Privacy Policy

WOWS Global Pte. Ltd. cares about your privacy and ensuring an environment of safety and security for transactions to take place.

This Privacy Policy applies to both information that is unique to you and may be used to identify you (“Personal Information”) and also applies to Personal Information collected by us that has been subsequently anonymized or aggregated. This Privacy Policy explains how we collect, use, process and transfer your Personal Information.

By accessing the Sites, using the Services, registering for a user account with WOWS, accepting or otherwise manifesting your assent to this Privacy Policy, or agreeing to provide Personal Information to another party who, in accordance with your agreement with such other party, may share such Personal Information with WOWS, you consent to our collection, use, processing, storage and transfer of your Personal Information in accordance with this Privacy Policy. We will not use, process or transfer your information except as described in this Privacy Policy without obtaining your prior consent. This Privacy Policy is also incorporated specifically by reference in any terms of service, agreements or contracts you may enter into with WOWS. If you are using the Services on behalf of a business organization or other entity, or a client (such as a fund or holding company you may manage or advise, a trust, or a joint account), this Privacy Policy is nevertheless personal to you as an individual, and does not apply to that organization, entity, or client or any information relating to that organization, entity or client.

If at any time you do not agree with this Privacy Policy, please discontinue your use of the Site or Services.

This Privacy Policy supplements our Terms of Use and explains how WOWS handles information collected and received in the course of your use of our website and services. It also governs the collection, use and disclosure of your information. 

What information do we collect and receive?

We may collect and receive the following types of information, which may include Personal Information:

• Your name, address(es), email address(es) and phone number(s), gender, and profile photo.
• As applicable, your bank account information, money transfer instructions, age / date of birth, driver’s license number.
• Occupation, employment information, income information.
• Citizenship and residency information.
• Account and identity information with respect to funds transfer accounts.
• Financial information with respect to your investment objectives and means, including information about your wealth and financial situation, equity compensation and prior investments.
• Service usage and Transaction history (including among other things bids, asks, negotiations, failed, abandoned, rejected, and otherwise uncompleted Transactions), as well as records of your communications with WOWS and customer service requests. When you list, bid, ask, or otherwise indicate an interest in a Transaction, we provide information about your availability and offers, in anonymized form except as described below, unless you agree otherwise.
• Information requested or required by regulatory or governmental authorities or law enforcement bodies.
• In connection with certain engagements, we gather documents pertaining to your ownership of Stock if you are a shareholder, including any documents you choose to upload. The types of documents we ask for include employment, stock purchase, option, and vesting agreements you may have with the company that issued your Stock, as well as company-related documents that may be considered confidential. We also keep records of the Transactions and Transaction documents. We may also have, or seek, applicable documents from the issuer of the Stock, or from third party reporting services.
• Information about your affiliation with the issuers of Stock you may own or purchase, or with any organizations, securities professionals, entities, or clients on whose behalf you are using the Services.
• Behavioral and marketing information such as your interests, and your public social media presence.
• If you invite others to use WOWS, we may retain Personal Information related to your referral.
• We also automatically collect information from your computer, browser, phone, or other devices and software used to access the Services using cookies and other tracking technologies, and log this information in log files. This information includes among other things your device ID, ISP, IP address, user IDs and access tokens for third party sites such as AngelList, Facebook, and LinkedIn, information you have authorized a third party to share, and any information you have made public on those services. More information about how we use cookies and other tracking technologies is described below.

How do we collect your information?

We may collect information by asking you to enter information (including Personal Information) into forms, by observing your account activity and usage of the Services, by logging your access and activity on the Site, by your uploading of documents, and via third party information providers that, among other things, provide background checks to verify your identity, creditworthiness, and your eligibility and suitability to participate in Transactions. Third party information providers include, among others: credit reporting agencies, social media sites, our affiliated entities, fund administration partners, advertising platforms, data brokers and other data sources, and compliance service providers.

If you register or use the Services through a third-party site or application such as AngelList, Facebook, or LinkedIn, or link your WOWS account to those sites and applications, we may collect Personal Information from them. We may also collect Personal Information by direct communication with you and others by telephone, in person, and by online or electronic messaging means both on-Site and through off-Site services.

When you access the Site or Services, we and certain information providers may place cookies, pixel tags, web beacons, page tags, or other data-gathering and transmitting tools or files on your device. These help us recognize you as a user, customize and personalize the Services, study and improve our offerings, collect information about your device and software in order to improve Site performance or prevent fraud. Most Internet browsers and our consent management tool are able to disable or remove these cookies, and will contain instructions on how to do so, but doing so could affect your ability to use the Site and Services.

You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.

By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their information for the respective purposes.

Why do we collect the information?

We may use the information collected and received from you for the following purposes:

• Create a user account to use parts of our Services, and maintain your user profiles.
• Help you discover, bid for, agree to, close, and otherwise participate in Transactions, as well as buy, sell, and otherwise enter into and service the securities and contracts that are issued as part of the Transactions, including but not limited to, enrolling you as a client of our affiliated brokerage(s) in connection with a Transaction.
• Provide our Services and customize the content shown to you.
• Assure us, and parties to the Transactions, of the valid issuance, ownership, vesting status, transferability, and other attributes of securities issued by third party private companies (the “Stock”).
• Verify your identity, your status as a professional investor, an accredited investor or qualified purchaser (or other qualifications), if applicable, process diligence checks, and establish your eligibility and suitability for being a member of the WOWS community.
• If you are using the Services on behalf of an entity, organization, or client, to verify your affiliation and that you are authorized to do so.
• Setup and maintain accounts for sending and receiving funds and for depositing, holding and transferring securities.
• Facilitate your and our compliance with various laws, regulations, and industry oversight pertaining among other things to banking, financial information, securities transactions, money laundering, terrorism, and “know your customer” rules promulgated by, among others, applicable government and regulatory bodies.
• Communicate with you.
• Provide you with information about, and solicit your further participation in, the Services (which may include research and development purposes and direct marketing activities and/or the transfer of your Personal Information to third parties for their direct marketing purposes).
• Study, test, and improve the Services, and the overall user experience using the Services.
• Detect, prevent and address technical issues with the Services.
• Offer customer support, technical support, maintenance, and product development.
• Protect against fraud, Site misuse, privacy and security breaches, securities and other legal and regulatory violations, and to fulfill and enforce agreements reached with you and others.

Who do we share your information with?

WOWS does not sell or share any information of any kind with any third party without your explicit consent, nor does WOWS use any information for advertisements unrelated to the marketing and promotion of WOWS’ Services. Except as noted in this Policy, we do not sell, trade, or otherwise transfer to outside parties your personally identifiable information without your consent. Additionally, WOWS does not use any personally identifiable information for advertisements unrelated to the marketing and promotion of the Services.

We may share your information (including but not limited to, information from cookies, log files, device identifiers, and usage data) with businesses that are legally part of the same group of companies that WOWS is part of, or that become part of that group ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Services (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences).

We also may share your information with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms. For example, these providers may help us administer our Website and Applications, manage and administer Services, or process credit card payments. Where required by law, these companies agree to only use such information for the purposes for which they have been engaged by us unless you expressly permit them to use your information for other purposes.

We may remove parts of data that can identify you and share anonymised data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

We may collect and release Personally Identifiable Information and/or non-personally-identifiable information only if required to do so by law, or in the good-faith belief that such action is necessary to comply with applicable laws and regulations in or outside Singapore, international law or respond to a court order, subpoena, or search warrant or equivalent, or where in our reasonable belief, an individual's physical safety may be at risk or threatened.

Transfer of information

By using our Services, you authorize us to use your information in Singapore, and other countries where WOWS operates for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act, 2012 of Singapore).

Protecting your information

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of information under our control.  We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. Sensitive information (such as credit card numbers) are encrypted using secure socket layer technology (SSL). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

It is important that you protect against unauthorized access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

Accessing and updating your information

As a user of WOWS’ services in accordance with the Terms and other guidelines provided by WOWS, you may access, review, update or correct your account information at any time by logging in to your account. You are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide, the consent to which has been obtained by you, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

The information collected by us shall not be retained for longer than is required after the deactivation of the account except to comply with legal obligations, resolve disputes or enforce agreements.

If you wish to: (a) apply for a copy of the information we hold about you; or (b) withdraw consent you previously provided to us to use, collect or disclose the information we hold about you, you may contact our Personal Data Protection Officer at the contact details set out in this policy. Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such a fee beforehand.

Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so. 

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email. You are responsible for reviewing the changes we make to this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

Third party sites and resources

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

Contact us

If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us by sending an email to contact@wowsglobal.com with a brief subject header that indicates the nature of request.