Ver. 1.2 – 09/20/2019
Digiwills. (“Digiwills,” “we,” “our,” or “us”) values your privacy. In this Privacy Policy (“Policy”), we describe the information we collect, how we use it, and when and with whom we share it. This Policy applies to all sites, including https://digiwills.io, mobile applications, and other online services (collectively, “Platform”) made available by Digiwills. This Policy applies only to information collected on or through the Platform. It does not apply to information collected or obtained by or through any other means (including, without limitation, information collected offline, in person, over the telephone and/or by mail, or from third parties outside the Platform). Undefined capitalized terms used herein shall have the definitions as set forth in our Terms of Use. By creating an account on Digiwills.io, you agree to this Policy. IF YOU DO NOT AGREE TO THIS POLICY, PLEASE DO NOT ACCESS OR USE THE PLATFORM.
INFORMATION WE COLLECT
How we collect and store information depends on how you access and use the Platform. We collect information in multiple ways including when you provide information directly to us, when you permit third parties to provide information to us, and when we passively collect information from you, such as information collected from your browser or device.
Information You Provide Directly to Us
We may collect information from you during your use or access of the Platform, such as:
When you register for an Account;
When you enroll for electronic newsletters;
When you make a purchase;
When you fill out any forms;
When you enter a sweepstakes or contest, or register for a promotion;
When you transmit User Content;
When you download or use one of our mobile applications; or
When you otherwise communicate with us or other users through the Platform.
This list is illustrative, not exhaustive; the Privacy Policy applies to all use of the Platform.
The information you provide directly to us may concern you or others and may include, but is not limited to: (a) name; (b) email address; (c) home or business telephone number; (d) demographic information (e.g., gender, age, and other information relevant to use it for user surveys and/or offers); (d) date of birth; (f) photographs; (g) in certain circumstances, payment and/or identity verification information; and/or (m) any other content you include in communications with other users through the Platform or communications with us. You are not required to provide us with such information, but certain features of the Platform may not be accessible or available, absent the provision of the requested information.
Social networking sites, such as Facebook, have their own policies for handling your information. For a description of how these sites may use and disclose your information, including any information you make public, please consult the sites’ privacy policies. We have no control over how any third-party site uses or discloses the personal information it collects about you.
We may collect information about you or others through non-affiliated third parties. For example, to the extent permitted by law, we may, in our sole discretion, ask for and collect supplemental information from third parties, such as information about your credit from a credit bureau, or information to verify your identity or trustworthiness, or for other fraud or safety protection purposes. We may combine information that we collect from you through the Platform with information that we obtain from such third parties and information derived from any other products or services we provide.
Information That is Passively or Automatically Collected
Device/Usage Information. We and our third-party service providers, which may include ad networks and analytics companies including DoubleClick and Google Analytics, may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Platform. As described further below, we may collect and analyze information including but not limited to (a) browser type; (b) ISP or operating system; (c) domain name; (d) access time; (e) referring or exit pages; (f) page views; (g) IP address; (h) unique device identifiers (e.g. IDFA or Android ID); and (i) the type of device that you use. We may also track when and how frequently you access or use the Platform. We use this information (including the information collected by our third-party service providers) for Platform analytics (including to determine which portions of the Platform are used most frequently and what our users like/do not like).
Location Information. When you use the Platform, we may collect general location information (such as IP address). If you install our mobile app, we may ask you to grant us access to your mobile device’s geolocation data. If you grant such permission, we may collect information about your precise geolocation, and we may use that information to improve the Platform, including providing you with location-based features. If you access the Platform through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details. If you disable certain functions, you may be unable to use certain parts of the Platform.
Cookies and Other Electronic Technologies. We and our third-party service providers may use cookies, clear GIFs, pixel tags, and other technologies that help us better understand user behavior, personalize preferences, perform research and analytics, and improve the Platform. These technologies, for example, may allow us to tailor the Platform to your needs. We or our third-party service providers also may use certain of these technologies in emails to our customers to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but your browser may allow you to modify your browser settings to decline cookies if you prefer. If you disable cookies, you may be prevented from taking full advantage of the Platform, because it may not function properly. As we adopt additional technologies, we may also gather additional information through other methods.
HOW DIGIWILLS USES THE INFORMATION WE COLLECT
We may use your information for any of the following reasons:
For the purposes for which you provided it;
To enable you to use the Platform;
For customer support and to respond to your inquiries;
For internal record-keeping purposes;
To administer surveys, sweepstakes, promotions, or contests;
To track fees and process billing and payment including sharing with third-party payment gateways and payment service providers in connection with the Platform;
To improve and maintain the Platform and for product development;
To address fraud or safety concerns, or to investigate complaints or suspected fraud or wrongdoing;
To periodically send promotional emails regarding new products from Digiwills, special offers from Digiwills, or other information that may interest you;
For Digiwills’s market research purposes, including, but not limited to, the customization of the Platform according to your interests;
To contact you about goods and services that may interest you or with information about your use of the Platform;
For other research and analytical purposes.
WHEN DIGIWILLS DISCLOSES YOUR INFORMATION
Unless otherwise described in this Policy, we may also share the information that we collect from you through the Platform as follows:
Consent. We may disclose your information to nonaffiliated third parties based on your consent to do so. Such consent includes the disclosure of your information (a) in order to provide services or products that you have requested (please see below for more details); (b) when we have your permission; or (c) as described in this Policy, the Terms of Use, or any other legal terms governing your use of the Platform.
Service Providers. We may provide access to your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us including without limitation billing, sales, marketing, advertising, market research, fulfillment, data storage, analysis and processing, identity verification, fraud and safety protection and legal services. As we retain new service providers, we generally seek contractual assurances from these service providers that they will not use your information in any manner other than to help us provide you with the services and products available from Digiwills.
Legal Requirements. We may disclose your information when required by law or when we believe in good faith that such disclosure is necessary to: (a) comply with subpoenas, court orders, or other legal process we receive; (b) establish or exercise our legal rights including enforcing and administering agreements with users; or (c) defend Digiwills against legal claims. If we are required by law to disclose your information, we will use commercially reasonable efforts to notify you unless (1) we believe in our sole discretion that providing notice could create a risk of injury or death, or that harm or fraud could be directed to Digiwills or users; or (2) we are precluded from providing notice by law. We will attempt to provide the notice by email. While you may challenge the disclosure request, please be advised we may still be legally required to turn over your information.
Protection of Digiwills and Others. We may disclose your information to whomever necessary when we believe it appropriate to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms of Use or any other legal terms governing use of the Platform, and/or to protect our rights and property and the rights and property of other users.
Business Transfers. As we continue to develop our business, we may sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such contemplated or actual transactions or where there is any change of control of Digiwills, user information may be among the shared and/or transferred assets.
App Store Providers. We may provide your identity and mobile device identifier to third-party app store providers (for example, the Apple App Store) to allow you to download our mobile apps.
Academics and Research. We may provide information about users to third parties for academic and research purposes, in anonymized or aggregated form.
Please be advised that some information you provide and/or that we collect will be publicly accessible. For instance, registration for an Account requires that you provide us with your name. If you register through Facebook, the Platform will use the name associated with your Facebook account. Your name (full name, or in some instances, your first name and last initial) may be visible to other users. Depending on the circumstances, your name may be attached to your Content or information, participating in discussions or forums, blog comments and profile information. Certain other people, including other users with whom you have interacted via the Platform, will see information about you that is attached to your name. For example (but without limitation), your name and/or your profile picture. Thus, other users may be able to personally identify you based on Content you provide. Similarly, the information we collect, including but not limited to when you last accessed the Platform, may be shared with other Members with whom you are interacting or otherwise made public.
We invite you to post Content on or through our Platform, including, but not limited to, your comments, pictures. However, please be careful and responsible whenever you are online. If you choose to post User Content on or through the Platform, such as through Member-to-Member messaging or through our forums, blogs, or other postings, that information: (a) may be or may become publicly available; (b) may be collected and used by third parties with or without our knowledge; and (c) may be used in a manner that may violate this Policy, the law, or your personal privacy.
ONLINE ANALYTICS AND TAILORED ADVERTISING
Analytics
We may use third-party web analytics services on the Platform, such as those of Google Analytics. These service providers use the sort of technology described in the Information That Is Passively or Automatically Collected section above to help us analyze how users use the Platform, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Platform. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-Out Browser Add-on.
PRIVACY OF MINORS
Our Services are not designed for minors under 18. Only persons 18 years of age or older may use the Platform. If we discover that an individual under 18 has provided us with personal information, we will close the account and delete the personal information to the extent required by the Children’s Online Privacy Protection Act. We may, where permitted by law, retain certain information internally for purposes described in this Policy.
SECURITY
We employ physical, procedural and technological security measures to help protect your personal information from unauthorized access or disclosure. Digiwills may use encryption, passwords, and physical security measures to help protect your personal information against unauthorized access and disclosure. No security measures, however, are 100% failsafe. Therefore, we do not promise and cannot guarantee, and thus you should not expect, that your personal information or communications will not be collected, disclosed and/or used by others. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, keeping your log-in and password private, and not recycling passwords from other websites or accounts. Digiwills is not responsible for unauthorized use of your information nor for any lost, stolen, or compromised passwords, or for any activity on your Account via unauthorized password activity.
The platform will storage your wills on the Blockchain where only you with your Private Key have access. Your successors will have access to the wills once meets criteria.
LINKS TO EXTERNAL PLATFORMS
The Platform may contain links to other websites or resources over which Digiwills does not have any control. Such links do not constitute an endorsement by Digiwills of those external websites. You acknowledge that Digiwills is providing these links to you only as a convenience, and further agree that Digiwills is not responsible for the content of such external websites or the protection and privacy of information you provide while visiting such external websites.
UPDATING, DELETING, AND CORRECTING YOUR INFORMATION
You may review, correct and delete certain information about you by logging in to the Platform and navigating to your preferences page. You must promptly update your Account information if it changes or is inaccurate. Upon your request, we will close your Account and remove your profile information from view as soon as reasonably possible. We may retain information from closed Accounts in order to comply with the law, prevent fraud, collect any fees owed, troubleshoot problems, assist with any investigations of any user, enforce our Terms of Use, and/or for any other purposes otherwise permitted by law that we deem necessary in our sole discretion. You should understand, however, that once you transmit User Content through the Platform, you may not be able to change or remove it. Once we have deactivated or removed your Account, you agree that Digiwills will not be responsible to you for retaining information related to your Account.
YOUR CHOICES REGARDING EMAIL COMMUNICATIONS
We may send periodic emails to you. You may opt out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your Account or any services you have requested or received from us.
CHANGES TO THIS POLICY
THIS POLICY IS CURRENT AS OF THE EFFECTIVE DATE SET FORTH ABOVE. DIGIWILLS MAY, IN ITS SOLE AND ABSOLUTE DISCRETION, CHANGE THIS POLICY AT ANY TIME. DIGIWILLS WILL POST ITS UPDATED POLICY ON THE PLATFORM, SEND YOU A MESSAGE OR OTHERWISE NOTIFY YOU WHEN YOU ARE LOGGED INTO YOUR ACCOUNT. DIGIWILLS ENCOURAGES YOU TO REVIEW THIS POLICY REGULARLY FOR ANY CHANGES. YOUR CONTINUED ACCESS TO OR USE OF THE PLATFORM WILL BE SUBJECT TO THE TERMS OF THE THEN-CURRENT POLICY.
CONSENT TO TRANSFER
Our computer systems are currently based in the Dominican Republic, so your personal data will be processed by us in the Dominican Republic, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. If you create an Account with the Platform as a visitor from outside the Dominican Republic, by using the Platform, you agree to this Policy and you consent to the transfer of all such information to the Dominican Republic, which may not offer a level of protection equivalent to that required in the European Union or certain other countries, and to the processing of that information as described in this Policy.
DELETE PERSONAL DATA
You can request “to be forgotten”. We provide Visitors and Authorized Customers with a mechanism to delete/deactivate Personally Identifiable Information from the Site’s database by contacting . However, because of backups and records of deletions, it may be impossible to delete a Visitor’s entry without retaining some residual information. An individual who requests to have Personally Identifiable Information deactivated will have this information functionally deleted, and we will not sell, transfer, or use Personally Identifiable Information relating to that individual in any way moving forward.Visitors and Authorized Customers may contact us related to your rights (The right to access, The right to rectification, The right to erasure , The right to restrict processing, The right to object to processing, The right to data portability, The right to complain to a supervisory authority, The right to withdraw consent).
KYC/AML Policy
Digiwills Anti-Money Laundering and Know Your Customer Policy (hereinafter – the “KYC/AML Policy”) is designated to prevent and mitigate possible risks of Digiwills being involved in any kind of illegal activity.
Both international and local regulations require Digiwills to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity from its Users.
KYC/AML Policy covers the following matters:
Verification procedures. Compliance Officer. Monitoring Transactions. Risk Assessment.
1. Verification procedures
One of the international standards for preventing illegal activity is customer due diligence (“CDD”). According to CDD, Digiwills establishes its own verification procedures within the standards of anti-money laundering and “Know Your Customer” frameworks.
1.1. Identity verification
Digiwills’s identity verification procedure requires the User to provide Digiwills with reliable, independent source documents, data or information (e.g., national ID, international passport, bank statement, utility bill). For such purposes Digiwills reserves the right to collect User’s identification information for the KYC/AML Policy purposes.
Digiwills will take steps to confirm the authenticity of documents and information provided by the Users. All legal methods for double-checking identification information will be used and Digiwills reserves the right to investigate certain Users who have been determined to be risky or suspicious.
Digiwills reserves the right to verify User’s identity in an on-going basis, especially when their identification information has been changed or their activity seemed to be suspicious (unusual for the particular User). In addition, Digiwills reserves the right to request up-to-date documents from the Users, even though they have passed identity verification in the past.
User’s identification information will be collected, stored, shared and protected strictly in accordance with the Digiwills’s Privacy Policy and related regulations.
Once the User’s identity has been verified, Digiwills is able to remove itself from potential legal liability in a situation where its Services are used to conduct illegal activity.
1.2. Card verification
The Users who are intended to use payment cards in connection with the Digiwills’s Services have to pass card verification in accordance with instructions available on the Digiwills’s Site.
2. Compliance Officer
The Compliance Officer is the person, duly authorized by Digiwills, whose duty is to ensure the effective implementation and enforcement of the KYC/AML Policy. It is the Compliance Officer’s responsibility to supervise all aspects of Digiwills’s anti-money laundering and counter-terrorist financing, including but not limited to:
a. Collecting Users’ identification information. b. Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations. c. Monitoring transactions and investigating any significant deviations from normal activity. d. Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs. e. Updating risk assessment regularly. f. Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement, which are involved in prevention of money laundering, terrorist financing and other illegal activity.
3. Monitoring Transactions
The Users are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, Digiwills relies on data analysis as a risk-assessment and suspicion detection tool. Digiwills performs a variety of compliance-related tasks, including capturing data, filtering, record-keeping, investigation management, and reporting. System functionalities include:
1) Daily check of Users against recognized “black lists” (e.g. OFAC), aggregating transfers by multiple data points, placing Users on watch and service denial lists, opening cases for investigation where needed, sending internal communications and filling out statutory reports, if applicable;
2) Case and document management.
With regard to the KYC/AML Policy, Digiwills will monitor all transactions and it reserves the right to:
ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
request the User to provide any additional information and documents in case of suspicious transactions;
suspend or terminate User’s Account when Digiwills has reasonably suspicion that such User engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor Users’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.
4. Risk Assessment
Digiwills, in line with the international requirements, has adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, Digiwills is able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate to the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
CONTACT US
If you have any questions about the Privacy Policy or the Platform, please contact us by sending an email to [email protected]
Digiwills
Registry number: 260495
Address: Av. La Gaviota, Residencial La Mañosa, Mnz 1, Edif. 2, Apt. 4B, Ciudad Juan Bosch, Santo Domingo, Republica Dominicana.