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PRIVACY POLICY

Last updated: September 2022

1. Introduction

This statement sets out the Privacy Policy adopted by Blank Finvex (“us”, “we” or “our”) in relation to our products and services (the “Services”) and our website (the “Website”). Protecting your privacy and safeguarding the confidentiality of your information are fundamental to how we deliver our Services and operate the Website.

Our Services and Website may contain links to third-party websites and services. We are not responsible for the privacy practices of such third parties, and we encourage you to review their privacy policies before using their services.

All information collected in connection with our Services is treated as confidential. We implement appropriate technical, organisational and security measures to protect Personal Data (as defined below) against unauthorised access, accidental loss, destruction, alteration, theft or disclosure.

When submitting information through our Website, you may be asked to provide personal details such as your name, email address, phone number, date of birth and identification information. This data may be used to verify identity, administer accounts, provide technical support and meet contractual or legal obligations. With your consent, we may also send important updates and information about our products and services via email or other communication channels. You may manage your preferences or unsubscribe from non-essential communications at any time.

2. Website; Visitors and Users

2.1. General

This section explains how data is collected from Website visitors (“Visitors”), registered users (“Users”) and business partners (together referred to as “Partners”). Personal Data may include IP addresses, names, contact details and information relating to your relationship with us, as defined by applicable data protection laws.

2.2. Collection and Use

By accessing the Website, you consent to the collection and use of your Personal Data in accordance with this Policy. If you do not agree, you should refrain from using the Website. We may collect data through page views, IP addresses, cookies and information voluntarily submitted via forms or registrations.

2.3. Purpose of Processing Personal Data

Personal Data is processed to operate, improve and personalise the Website and Services. This includes communication, customer support, fulfilment of contractual obligations, collaboration with partners and enhancement of service accuracy. All processing is carried out based on consent or another lawful basis.

The purposes and legal bases for processing Personal Data include:

Account registration Your consent; performance of Services or contractual obligations
Provision and use of Services Performance of Services or contractual obligations
Operational communications Performance of Services or contractual obligations
Responding to enquiries and providing support Legitimate interests or performance of Services
Personalised Services, advertising and marketing Legitimate interests or your consent
Developing and improving Services Consent and legitimate interests
Sending marketing communications Your consent
Measuring marketing effectiveness Legitimate interests or consent
Operational and support activities Legitimate interests or performance of Services
Statistical and analytical purposes Legitimate interests
Protecting rights, assets and security Legitimate interests or legal obligations

2.4. Sharing Personal Data

Personal Data may be shared with service providers, Partners and contractors where necessary. For users within the European Economic Area, all processing is carried out in accordance with applicable data protection laws, including GDPR.

3. Partners

3.1. General

In order to provide Services and collaborate with Partners, we may collect and process specific data. Partners remain responsible for their own data, which may be accessed securely where required.

3.2. Processing of Personal Data

Personal Data is processed based on Partner consent or legitimate interests. Aggregated data may be created for service development and quality improvement.

3.3. Controller and Processor Roles

Depending on the context, we may act as:

  • Controller for Visitor and User data
  • Processor for Partner data
  • All data is hosted securely using industry-standard safeguards.

3.4. Third-Party Data Processing

If Services involve third-party platforms:

  • We act as a data processor
  • Follow the controller’s instructions
  • Apply appropriate security measures
  • Notify relevant parties of data breaches
  • Do not subcontract without consent
  • Do not transfer data outside approved regions without permission
  • Ensure consent and opt-out options for electronic marketing

4. Security

We apply administrative, technical and organisational measures to protect Personal Data from unauthorised access, loss, misuse or alteration. When working with third parties, we require equivalent data protection standards through contractual agreements.

While we take strong precautions, no system is entirely immune to security risks. Users acknowledge the inherent risks associated with online data transmission.

5. Cookies

Please refer to our Cookie Policy for information about the cookies and tracking technologies used on the Website.

6. Links to Other Websites

The Website may contain links to external websites. We are not responsible for their content or privacy practices, and users should review their policies independently.

7. Retention and Deletion

Personal Data is retained only for as long as necessary. Users with active accounts are responsible for managing their data. Upon account termination, data is deleted in accordance with legal and internal requirements.

Withdrawal of consent may limit access to certain Services without entitlement to compensation.

8. Your Rights

Users have the following rights regarding Personal Data:

8.1. Right of Access

  • Confirmation of data processing
  • Access to Personal Data
  • Information on processing purposes, recipients and retention

8.2. Right to Rectification

  • Correction of inaccurate data
  • Completion of incomplete data

8.3. Right to Erasure

  • Request deletion of Personal Data where applicable

8.4. Right to Restrict Processing

  • Request limitation of processing under certain conditions

8.5. Right to Data Portability

  • Receive data in a structured, machine-readable format
  • Transfer data to another controller

8.6. Right to Object

  • Object to processing based on legitimate interests or marketing

8.7. Right to Withdraw Consent

  • Withdraw consent at any time

9. Advertising and Marketing

Marketing communications are sent only with consent. You may withdraw consent at any time by contacting us in writing.

10. Acceptance of this Policy

By using the Website or Services, you acknowledge that you have read and accepted this Privacy Policy. Continued use following updates constitutes acceptance of any changes.

11. Legal Disclosure

Personal Data may be disclosed where required by law or to protect rights, property or safety.

12. Data Protection Officer

For privacy-related enquiries, please contact our Data Protection Officer at [email protected].

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