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Privacy Policy

Willmart Facilitator Limited: Terms of Use

 

Last updated: July 30, 2025

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Introduction

 

Willmart Facilitator Limited (“WFL”, “we”, “our” or “us”) cares about privacy and the protection of your personal data. This Privacy Policy (the “Policy”) explains the general principles of how WFL, its licensors, and affiliates collect and process information when you visit our website at [insert WFL’s website address] (“Website”), use any of our services (“Services”), or interact with us in other ways (for example, via social media).

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By communicating with us through the Website or Services, you (“you”, “your”, “client”, “client representatives”, “data subject”) agree to the terms of this Policy.

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“Personal Data” means any information that can be used to directly or indirectly uniquely identify, contact, or locate you. We process Personal Data under this Policy and in accordance with applicable legislation, including the Personal Information Protection and Electronic Documents Act (PIPEDA), Personal Information Protection Act (PIPA), and, if applicable, the General Data Protection Regulation (GDPR) (2016/679) (together, “Data Protection Law”).

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Scope of the Policy

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This Policy describes how we process Personal Data in connection with:

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  • Information you provide via forms on the Website.

  • Your use of the Website, including cookies and browsing data.

  • Information collected to establish, perform, and manage agreements with you or your organisation.

  • Our statutory obligations under Data Protection Law and other applicable regulations.

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Principles of Personal Data Processing

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We adhere to the principles of personal data protection under Data Protection Law. Accordingly, Personal Data shall be:

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  1. Processed fairly, lawfully, and transparently.

  2. Collected for specified, explicit, and legitimate purposes only.

  3. Adequate, relevant, and limited to what is necessary.

  4. Kept accurate and up to date.

  5. Retained no longer than necessary.

  6. Processed securely and with appropriate safeguards.

 

Legal Basis for Processing

 

We process Personal Data based on:

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  • Your consent.

  • A contractual relationship between us.

  • Legal obligations.

  • Our legitimate interests (where they do not override your rights).

 

If processing is based on consent, you may withdraw consent at any time. However, this may limit the services we can provide.

 

Personal Data Processing

 

We may process the following categories of Personal Data:

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  • Consent-based data – where you opt-in to our Policy or provide consent electronically or in writing.

  • Business relationship data – name, surname, phone, email, identification documents, IP address, beneficiary/shareholder data, source of funds, payment details, and other information required for compliance and service provision.

  • Marketing data – name, surname, email, phone, provided with your consent.

  • Legal obligations – data required by law, e.g. anti-money laundering (AML), taxation, or reporting requirements.

  • Legitimate interests – data used for fraud prevention, legal claims, or improving services.

  • Cookies and technical data – IP address, browser, device, visit information, clickstream data, etc.

  • Automated decision-making and profiling – used for risk assessment, service improvement, or fraud prevention, but not as the sole basis for decisions with significant impact.

  • Special category data – not generally collected, but may be processed if legally required.

  • Children’s data – WFL does not knowingly provide services to, or collect data from, individuals under 18.

 

Your Rights

 

You have the following rights under Data Protection Law:

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  • Access – to know what data we process about you.

  • Rectification – to request corrections.

  • Objection – to certain processing, including marketing.

  • Erasure – to request deletion of data, subject to legal exceptions.

  • Data portability – to receive your data in machine-readable format and transfer it elsewhere.

  • Withdrawal of consent – to revoke previously given consent.

  • Marketing opt-out – to unsubscribe from communications at any time.

 

For concerns about your rights, contact us at msb@willmartfacilitator.com. You may also lodge a complaint with the Office of the Privacy Commissioner of Canada: https://www.priv.gc.ca/en/ or your local Data Protection Authority.

 

Recipients of Personal Data

 

We may share your data with:

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  • WFL group companies and affiliates.

  • Partners and third-party providers (e.g. KYC/KYB services, payment processors, IT providers).

  • Financial institutions, payment schemes, and regulators.

  • Law enforcement or courts, if legally required.

  • Other parties with your authorisation.

 

Security Measures

 

We take reasonable administrative, technical, and organisational measures to protect Personal Data from loss, misuse, unauthorised access, disclosure, alteration, or destruction.

 

Access to Personal Data is restricted to authorised staff who require it for their duties, in compliance with Data Protection Law.

 

Data Retention

 

We retain Personal Data only as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law.

 

Changes to this Policy

 

We may amend this Policy from time to time. Any changes will be published on the Website, and where appropriate, notified to you. Continued use of our Services after amendments are published will constitute acceptance of the updated Policy.

 

Contact Us

 

If you have any questions about this Privacy Policy, please contact us at:

 

Willmart Facilitator Limited
Incorporation number: BC1466235
Business Number: 757598156 BC0001

Registered Office (Mailing & Delivery Address):
C/O INCORP PRO
170-422 Richards Street
Vancouver, BC V6B 2Z4
Canada

 

E-mail: msb@willmartfacilitator.com

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