Last updated date: 22 August 2022
As used herein, “Personal Data” means any information relating to an identified or identifiable natural person, such as a name, an identification number, location data, an online identifier and etc.
BESIDES ALL, PERSONAL DATA INCLUDES:
- Email address
- Mobile phone number
- Full legal name (including former name, and names in local language)
- Passport number, or any government issued ID number
- Date of birth
- Proof of identity (e.g. passport, driver’s license, or government-issued ID)
- Residential address
- Proof of residency
- Proof of the source of wealth
- Additional Personal Data or documentation at the discretion of our Compliance Team
Finandy collects, processes, and stores Personal Data collected from you via your use of the Service or where you have given your consent.
We collect information you provide during the Finandy onboarding process, which may be a completed, incomplete, or abandoned process. Offering services to residents in the European Economic Area (“EEA”), we collect, store, and process your personal information in accordance with the provisions of the General Data Protection Regulation (GDPR) and Data Protection Act. To understand more about how we protect the data collected from individuals and entities located within the EEA, please see the details below.
As outlined above, we may collect Personal Data from customers located in the EEA. We request explicit consent for the transfer of Personal Data from the EEA to outside of the area. If you are an individual located in the EEA and you decline to consent to such transfer, you will no longer be able to use Services. Please, in this case withdraw your digital assets and stop using our Services.
You have following rights under data protection laws in relation to your personal data:
- 1.right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
- 2.right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
- 3.right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for reasons which will be notified to you;
- 4.right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
(a) if you want us to establish the data's accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
(d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
- 1.right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you; and
- 2.right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you.
- 3.Right to have you Personal Data deleted. You may also request to delete your Personal Data, with exception that we may refuse your deletion request in certain circumstances, such as compliance with law or legal purposes.
Please contact Support Team if you have any questions concerning your personal data.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We may refuse to comply with your request in these circumstances.
Finandy uses Personal Data to communicate with you and to administer, deliver, improve, and personalize the Service. Finandy might also generate generic data out of any Personal Data we collect and use it for our own purposes. Finandy may also use such data to communicate with clients by offering other products or services of Finandy and/or its partners. We do not share your Personal Data with third parties except where you have given your consent or it is required by law.
We may share your Personal Data with third parties:
1. If we think that sharing it is necessary to enforce the Terms of Service;
2. To comply with government agencies, including regulators, law enforcement and/or justice departments;
3. To third parties who provide services to Finandy (such as administration or technical services);
4. In connection with the sale or transfer of our business or any part thereof.
The collection of personal data is also carried out in order to counteract the laundering of criminally obtained income and the financing of terrorism.
The data that we collect from you may be transferred to, and stored at, a destination outside of Seychelles. It may also be processed by staff operating outside of Seychelles who work for us or for one of our suppliers. By submitting your personal data, you agree to this transfer, storing or processing, except customers located in the EEA, as detailed above. All information you provide to us is stored on our and/or third party cloud servers.
We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.
Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
You agree and acknowledge that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.
If you disagree to receive these messages, please contact Support Team.
While you access Finandy, we may use the industry practice of placing a small amount of data that will be saved by your browser (Cookies). This information can be placed on your computer or other devices used to visit Finandy. This information help us recognize you as a customer, collect information about your use of Finandy to better customize our services. We may also use the information collected to ensure your account security has not been compromised by detecting irregular or suspicious account activities.
Most browsers are setup to accept cookies automatically. Some Cookies expire when you finalize the session and other Cookies remain on your computer or other devices until deleted or expired. You have the option to decline the use of our Cookies, but this may affect the functionality of Finandy services or your user experience.
This Policy is reviewed periodically to ensure that any new obligations are taken into consideration and takes into account any changes to the regulatory landscape. Where there are any changes to this Policy, we shall release an updated Policy on the website and change the Last Updated date. By continuing to use the Services after the Policy has been updated, it shall be deemed that you agree to the updated Policy. Should you not agree any of the terms in the updated Policy, you should cease to use the Services immediately.