Privacy Policy

1. General:

  • This Privacy Policy, together with our Terms of Use, governs Walahala collection, processing and use of your Personal Data. As used in this Privacy Policy, “Walahala”, “we”, “us” or “our” refers to Walahala.O.Ü., a Payment Institution, registered with the Estonian Financial Intelligence Unit (FIU) Estonia (E.U) Register under the number 14648236, Holding Activity license FVR000670 Financial services providing services of exchange virtual currency against Fiat currency and Activity License FRK000577.Financial services providing virtual currency wallet service with its registered address at Harju maakond, Tallinn, Lasnamäe linnaosa, Peterburi tee 47, 11415 Estonia , are data controllers under this Privacy Policy, which sets out the manner in which all the companies, as data controllers, may use your Personal Data.
  • “DP Law” means data protection law as applicable to Walahala, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts. “Personal Data” has the meaning set forth in DP Law. This notice covers our use of your Personal Data arising from use of the Walahala website ( as well as registering, subscribing, buying and using our products and Services.If you have any questions or need any further clarification please get in touch. Contact details are set out below in the Contact Us section.
  • Capitalized items in this Privacy Policy have the meaning set out in the Definitions section below.
  • Walahala is committed to protecting and respecting your privacy. The purpose of this Privacy Policy is to describe:
    • The types of Personal Data we collect and how it may be used;
    • Our use of cookies and similar technology;
    • How and why we may disclose your Personal Data to third parties;
    • The transfer of your Personal Data within and outside of the European Economic Area (“EEA”);
    • Your statutory rights concerning your Personal Data;
    • The security measures we use to protect and prevent the loss, misuse, or alteration of Personal Data; and
    • Walahala’s retention of your Personal Data.

2. Collection and use of personal information:

We collect the Personal Data which you provide directly to us or which we generate when you open a Walahala Account, perform any transactions on the Walahala Platform, or use other Walahala Services or our website.

2.1. Information in general
This may include:

  • contact information, such as name, home address and e-mail address;
  • account information, such as username, password, account settings and preferences;
  • financial information, such as bank account numbers, bank statement, and trading information;
  • identity verification information, such as images of your government-issued ID, passport, national ID card, or driving licence.
    Note: US residents may be asked to provide their social security numbers;
  • residence verification information, such as utility bill details or similar information;
  • information regarding the way in which you use our Services, such as when you used our Services and the specific Services used; and
  • information relating to communications with us, whether through the Walahala website or via e-mail, over the phone or via any other medium. .

2.2. Information for Corporate Clients
  • Full legal name,
  • Legal form,
  • Company number,
  • Registered office address,
  • Place of business,
  • E-mail address,
  • Phone number,
  • Website,
  • IP address,
  • UBO`s (ultimate beneficial owners) all the information about natural person as given above,
  • Officers,
  • Business activity,
  • Articles of Association or another governing document
  • Source of funds,
  • Purpose of account,
  • Data on the nature of income,
  • Information about representative of the Company (all information about natural person given above).

2.3. Supervision

Chief compliance officer is the person in charge of ensuring our company adheres to this privacy notice. This person is also the main contact for our Data Protection Supervisory Authority, the European Data Protection Supervisor

2.4. User Data Collection

The main way how we get that kind of personal data is when you provide it to us such as when you sign up for a Walahala account also when you communicate with us by email, we collect the communication and any data provided in it. Moreover, when we obtain information from third parties such as identity verification services, credit reference agencies, and regulatory and enforcement agencies. When you use the Walahala platform we collect information on your transactions and other use of your Walahala account.

We also automatically collect certain computer, device and browsing information when you access the Walahala website or use Walahala Services. This information is aggregated to provide statistical data about our users' browsing actions and patterns, and does not personally identify individuals.
This information may include:

  • Computer or mobile device information, including IP address, operating system, network system, browser type and settings.
  • Website usage information.

Finally, we may collect Personal Data from third-party partners and public sources, which include:

  • Reputational information;
  • Financial information;
  • Business activities of corporate customers.

We need to collect certain types of information for compliance with legal requirements relating to our anti-fraud/anti-money-laundering/counter-financing-of-terrorism/know-your-customer obligations. If this information is not provided, we may not be able to provide a Service for you. Your Personal Data may also be processed if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency or in the defense of a legal claim. We will not delete Personal Data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

2.5. Retention of User Data

It is important to note that the Personal Data we collect on you when you create an Account will be retained for the mandatory retention period set forth by applicable law as it is necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated financial sector professionals, even if your Account has not been successfully activated (e.g. if Account verification has not been completed) or no transaction has been made using it.

2.6. Data Usage

We will process your Personal Information only for the purpose(s) of providing to you the service(s) that you ask us to provide and to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s).
This may include usage for the purpose of:

  • allowing you to open and operate an Account on the Platform;
  • processing transactions on the Platform;
  • replying to your e-mails or contact you about Walahala services;
  • analysing use of our Site;
  • verification of your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including as required for compliance with the Walahala Anti Money Laundering notice, as well as address other law enforcement needs as more fully described in our Terms of Use, and generally as required for compliance with legislation and regulations applicable to Walahala;
  • understanding the nature of business and management structure of the Company, obtain the preliminary monthly transaction volumes for the Customer – body corporate;
  • verification of your identity to protect against fraud, comply with financial crime laws, and to confirm your eligibility to use our products and services;
  • using your personal data and cookies (read below to know more about cookies) to send you information related to our marketing communications, dedicated personally to you considering your data.

2.7. Usage of Cookies and Similar Technology

The Walahala website uses cookies. Cookies are small text files that are placed on your computer by websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site.
Cookies are typically stored on your computer’s hard drive. Information collected from cookies is used by us to evaluate the effectiveness of our Site, analyze trends and administer the Platform. The information collected from cookies allows us to determine such things as which parts of our website are most visited and what difficulties our visitors may experience in accessing our website. With this knowledge, we can improve the quality of your experience on the Platform by recognizing and delivering more of the most desired features and information, as well as by resolving access difficulties. We also use cookies and/or a technology known as web bugs or clear gifs, which are typically stored in emails to help us confirm your receipt of, and response to, our emails and to provide you with a more personalized experience when using our Site.

2.8. Third Party Usage

We use one or more third party Service provider(s), to assist us in better understanding the use of our Site. Our Service provider(s) will place cookies on the hard drive of your computer and will receive information that we select that will educate us on such things as how visitors navigate around our Site, what products are browsed, and general Transaction information. Our Service provider(s) will analyse this information and provide us with aggregate reports. The information and analysis provided by our Service provider(s) will be used to assist us in better understanding our visitors' interests in our Site and how to better serve those interests. The information collected by our service provider(s) may be linked to and combined with information that we collect about you while you are using the Platform. Our Service provider(s) is/are contractually restricted from using the information they receive from our Site for any other purpose than to assist us.
If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features of our website or Services, such as logging in to your Walahala Account or making Transactions. Your use of our website or Service with a browser that is configured to accept cookies constitutes an acceptance of our and third-party cookies.

2.9. Further Data Usage

We collect and use your information for a variety of reasons. We need some information to enter into and perform our contract – for example, your contact and payment details. Some information processing is required by law due to our anti-fraud screening obligations, or is in the public interest, such as making sure we verify our customers’ identities.
Some information is processed because you have given your consent to that, which can be withdrawn in your Account preferences and settings. Other information we collect and use because we have legitimate business interests to do so, having taken into account your rights, interests and freedoms.
We may use your Personal Information to:

  • create and administer your Walahala Account and generally for accounting, billing, maintenance of legal documentation and claim and dispute management. Related processing operations are necessary for the performance of a contract with you (or to take steps at your request prior to entering into a contract) and for compliance with legal obligations to which we are subject;
  • process your Walahala transactions. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject.
  • verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including those required for compliance with the Walahala Anti-Money Laundering Policy, as well as address other law enforcement needs as described in our Terms of Use and generally as required for compliance with legislation and regulations applicable to Walahala. With respect to US residents, we also may share your information with other financial institutions as authorized under Section 314(b) of the US Patriot Act, and with tax authorities, including the US Internal Revenue Service, pursuant to the Foreign Account Tax Compliance Act (“FATCA”), to the extent that this statute may be determined to apply to Walahala. Related processing operations are necessary for the performance of a contract with you and for compliance with legal obligations to which we are subject;
  • personalize your Walahala Services experience. Related processing operations are necessary for purposes of our legitimate interests (that is, improving our Services);
  • Walahala website usage, and improve our website and website offerings. Related processing operations are necessary for purposes of our legitimate interests (that is, improving and promoting our Services);
  • help us respond to your customer Service requests and support needs. Related processing operations are necessary for the performance of a contract with you, and for purposes of our legitimate interests (that is, improving our services and offering you the best experience);
  • contact you about Walahala Services. The email address you provide may be used to communicate information and updates related to your use of Walahala Services.


We may make automated decisions on certain matters. For example, we may do this to decide whether we can provide our Services to you based on a credit check/risk profiling. Depending on the outcome of the credit check/risk profiling, a decision is reached automatically as to whether we are able to provide products or Services to you based on your credit worthiness.
If you disagree with the decision you are entitled to contest this by contacting us at the following email address: [email protected]


We may also occasionally communicate company news, updates, promotions and information relating to similar products and Services provided by Walahala. We may also administer a contest, promotion, survey or another site feature as is further explained on the website. We shall only do this where you have given us your consent or otherwise where we are permitted to do so under DP Law in pursuit of our legitimate interests (that is, promoting our Services).
We may share Personal Data with third parties to help us with our marketing and promotional projects, or sending marketing communications.
If you want to opt out of receiving promotional and marketing emails, text messages, posts and other forms of communication from us (or our promotional partners), which you might receive in accordance with this section, you can choose one of the following ways:

  • Log into your Account and update your profile;
  • Click “unsubscribe” at the bottom of an email we sent you; or
  • Contact us at [email protected] and request to opt out.

If you do opt out of receiving promotional and marketing messages, we can still contact you regarding our business relationship with you, such as Account status and activity updates, survey requests in respect of products and Services we have provided to you after you have opted out, reservation confirmations or respond to your inquiries or complaints, and similar communications.


We may disclose your Personal Data to third parties and legal and regulatory authorities and transfer your Personal Data outside the EEA, as described below.

5.1. Disclosure to Third Parties

There are certain circumstances where we may transfer your Personal Data to employees, contractors and to other parties.
We may share information about you with other members of our group of companies so we can provide the best Service across our group. They are bound to keep your information in accordance with this Privacy Policy.
We may also share your information with certain contractors or Service providers. They may process your Personal Data for us, for example, if we use a marketing agency. Other recipient’s/Service providers include advertising agencies, IT specialists, database providers, backup and disaster recovery specialists, email providers or outsourced call centres. Our suppliers and Service providers are required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in relation to the performance of their function.
We may also share your information with certain other third parties. We will do this either when we receive your consent or because we need them to see your information to provide products or Services to you. These include credit reference agencies, anti-fraud databases, screening agencies and other partners we do business with.
Your Personal Data may be transferred to other third-party organizations in certain scenarios:

  • if selling or transferring a part or all of our business – the information may be transferred to prospective purchasers under suitable confidentiality terms;
  • if our business is reorganized or sold, information may be transferred to a buyer who can continue to provide Services to you;
  • if required by law, or under any regulatory code or practice we follow or if we are asked by any public or regulatory authority – for example law enforcement and other related departments;
  • if defending a legal claim, your information may be transferred as required in relation to defending such claim.

Your Personal Data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be Personal Data.
Your information will not be sold, exchanged or shared with any third parties without your consent, except to provide Walahala Services or as required by law.
Walahala’s third party Service providers are contractually bound to protect and use such information only for the purposes for which it was disclosed, except as otherwise required or permitted by law. We ensure that such third parties will be bound by terms complying with DP Law.

5.2. Disclosure to Legal Authorities

We may share your Personal Data with law enforcement, data protection authorities, government officials and other authorities when:

  • Compelled by court order or other legal procedure.
  • Disclosure is necessary to report suspected illegal activity or
  • Disclosure is necessary to investigate violations of this Privacy Policy or our Terms and conditions

5.3. International Transfer of Personal Data

We primarily store and process your Personal Data in data centers in the European Union, and, for other users, around the world, where Walahala facilities or Service providers are located. As such, we may transfer your Personal Data outside of the European Union. Some of the countries to which your Personal Data may be transferred to for these purposes that are located outside the EU do not benefit from the adequacy decision issued by the EU Commission regarding protection afforded to Personal Data in that country. Such transfers are undertaken in accordance with our legal and regulatory obligations, and appropriate safeguards under DP Law will be implemented, such as standard data protection clauses, with data recipients or processors approved by competent authorities. A copy may be requested at the address set out in the Contact Us section.


You have certain rights concerning your Personal Data under DP Law, as mentioned below and can exercise them by contacting us at [email protected]

Access: you are entitled to ask us if we are processing your information and, if we are, you can request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold on you and certain other information about it to check that we are processing it lawfully. We process a large quantity of information and can thus request, in accordance with DP Law, that before the information is delivered, you specify the information or processing activities to which your request relates.

Correction: you are entitled to request that any incomplete or inaccurate Personal Data we hold about you is corrected.

Erasure: you are entitled to ask us to delete or remove Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure; for example, where the Personal Data is required for compliance with law or in connection with claims.

Restriction: you are entitled to ask us to suspend the processing of certain parts of your Personal Data; for example, if you want us to establish its accuracy or disclose the reason for processing it.

Transfer: you may request the transfer of a certain part of your Personal Data to another party.

Objection: where we are processing your Personal Data based on a legitimate interest (or that of a third party) you may challenge this. However, we may be entitled to continue processing your information based on our legitimate interests or where this is relevant to legal claims. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Automated decisions: you may contest any automated decision made about you where this has a legally or similarly significant effect and ask for it to be reconsidered.

You also have a right to lodge a complaint with a supervisory authority, in particular in the Member State of the European Union where you are habitually resident, where we are based or where an alleged infringement of Data Protection Law has taken place.


We use a variety of security measures to ensure the confidentiality of your Personal Data and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction. These security measures include, but are not limited to:

  • password protected directories and databases;
  • Secure Sockets Layered (SSL) technology to ensure that your information is fully encrypted and sent across the Internet securely; and
  • PCI Scanning to actively protect our servers from hackers and other vulnerabilities.

All financially sensitive and/or credit information is transmitted via SSL technology and encrypted in our database. Only authorized Walahala personnel are permitted access to your Personal Data and these personnel are required to treat the information as highly confidential. The security measures will be reviewed regularly in light of new and relevant legal and technical developments.

We do not ask for financial or payment information, such as your credit card number, passcode, account number or pin number, in an e-mail, text or any other form communication that we use to contact you. Please always check that any website on which you are asked for financial or payment information in relation to our reservations or Services is operated by Walahala. If you do receive a suspicious request, do not provide your information and report it by contacting one of our member Service representatives as set in this Privacy Policy.

You are responsible for keeping your Account passcode, membership numbers and pin numbers safe and secure. Do not share those with anyone. If there is an unauthorized use or any other breach of security involving your information, you must notify us as soon as possible (see Contact Us or at [email protected]).


We retain Personal Data for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations.
The criteria we may use to determine the retention period for certain categories of data include:

  • Walahala membership period;
  • contractual or legal obligations that exist that require us to retain the data for a certain period of time;
  • eventual ongoing legal or financial claim that relates to your relationship with us;
  • applicable law, statute, or regulation allows a specific retention period; and
  • expectation for retention at the time the data was provided to us.

In accordance with our record-keeping obligations, we will retain Account and other Personal Data for at least five years (in some cases up to ten years, as required by applicable law) after an Account is closed.


This Privacy Policy was last revised effective April 6th, 2020. We may change this Privacy Policy from time to time, so it is advisable to review it frequently. Changes to this Privacy Policy will be announced on our website or through similar means for a reasonable length of time prior to and following the change taking effect.


For all personal and enterprise user accounts, we collect transaction information including deposit snapshots, account balances, trade history, withdrawals, and order activity and distribution history. This transaction data is monitored for suspicious trading activity for user fraud protection, and legal case resolution.

Account: The contractual arrangement wherein a Walahala member has accepted our Terms and conditions and Privacy Policy, and received approval to use the Walahala Services, including the purchase of Walahala Wallet and sale of Virtual Assets, to perform associated Transactions.

Walahala Platform: Hardware and software technologies used by Walahala to provide the Walahala Service as set out in our Terms and conditions.

DP Law: Stands for Data Protection Law applicable to Walahala, including the EU General Data Protection Regulation 2016/679, its successors or implementing texts as well as equivalent legislation, which is applies to the processing of Personal Data by Walahala;

Personal Data: Information that identifies an individual, such as name, address, e-mail address, trading information and banking details. Personal Data does not include anonymized and/or aggregated data that does not identify a specific user.

Service(s): The technological platform, functional rules and market managed by Walahala to permit Sellers and Buyers to perform purchase and sale transactions of Bitcoins.

Transaction: Includes agreement between Buyers and the Sellers to exchange digital assets through the Service for currencies at a mutually agreed rate, conversion of currencies into digital assets deposited by members on their Accounts, transfer of digital assets among members, transfer of currencies among members and purchase of ancillary products.

Contact Us:

Please contact us with questions, comments or concerns regarding our Privacy Policy and/or practices at [email protected]