1. GENERAL INFORMATION

 

This policy (“Policy”, together with our Terms of Use) explains and sets out the basis for why and when we collect personal information about the people who visit our Website(s), how we use it, the conditions under which we may disclose it to others and the measures we take to keep it secure.

 

By visiting this Website you are accepting and consenting to the practices described in this Policy. Please note that this includes consenting to the collection and processing of any personal information you provide, as described below. We may amend this Policy from time to time so please check it occasionally to ensure that you agree with any changes. Your continued use of our Website will constitute your acceptance of, and agreement to, any changes.

 

2. PURPOSE

 

The purpose of this Privacy Policy is to inform you of:

 

(i) the kinds of Personal Information we may collect about you and how it may be used;

(ii) use of information regarding IP Addresses and our use of cookies;

(iii) disclosure of Personal Information to third parties;

(iv) the transfer of your Personal Information within and outside of the European Economic Area (“EEA”);

(v) your ability to correct, update and delete your Personal Information;

(vi) the security measures we have in place to prevent the loss, misuse, or alteration of Personal Information under our control;

(vii) Finexify’s retention of your Personal Information.

 

3. RESPONSIBLE PERSON

 

For any matters relating to data protection you may contact compliance@finexify.com in writing by e-mail.

 

4. DATA PROCESSING

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4.1. INFORMATION WE AUTOMATICALLY COLLECT

 

When you access or use our Website, we automatically collect information about you. This information is used to provide statistical data about our users browsing actions and patterns, and does not personally identify individuals. This information may include:

 

(i) Log Information: the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to our services.

(ii) Device Information: information about the computer or mobile device you use to access our services, including the hardware model, operating system and version, unique device identifiers, and mobile network information.

 

The collection and processing of this technical data is for the purpose of enabling the use of our Website, continuously ensuring system security and stability, optimising our Website, and for internal statistical purposes. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

4.2. IP ADDRESSES

 

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users' browsing actions and patterns and does not identify any individual.

 

Furthermore, the IP addresses will be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorised use or misuse of the Website, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of Art. 6 Par. 1 lit. f GDPR.

 

4.3. USAGE OF COOKIES

 

The Website uses cookies. Cookies are text files that are stored in a computer system via an Internet browser. More detailed information on cookies and how they work can be found at: https://www.allaboutcookies.org.

 

We use information collected from cookies to assess the effectiveness of our Website, analyse trends, and administer the Platform. The information collected from cookies allows us to determine 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 Website.

 

By continuing to use our Website you agree to the following cookies:

 

(i) Cookies that are strictly necessary to operate our Website: cookies to log in, transact and otherwise use our Website;

(ii) Cookies for analytical and performance purposes;

(iii) Cookies for targeting user actions;

(iv) Cookies from third parties;

 

We use third party service provider(s), to assist us in better understanding the use of our Website. 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 Website, what products are browsed, and general Transaction information. Our service provider(s) analyses this information and provides 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 Website 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 information they receive from our Website other than to assist us.

Third-party providers that we use include:

 

(i) Google Analytics;

(ii) Sendgrid;

(iii) Google Adwords;

(iv) Facebook Analytics;

 

4.4. E-MAIL SUBSCRIPTION

 

Financial professionals who complete the registration process on our web site are at the same time granting Finexify permission to send them e-mail messages for marketing and general communication purposes at the e-mail address they have provided. This consent constitutes the legal basis for our processing of your e-mail address in the sense of Art. 6 Par. 1 lit. a GDPR. All information gathered this way will never be passed on or sold to any third party.

 

At the end of each newsletter a link is provided by means of which you can unsubscribe at any time. After unsubscribing your personal data will be deleted.

 

4.5. SOCIAL MEDIA

 

We may use plug-ins from social networks such as Twitter, GitHub, YouTube, Reddit, Facebook on our Website. When you activate them (by clicking on them), the operators of the respective social networks may record that you are on our Website and may use this information. This processing of your personal data lays in the responsibility of these individual social media platforms and occurs according to their privacy policy. Please check with these individual social media platforms regarding their privacy policies. Finexify is not responsible for data collected by these individual social media platforms. We only use these platforms to inform our community of updates and answer user questions.

 

5. DISCLOSURE OF INFORMATION

 

Your Personal Information may be disclosed to third parties and/or legal authorities under the following circumstances/conditions:

 

5.1. DISCLOSURE TO THIRD PARTIES

 

We may disclose your Personal Information with third parties including:

 

(i) Business partners, suppliers, sub-contractors and other service providers;

(ii) Advertisers and/or advertising networks that require data in order to select and show you relevant advertisements;

(iii) Analytics and/or search engine providers that assist us in the optimization of our Website.

 

(iv) All our third party service providers are bound by contract to protect and use our users’ Personal Information only for the purposes listed above, except as otherwise required by law.

 

5.2. DISCLOSURE TO LEGAL AUTHORITIES

 

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other authorities in the following cases:

 

(i) If we believe disclosure is in accordance to any law, regulation or legal procedure;

(ii) If we think disclosure is needed to prevent any harm or financial loss;

(iii) If disclosure is necessary to report certain illegal activity;

(iv) To protect the rights, property or safety of Finexify and its community.

(v) If we believe your actions are in violation of this Privacy Policy and/or our Terms of Use.

 

6. INTERNATIONAL TRANSFER

 

We store and process your Personal Information in data centers around the world, wherever Finexify facilities or service providers are located. As such, we may transfer your Personal Information outside of the EEA. Such transfers are undertaken in accordance with our legal and regulatory obligations.

 

7. MINORS

 

THE SERVICE IS NOT FOR PERSONS UNDER THE AGE OF 18 OR FOR ANY USERS PREVIOUSLY SUSPENDED OR REMOVED FROM THE SERVICE. IF YOU ARE UNDER 18 YEARS OF AGE, THEN YOU MUST NOT USE OR ACCESS THE SERVICE AT ANY TIME OR IN ANY MANNER. By accessing or using the Service, you affirm that you are at least 18 years of age.

 

Finexify does not knowingly collect or use any personal data from minors. A minor may be able to willingly share personal information with others, depending on the products and/or media channels used. If a minor provides us with their information without the consent of their parent or guardian, we will ask the parent or guardian to contact us for the purpose of deleting that information.

 

8. LINKS

 

Finexify may provide references and/or links to other Websites. This Policy applies only to Finexify’s Website.

 

9. CORRECTION/UPDATING/DELETING OF PERSONAL INFORMATION

 

You may access your Personal Information whenever you want by sending us an e-mail to compliance@finexify.com. Please, have in mind that there might be a small fee in order to cover our costs for providing you the desired access.

 

You have the right to correct, update or delete any inaccurate and/or incorrect data by contacting us at compliance@finexify.com.

 

The deletion or destruction requests of both your Account and Personal Information will be reviewed and processed only where this is not inconsistent with its legal and regulatory obligations.

 

10. SECURITY OF PERSONAL INFORMATION

 

We use appropriate technical and organizational security measures to protect your stored personal data against manipulation, partial or complete loss, and unauthorized access by third parties. Our security measures are continuously being improved in line with technical developments. 

Part of these measures are:

 

(i) Password protected directories and databases;

(ii) Only authorised personnel with access to your Personal Information, who are required to treat the information as confidential;

(iii) Secure Sockets Layered (SSL) technology to encrypt and send your information across the Internet securely;

(iv) PCI Scanning to prevent your information from being hacked.

 

11. RETENTION OF PERSONAL INFORMATION

 

We retain Personal Information for as long as necessary to fulfil purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. 

 

12. CHANGES AND UPDATES TO THIS PRIVACY POLICY

 

This Privacy Policy may be revised, modified, updated and/or supplemented at any time, without prior notice. When we make changes to this Privacy Policy, we will notify all users on our Website, and make the amended Privacy Policy available on our Website.