March 14, 2023
1. Our Commitment
1.1 Wombat Invest (“Wombat” or “We” or “Our”) respects Your privacy and is committed to protecting the personal data (“Personal Data”) of Wombat’s customers and clients. We do not access it or use it for any purpose other than providing, maintaining, and improving Our services and as otherwise required by law.
2. Personal Data
2.1 This Policy applies to the data processing activities of Wombat Invest in relation to the Affiliate Marketing Program. This Policy outlines how Wombat may collect, process and manage Affiliate (“Your” or “You”) Personal Data to ensure We meet Our obligations to respect Our clients’ privacy and that all such information remains confidential. We fully comply with the General Data Protection Regulation (GDPR) and any other applicable regulations or data protection laws.
3. Your Consent
4. Personal information You volunteer or which We may infer on The Website
4.1 In general, You can access Our website (“Website”) at https://www.wombatinvest.com without giving us any personally identifiable information. Any domain name information that We collect is not used to personally identify You but is instead aggregated to measure the number of visits, average time spent on the Website, and pages viewed. We use this information to measure the use of Our Website and to improve its contents. However, additional services may be available if We have certain information about you.
4.2 We may collect the following information:
4.2.1 the features and services You express an interest in when You use the Website;
4.2.2 your name and contact information, including email address which You may submit to us when You interact with the Website;
4.2.3 information regarding Your personal or professional interests, demographics, experiences with Our products and contact preferences in order to provide You with further correspondence about Our products and services.
4.3 When You use the Website, Wombat automatically receives and records Non-Personal Information on Our server logs from Your browser or mobile platform, including Your location, IP address, cookie information, and the page You requested.
4.3.1 We treat this data as Non-Personal Information, except where We are compelled to do otherwise by law or legal authority.
4.3.2 Wombat Invest only uses this data in aggregate form and We may provide this aggregate information to Our partners about how Our customers, collectively, use the Website, so that Our partners may also understand how users make use of the Website.
5. Personal information You volunteer or which may be collected for the Affiliate Program
5.1 When You connect to, sign up to, participate in, or create an account for Wombat’s Affiliate Program, We may collect Personal Data about you.
5.2 Wombat processes Personal Data that We receive from You in the context of Our business relationship. To the extent necessary and in order to provide Our services We also process Personal Data that may also be obtained from publicly available sources. We collect, use or otherwise process different types of Personal Data about you, depending on Our engagement and the law, which may include:
5.3 Your data is stored in Our encryption-protected system. Your information is received, processed and accessed by a limited number of Wombat staff that need it for the execution of contractual, legal and regulatory obligations and in order to provide You with Wombat products and services.
6. What We Do With the Information
6.1 Your Personal Data is received and processed by Wombat employees that require it for the execution of contractual, legal and regulatory obligations. We use this information to provide You with a better service, in particular for the following reasons:
6.1.1 providing services You have requested and notifying You about important changes or developments to these services;
6.1.2 responding to Your inquiries and complaints or processing Your requests in relation to Your information;
6.1.3 to follow up as part of Our customer care procedures;
6.1.4 updating Our records about you;
6.1.5 internal record keeping;
6.1.6 administering offers;
6.1.7 to improve Our products and services;
6.1.8 crime or fraud detection prevention and prosecution;
6.1.9 competitions and other promotions;
6.1.10 evaluating the effectiveness of Our marketing and for research, training and statistical analysis with the aim of improving Our services;
6.1.11 making Our Website easier for You to use and providing You with access to certain parts of the Website;
6.1.12 to contact You for market research purposes.
6.2. At the time You provide us with any information in response to a request from us, Our request will provide You with specific information on We will use such information.
6.3. We may contact You by email, phone or SMS in relation to the purposes set out in this section and by providing such information You are deemed to have agreed to us contacting You by these methods of communication. We will continue to contact You through such methods until You advise us in writing that You no longer wish to be contacted by certain methods. Please note You are required to accept at least one of the above methods as Your chosen method of receipt of communication from us.
6.4. To the extent Wombat deem such disclosure or transmission is necessary for satisfying the purposes set out above, to the following recipients, Wombat may disclose Your Personal Data to:
6.4.1 Any lawyers, external auditors or advisors, professional consultants, credit reference agencies, notaries, bailiffs, as well as any courts, regulatory, governmental, administrative or other official bodies as agreed or may be required by law, where such disclosure is necessary:
184.108.40.206 to comply with any applicable law or regulation;
220.127.116.11 to enforce applicable terms and conditions or policies;
18.104.22.168 to protect the security or integrity of Our services;
22.214.171.124 to protect Our rights and interests;
6.4.2 Third-party service providers that include but are not limited to: Affiliate Management Platform, IT services, advisory and consultancy services, research, identity verification checks, payment processing services, insurance or other services to Wombat, which are only authorised to process Your Personal Data for the sole purpose of providing such services and in strict adherence with Our instructions. If applicable, We will enter with such third-party service providers into the relevant contractual agreements or the standard data protection clauses that would be required under the GDPR to ensure compliance;
7. Sharing Your Information
7.1 We will not transfer, disclose, sell, distribute or lease Your personal information to third parties other than on the following basis:
7.1.1 where We have Your permission;
7.1.2 where We are required to do so by law;
7.1.3 where it is needed by Our agents, advisors or others involved in running accounts and services for You or in undertaking activities linked to the operation of such services or accounts on Our behalf; or
7.1.4 where the transfer or disclosure would otherwise be in compliance with legal requirements We are subject to including, but not limited to, statute or regulation.
7.2 This process may include sending personal information to other countries, whose data protection laws may not be as extensive as in the European Economic Area. However, We have taken appropriate steps to ensure the same level of protection for the processing carried out in these countries as within the European Economic Area.
8. Accessing Your Personal Information
8.1 If You think any information We have about You is incorrect or incomplete, please email us as soon as possible. We will correct or update any information as soon as possible.
8.2 You may request details of personal information which We hold about you. If You would like a copy of the information held on you, please contact us at email@example.com. To request information, We will need to verify Your identity. Upon receiving a request from You and/or upon the receipt of the applicable fee, We will acknowledge Your request and respond to You within one month of filing Your request.
Wombat is committed to the highest standards to ensure that Your Personal Data is secure, confidential and protected. We take Your data security extremely seriously and adhere to the most rigorous industry standards, including 256-bit, bank-level encryption for the transmission of sensitive financial and personal data. Your information is stored securely on Our servers and processed in accordance with local laws and regulations.