our active databases or subjected to irreversible cryptographic anonymization.

7. EXERCISING YOUR DATA RIGHTS

You hold the following rights regarding your data:

• Right of Access (SAR): Request a comprehensive export of all data we hold on you.
• Right to Rectification: Update inaccurate data.
• Right to Erasure: Request deletion (subject to our 5-year AML retention legal obligation).
• Right to Restrict Processing: Temporarily halt data processing during a dispute.
• Right to Data Portability: Receive your data in a machine-readable CSV/JSON format. Submit requests to legal@wildpaywallet.com. We are legally bound to fulfill standard requests within 30 days.