This privacy policy sets out the basis on which we will process any Personal Data that we may collect about you as a visitor to our website. This policy further sets out how we protect your privacy and your rights in respect of our use of your Personal Data.

WHO IS THE DATA CONTROLLER?
A “data controller” is a person or organization who alone or jointly determines the purposes for which and the manner in which any personal data is, or is likely to be, processed. In this sense, WAGMI Solutions, Inc. of 112 GF Ricogen Building, Aguirre St., Legazpi Village, Makati City 1229, Philippines (“WAGMI Solutions”, “we”, “us”, or “our”) is the data controller. If you have any questions about this policy or about data protection at WAGMI Solutions in general, please contact us via email using ginalyn@wagmisolutions.io with “Data Protection” in the subject line.

WHAT IS PERSONAL DATA?
Personal Data is information that makes it possible to identify a natural person. This includes, in particular, your name, date of birth, address, telephone number, e-mail address, but also your IP address. Anonymous data exists if no personal reference to the user can be made.

WHAT IS PROCESSING?
"Processing" means and covers virtually any handling of data.

WHAT LAW APPLIES?
We will only use your Personal Data in accordance with the Philippines' Republic Act 10173, Data Privacy Act of 2012 (“DPA”) and the EU's General Data Protection Regulation (“GDPR”), and of course only as described in this Privacy Policy.

WHAT ARE THE LEGAL BASES FOR PROCESSING PERSONAL DATA?
We have to have at least one of the following legal bases to process your Personal Data:
a) you have given your consent;
b) the data is necessary for the fulfillment of a contract/pre-contractual measures;
c) the data is necessary for the fulfillment of a legal obligation; or
d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden.

WHAT PERSONAL DATA DO WE COLLECT FROM YOU?
We may collect and process the following Personal Data about you:

a) Personal Data that you give us:
This is information about you that you give to us by filling in forms on our website, scheduling an appointment, requesting a quotation or services, or corresponding with us by telephone, post, email, or otherwise. It may include, for example, your name, address, email address, and telephone number; information about your business relationship with us; and information about your requirements and interests.

The protection of your Personal Data is particularly important to us in the performance of our services. We therefore only want to process as much Personal Data (for example, your name, address, e-mail address, or telephone number) as is absolutely necessary. Nevertheless, we rely on the processing of certain Personal Data, to fulfill our contractual obligations to you or to carry out pre-contractual measures and in the context of administrative tasks as well as the organization of our business and compliance with legal obligations, such as archiving.

For optimal customer service, we use your first and last name, your e-mail address and the data relating to your contact or contract with us. Your data is stored on our website and/or in our ERP (Enterprise Resource Planning) system of Odoo. This data processing is based on our legitimate interest in providing our service.

b) Personal Data that our website and other systems collect about you:
If you visit our website, it will automatically collect some information about you and your visit, including the Internet protocol (IP) address used to connect your device to the Internet and some other information, such as the pages on our site that you visit. This is used to monitor the performance of the website and improve the experience of visitors to the website.

We host our website using the services of Wix.com Ltd. In this sense, Wix processes all data and communication data, including IP addresses, that are provided to us through our website. This means that all data submitted to our website is transferred to Wix. The legal basis for processing is our legitimate interest.

We also use the Content Management System (CMS) of Wix to publish and maintain the created and edited content and texts on our website. This means that all content and texts submitted to us are transferred to our Wix server. In addition to texts, this also includes, for example, your data in our forms. The legal basis for this processing is our legitimate interest.

We use so-called cookies on our website. Cookies are pieces of information that are transmitted from our web server or third-party web servers to your web browser and stored there for later retrieval. Cookies may be small files or other types of information storage. As set out in the DPA and the EU's Privacy and Electronic Communications Directive (“PECD”), we need to obtain consent for the use of non-essential cookies. For further information on the cookies we use, please refer to our Cookie Policy.

OTHER USES OF YOUR PERSONAL DATA?

We may also collect, store, and use your Personal Data for the following purposes:

- to operate, manage, develop, and promote our business and, in particular, our relationship with you and related transactions, including, for example:

- marketing purposes (when we have either gathered prior opt-in consent and/or have a legitimate interest to send you communications which we believe to be relevant and of use to you);

- accounting and billing/payment purposes;

-to operate, administer, and improve our website and other aspects of the way in which we conduct our business;

- to offer you our services;

- to provide you with services or information that you may have requested; and

- to keep you informed and updated on relevant topics or services you may be interested in.

- to protect our business from fraud, money laundering, breach of confidence, theft of proprietary materials, and other financial or business crimes;

- to comply with our legal and regulatory obligations, bring and defend legal claims and assert legal rights; and

- if the purpose is directly connected with an assigned purpose previously made known to you.

CHANGE OF PURPOSE
We will only use your Personal Data for the purposes for which we collected it as detailed above, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so.

DATA SHARING
Internal
If necessary, we transfer your Personal Data within WAGMI Solutions. Access to your Personal Data is only granted to authorized employees who need access to the data due to their job.

External bodies
Personal Data is transferred to our service providers in the following instances:

- in the context of fulfilling our contract with you,

- to use marketing services and to advertise our products and services online,

- to communicate with you,

- to provide our website, and

- to state authorities and institutions as far as this is required or necessary.

International transfers
We may transfer your Personal Data to other companies as necessary. In order to provide adequate protection, we have contractual arrangements such as NDAs and standard contractual clauses.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?
We will delete your Personal Data when:

- it is no longer necessary for us to retain it,

- we believe it is inaccurate,

- or you inform us you no longer consent.

- Legal or regulatory retention requirements may apply in some cases.

DATA SECURITY
Our website uses SSL/TLS encryption. We also implement technical and organizational security measures to protect your data.

SOCIAL MEDIA
We are present on social media based on our legitimate interest. If you contact us there, we and the platform are jointly responsible for processing your data.

MARKETING
With your consent, we may contact you via channels you agreed to. We use Apollo (ZenLeads Inc.) for marketing. You may unsubscribe at any time.

YOUR RIGHTS AND PRIVILEGES
Under the DPA, you have the right to:

- Right to be informed

- Right to access
- Right to rectification
- Right to erasure
- Right to object/opt-out
- Right to consent
- Right to redressal

Under the GDPR, you can:

- Right to request information
- Right to rectify data
- Right to object to processing

- Right to request deletion
- Right to data portability
- Right to withdraw consent
- Right to lodge complaints
- Right to opt out of automated processing

Update or withdraw your information
To correct or delete your data, or object to processing, contact us via ginalyn@wagmisolutions.io.

Access Request
To request access to your data, contact us. We’ll respond within 30 days or let you know why we need more time.

We do NOT:

- Request data from children

- Process special categories of data without explicit consent

- Use automated decision-making

- Sell your data

Complaint to a supervisory authority
Contact the National Privacy Commission (NPC) in the Philippines or the relevant authority in your country if you have concerns. We encourage reaching out to us first.

USA-SPECIFIC PROVISIONS
We apply relevant laws such as:

CCPA (California)

COPPA (Children’s privacy)

CAN-SPAM Act

TCPA (for SMS)

Do-Not-Track

MEXICO-SPECIFIC PROVISIONS
We comply with LFPDPPP and INAI in Mexico.

HELP AND COMPLAINTS
Contact us at ginalyn@wagmisolutions.io with questions or concerns.

CHANGES
This version was issued on Thursday, May 22, 2025, and is the current version.