Data Processing
1. Our Commitment to Privacy
At W Payments, we recognize that privacy, confidentiality, and information security are essential to establishing relationships of trust with our users, content creators, studios, agencies, business partners, and other participants in the digital economy.
This Privacy and Personal Data Processing Policy establishes the principles, procedures, and conditions applicable to the collection, use, storage, transmission, transfer, retention, and disposal of personal information within the framework of the services offered by W Payments.
W Payments is a technology platform operated by TWC International LLC, a company organized under the laws of the State of Wyoming, United States of America.
Our commitment is to process information lawfully, transparently, securely, and proportionally to the legitimate purposes of our services, respecting the rights of data subjects and applicable legal obligations.
2. Regulatory Framework
The processing of personal data will be carried out in accordance with the applicable legislation in the jurisdictions where our activities take place.
In Colombia, where applicable, the provisions of Statutory Law 1581 of 2012, Decree 1074 of 2015, regulatory standards, and instructions from competent authorities will be observed.
Likewise, other provisions regarding data protection, privacy, information security, and cross-border processing may apply, depending on the data subject's residence, the nature of the services, and the jurisdictions involved.
The incorporation of TWC International LLC in the United States does not preclude the application of mandatory data protection regulations in other jurisdictions.
3. Definitions
For the purposes of this Policy:
Data Subject: Natural person whose personal data is processed.
User: Natural or legal person who uses W Payments services.
Creator: Natural person who carries out legitimate commercial activities through digital platforms, content, entertainment, streaming, subscriptions, or other monetization methods.
Studio or Agency: Legal entity or commercial establishment that maintains contractual relationships with creators and may use W Payments services to manage authorized activities and instructions.
Beneficiary: Natural person whose data is processed to verify, coordinate, or document payment operations.
Data Controller: Natural or legal person who determines the purposes and essential means of the processing of personal data.
Data Processor: Natural or legal person who processes personal data on behalf of a Controller, in accordance with their instructions and applicable obligations.
Third-Party Allies: Financial, technological, verification, fraud prevention, infrastructure, and complementary service providers that legitimately participate in the provision of the services.
Sensitive Data: Information whose improper use may affect the data subject's privacy or generate discrimination, including biometric data under the terms of applicable legislation.
4. Identification of the Data Controller and Distribution of Responsibilities
TWC International LLC, as the operator of W Payments, will act as the Data Controller with respect to personal data for which it directly determines the essential purposes and means.
This may include information used for:
Account creation and management.
User identification and authentication.
Identity verification and biometric checks.
Fraud prevention and risk management.
Compliance with legal and contractual obligations.
Customer support.
Management of business relationships.
Security and operation of the Platform.
When W Payments processes information exclusively on behalf of studios, agencies, or other business clients that determine the essential purposes and means of processing, it may act as a Data Processor, in accordance with the corresponding instructions and agreements.
Third-Party Partners may act as independent controllers or processors, depending on their functions and the processing actually carried out.
Responsibilities will be determined according to the nature of each activity and not exclusively by the contractual designation used.
5. Categories of Information Processed
W Payments may collect and process the following categories of information when necessary for the provision of its services:
Identification information: First names, last names, identity documents, date of birth, nationality, contact details, and address.
Corporate information: Business registries, tax information, legal representatives, corporate structures, and ultimate beneficial owners.
Economic activity information: Profession, monetization method, platforms used, commercial contracts, relationships with studios or agencies, and income-related documentation.
Financial and transactional information: Destination account details, payment receipts, monetization reports, settlement records, withdrawal instructions, beneficiaries, and transactions associated with the services.
Biometric information: Facial images, liveness checks, and other elements necessary for identity verification procedures, when its processing is duly authorized or supported by an applicable legal basis.
Technological information: IP addresses, device identifiers, access logs, session data, security events, and other metadata necessary for the protection and operation of the Platform.
Communications information: Inquiries, support requests, claims, and communications related to the services.
W Payments will endeavor to limit the collection of information to that which is adequate, relevant, and necessary for the corresponding purposes.
6. Purposes of the Processing
Personal data may be processed to:
a. Create, verify, and manage accounts.
b. Provide the contracted technological services.
c. Coordinate payment, withdrawal, settlement, and transfer instructions.
d. Verify the identity of users and beneficiaries.
e. Prevent fraud, impersonation, and unauthorized access.
f. Perform Know Your Customer and Know Your Business (KYC/KYB) procedures.
g. Verify the origin of funds and the legitimacy of transactions.
h. Conduct transactional monitoring and risk management.
i. Comply with legal, regulatory, and contractual obligations.
j. Address requests, claims, and inquiries.
k. Manage billing, fees, and commercial relationships.
l. Maintain the security, stability, and continuity of the services.
m. Conduct internal operational analyses and improve the Platform using adequate and, whenever possible, aggregated or anonymized data.
n. Send commercial communications, updates, or informational content when there is valid authorization or another applicable legal basis.
The data will not be used for purposes incompatible with those disclosed to the data subject without the corresponding legal basis.
7. Consent and Legal Bases for Processing
W Payments will obtain the required authorizations for processing personal data in accordance with applicable legislation.
Authorization may be obtained through electronic forms, acceptance mechanisms, registration procedures, or other means that allow for the preservation of verifiable evidence.
When legislation permits processing without prior authorization under specific circumstances, W Payments may act in accordance with legally provided exceptions.
General acceptance of the Terms and Conditions shall not replace specific authorizations that are legally required, especially regarding sensitive data or independent commercial purposes.
The data subject may exercise their rights of revocation and deletion when legally applicable, without prejudice to legitimate retention obligations.
8. Processing of Biometric Data
W Payments may use facial recognition technologies, biometric verification, and liveness detection tests to confirm user identity, prevent impersonation, and protect transactions.
We recognize that biometric data may constitute sensitive information and requires heightened protection measures.
Where applicable, the data subject will be informed of:
The specific purposes of the verification.
The sensitive nature of the information.
Their right to not authorize processing when established by law.
The operational consequences of not completing a required verification.
The vendors involved in the procedure, as applicable.
Where feasible and appropriate, alternative verification mechanisms may be evaluated.
Refusal to authorize biometric processing may limit access to features that legitimately require such verification, in accordance with applicable technical, contractual, and legal conditions.
Biometric data will be subject to heightened access, security, and retention controls.
9. Creator, Studio, and Agency Information
W Payments recognizes that information regarding income, monetization platforms, representation agreements, beneficiaries, and business relationships may be confidential.
Its processing will be limited to the purposes necessary for the provision of services, transaction verification, and compliance with applicable obligations.
When studios or agencies provide information regarding creators or beneficiaries, they must have the corresponding authorizations or legal grounds and fulfill the responsibilities that are legally attributable to them.
W Payments may conduct independent verifications when it directly determines purposes related to security, identification, fraud prevention, or compliance.
Information relating to creators' professional activity will not be used for purposes other than those authorized or legitimately applicable.
10. Protection of Financial and Commercial Information
Financial documents, monetization reports, contracts, income records, payment receipts, and other commercial information provided by users will be handled under the criteria of confidentiality, necessity, and proportionality.
Requests for additional information must be related to a legitimate purpose, the identified risk, and applicable obligations.
The submission of full bank statements does not constitute a general requirement for onboarding or continuing with W Payments.
Where appropriate, transaction receipts, certifications, partial statements, platform reports, or equivalent documents may be used to verify the required information.
The disclosure of financial documentation to third parties will be limited to the data necessary for the corresponding purpose, in accordance with the applicable legal or contractual basis.
11. Sharing Information with Third-Party Partners
W Payments may share information with financial, technological, identity verification, fraud prevention, infrastructure, and other Third-Party Allied providers when necessary to provide the services or fulfill legitimate obligations.
Sharing will be subject to the following criteria:
Specific purpose.
Necessity and relevance.
Proportionality.
Data minimization.
Security and confidentiality.
Compliance with legal and contractual obligations.
Where applicable, W Payments will establish data processing agreements and contractual measures designed to protect the shared information.
Third-Party Allies acting as independent data controllers will be subject to their own data protection obligations.
Through this Policy, W Payments does not authorize a general and unlimited disclosure of personal or financial information.
12. International Transfers and Transmissions
Due to the international nature of the services, W Payments may transfer or transmit personal data to providers located in other jurisdictions.
These operations may be necessary for technological infrastructure services, identity verification, fraud prevention, payment coordination, support, and compliance.
Transfers and transmissions will be carried out in accordance with the requirements established by applicable law, including the corresponding authorizations, exceptions, contracts, and other guarantees.
When data processors are used, efforts will be made to establish appropriate obligations regarding confidentiality, security, limited use, and protection of data subjects' rights.
International transfers do not constitute an irrevocable or unlimited authorization to use information for purposes other than those legitimately established.
13. Information Security
W Payments will implement reasonable technical, administrative, and organizational measures to protect personal data against loss, unauthorized access, alteration, disclosure, or improper processing.
These measures may include access controls, authentication, encryption, activity logs, incident management, permission restrictions, and vendor evaluations.
Access to personal information will be limited to personnel, contractors, and vendors who need to know it to perform authorized functions.
Security incidents will be evaluated and managed in accordance with internal procedures and applicable legal notification obligations.
14. Retention and Disposal of Information
W Payments will retain personal data for the time necessary to fulfill the legitimate purposes of the processing and applicable legal or contractual obligations.
Retention periods may vary depending on the nature of the information, the business relationship, security requirements, and the corresponding obligations.
When the purpose justifying the processing ends and there is no valid retention obligation, the data will be deleted, anonymized, or subjected to appropriate secure disposal procedures.
Information subject to retention obligations may be maintained with restricted access and usage limitations.
The existence of an investigation, claim, or dispute may justify additional retention when there is sufficient legal basis.
A uniform retention period will not apply to all categories of information when their legal and operational requirements differ.
15. Rights of Data Subjects
Data subjects may exercise the rights recognized by applicable legislation, including:
Know, access, update, and rectify their personal data.
Request information regarding the processing carried out.
Request proof of the authorization granted, where applicable.
Submit inquiries and complaints.
Revoke authorizations when legally appropriate.
Request the deletion of information when there is no legitimate obligation to retain it.
File complaints with the competent authorities, in accordance with applicable legal requirements.
Refuse the processing of sensitive data under the terms established by law.
The exercise of these rights will not be conditioned upon the payment of fees other than those expressly permitted by applicable legislation.
16. Procedure for Inquiries and Complaints
Data subjects may submit inquiries and claims regarding their personal data through the official channels established by W Payments.
Inquiries will be handled within ten (10) business days following their receipt, with the possibility of an extension of up to five (5) additional business days when applicable under Colombian law.
Claims will be handled within fifteen (15) business days starting the day after their complete receipt, with the possibility of an extension of up to eight (8) additional business days in cases legally permitted.
When a request concerns information for which W Payments acts solely as a Data Processor, its response will be coordinated with the corresponding Data Controller.
Requests will be managed while seeking to verify the applicant's identity and protect third-party information.
17. Cookies and Tracking Technologies
W Payments may use cookies and similar technologies to facilitate website operation, maintain sessions, protect accounts, analyze performance, and improve the browsing experience.
When non-essential technologies that require authorization are used, the corresponding information and consent mechanisms will be implemented.
Users may manage their preferences through the tools available on the website or in their browsers.
The purposes, categories, and providers of tracking technologies must correspond to the tools actually implemented.
18. Commercial Communications
W Payments may send communications related to services, security, operational updates, and contractual obligations when necessary for the business relationship.
Promotional communications, newsletters, and marketing content will be sent in accordance with applicable authorizations and legal grounds.
Recipients may request to unsubscribe from commercial communications through the mechanisms provided.
Unsubscribing from promotional communications will not prevent the sending of essential notifications related to security, operations, or contracted services.
19. Business User Responsibilities
Studios, agencies, and other business users that provide personal information of third parties must ensure that they have the necessary authorizations or legal grounds for its processing.
Likewise, they must adequately inform data subjects and comply with the obligations that correspond to them as data controllers or data processors, depending on the nature of each relationship.
W Payments and its business users shall assume the responsibilities that legally and contractually correspond to their respective actions.
The existence of a commercial relationship does not imply an automatic or unlimited transfer of data protection responsibilities.
20. Identification and Contact Information
Data Controller: TWC International LLC
Commercial brand: W Payments
Jurisdiction of incorporation: Wyoming, United States of America
Website: https://wpayments.co
Email for privacy and legal notices: legal@twcinternational.llc
General support email: info@wpayments.co
Address for notices: legal@twcinternational.llc
Requests related to the processing of personal data may be sent to the indicated channels, identifying the data subject, the nature of the request, and the information necessary for its resolution.
21. Validity and Updates
This Policy will take effect upon its publication on the official channels of W Payments.
It may be updated to reflect legal, technological, operational, or commercial changes.
Significant modifications will be communicated through the appropriate mechanisms and, where applicable, new authorizations will be requested.
The current version will be available for public consultation on the official website.