Privacy Policy

Our company recognizes the vital importance of protecting your personal and financial information. This privacy policy details how we manage personal information provided to us by you or a third party in connection with our provision of services to you or that we collect as a result of your use of our services and/or our apps or websites.

The personal information we store about you must be:

* Used legally, fairly, and transparently.

* Collected only for valid purposes that we have clearly explained to you, and not used in any way inconsistent with those purposes.

• It is related to the goals that we have told you about, and is limited only to them.

* Securely stored only for as long as it is necessary for the purposes we have told you about.

• Accurate and up-to-date

We reserve the right to change and supplement this privacy notice from time to time, taking into account new technologies, changes in our activities and practices, new laws and regulations. Our most recent privacy policy will govern any personal information we hold about you.

1. Data controller

2. Use of Personal Data and Legal Grounds for their Processing

2.1 Provisions, Improvement and Development of Products and Services

When opening an account, we will need to use your personal information to perform our services and fulfill our obligations to you. It is in our legitimate interest to ensure that we provide you with the best products and services, so we can regularly check your needs to make sure that you get the best products and services from us.

2.2 Identity Verification and Account Management

As part of providing you with services or information about our services, we will need to verify your identity in order to set you up as a customer, and we will need to use this data to effectively manage your account with us to ensure that you receive the best possible service from us. This may include third parties performing credit or identity checks on our behalf. We collect, process, and disclose personal data to fulfill our contractual, regulatory, and statutory obligations to our customers. This is in our legitimate business interests, and the use of your personal information in this way is necessary to provide you with our contractual services. We are also required to comply with applicable laws and regulations

2.3 Settlement of requests and disputes

In cases where we believe that there is a risk that we may need to defend or bring legal action, we may retain your personal information necessary to protect our legitimate interests so that we can properly present or defend it.

legal claims. We may also need to share this information with our insurers or legal advisors. How long we retain this information will depend on the nature of the claim and how long we believe there is a risk that we will have to defend or bring a claim. Using your personal information in this way is in our legitimate interests


2.4 Profiling and automated decision-making

We may from time to time use personal information about you to form profiles about you so that we understand your needs and provide the best products and services that we can. We may also make decisions about you through automatic profiling or automatic credit checks that may affect your ability to use our services. We may have to do this either to fulfill our legal obligations or because it is in our legitimate interest to use your personal information in this way. You can object to automatic decision-making and ask we should check the information received and / or ask another employee to review it. Profiling is any form of automated processing of personal data that involves the use of personal data to evaluate certain personal aspects related to an individual, labor productivity, economic status, health.

2.5 Compliance with Applicable laws and regulations

We may need to use your personal information to comply with applicable laws, court orders, or other personal preferences, interests, reliability, behavior, location, movements, etc.

court decisions.

or the requirements of any applicable regulatory authority and transfer your personal information to third parties, including, but not limited to, auditors and regulators. For example, conduct anti-money laundering and due diligence checks, detect and prevent fraud, track and record phone calls, inform you of any changes to our services, respond to complaints and requests, and keep your records up to date. We do this in accordance with our legal obligations, as well as because it is in our legitimate interests.

2.6 Marketing

We may collect your name and contact information (such as your email address, phone number, or address) in order to send you information about our products and services that may be of interest to you. We may receive this information directly from you or through a third party. If a third party has collected your name and contact information, they will only share it with us for marketing purposes if you give your consent. It is in our legitimate interest to use your personal information in this way.

You always have the right to " opt out” of receiving our marketing. You can exercise this right at any time by contacting us. If we send you any marketing emails, we will always give you the option to unsubscribe so that you can opt out of any further marketing emails. If you “opt out” of our marketing materials, you will be added to our suppression list so that we do not accidentally send you further marketing.

We will never share your name or contact information with third parties for marketing purposes, unless we have your " consent” to share your data with a specific third party to send you marketing messages. We do use third-party service providers to send out our marketing information, but we only allow them to use this information according to our instructions and in cases where they have agreed to treat this information confidentially and keep it safe. It is in our legitimate interest to use your personal information in this way.

We keep your data on our marketing list until you “opt out”, after which we will add you to our suppression list. We keep this suppression list indefinitely to fulfill our legal obligations and to ensure that we don't accidentally send you any more marketing.

2.7 Links and surveys

From time to time, third parties, such as credit agencies, may contact us to provide a credit certificate about you to verify your creditworthiness and identity. It may be in our legitimate interest to comply with our legal obligations, or we may be required to provide such a link in order to fulfill a legal obligation.

From time to time, we may send you surveys as part of our customer feedback process, and it is in our legitimate interest to do so.

interest in feedback to make sure we provide you with the best service. However, we may also ask you to participate in other surveys from time to time, and if you agree to participate in such surveys, we rely on your consent to use the personal information we collect as part of such surveys. All responses to any survey we send out, whether for customer feedback or otherwise, will be aggregated and depersonalized before the survey results are shared with third parties.

2.8 Website Information

Our web pages and emails may contain web beacons or pixel tags or any other similar data analysis tools that allow us to track the receipt of correspondence and count the number of users who have visited our web page or opened our correspondence. If your personal information is completely anonymized, we do not require a legal basis, as this information will no longer constitute personal information. However, in cases where your personal information is not in an anonymous form, it is in our legitimate interest to continually evaluate it. This personal information ensures that the products and services we provide are relevant to the market.

2.9 Internal Business and Office Management

We may need to process your personal information for internal business and research purposes, as well as for record-keeping purposes. Such processing is carried out in our own legitimate interests and is necessary to comply with our legal and regulatory obligations. This may include any communications we have with you in connection with the services we provide to you and our relationship with you. We will also keep records to ensure that you meet your obligations under any contract you have entered into with us.


2.10 Exchange of information with Cooperation Partners and suppliers

We may share your personal information with cooperation partners who provide services on our behalf or have introduced you to us or to other cooperation partners or suppliers with whom we cooperate. It is in our legitimate interest to use your personal information in such a way as to provide you with our services.

2.11 Joint use with Group Entities and Corporate Restructuring

We may share your personal information with other organizations in our group as part of our regular reporting activities to evaluate the performance of the company in the context of a business reorganization or group restructuring, as well as to support system maintenance and data placement. It is in our legitimate interest to use your personal information in this way.

We may share your personal information with other third parties, for example, in the context of a possible sale or business restructuring, when necessary in connection with the purposes for which your information was collected. This is in our legitimate interests.

3. Collection of Personal Data

We may collect the following types of information from an actual or potential customer

• * name, address, and contact information, including, but not limited to, phone number and email address

• date of birth and gender

* Social networks or other network data when these technologies are used by you to communicate

• any other similar information

We receive this information through your use of our services or other transactions with us, including through any of our websites, applications, account opening applications, demo registration, webinar registration, news subscriptions, and from information provided in the course of ongoing communication with customers. We may collect this information about you from third parties either through purchased third-party marketing lists, publicly available sources, or through our "invite a friend" scheme. When we do this, we ensure that any third party who provides us with personal data has the necessary consent of the data subject to the disclosure of personal data by our company

We may ask for other personal information from time to time, and if you choose not to provide the information we require to fulfill your request for a particular product or service, we may not be able to provide you with the ordered product or service and this may mean that we must terminate the service or limit the accounts you have with us.

We may record any communications, electronic, telephone, personal, or otherwise, that we have with you in connection with the services we provide to you and our relationship with you. These records will be our only property and represent evidence of a connection between us. Any telephone conversation can be recorded without the use of a warning signal or any other additional notification. We record calls to meet our regulatory obligations.


4. Disclosure of Personal Data and their Transfer outside the European Economic Area

As part of the standard activities of our business, we may share selected information with the following persons

• * credit institutions, any relevant regulatory, government or law enforcement agencies as required by law or in agreement with you

• our insurers, agents, service providers, specialist consultants, suppliers and subcontractors who provide us with insurance, administrative, IT, financial, verification, regulatory, compliance research or other services.

* professional consultants, such as our attorneys in connection with any ongoing or anticipated legal proceedings or for the purpose of establishing, exercising or defending our legal rights, as well as our auditors and accountants in order to meet our regulatory and financial reporting obligations.

* representing brokers and branches with which we have a mutual relationship;

* credit reporting and reference agencies

• any member of our group, i.e. our subsidiaries, our ultimate holding company and its subsidiaries, as well as the legal successors in ownership of our business

• any person authorized by you

As a general rule, we require that third parties who process or receive your personal information recognize the confidentiality of this information, undertake to respect any person's right to privacy, and comply with all relevant data protection laws and this privacy notice. If any third party uses your personal data as a data controller, such use is not subject to this privacy notice and is not subject to our company's privacy standards and procedures.

Please note that third parties, such as credit reports and reference agencies, may keep records of any searches and may use the search data to assist other companies in performing their searches.

In order to transfer personal information to third parties in territories where applicable law may be inadequate, we enter into agreements with such third parties to ensure appropriate and acceptable measures based on standard contractual terms adopted by the European Commission.

5. Your consent

If the use of your personal information by us requires your consent, such consent will be provided in accordance with the applicable customer terms available on our website (s) or any other contract we may have entered into with you or agreed upon in our communication with you from time to time.

If we rely on your consent as a legitimate basis for processing your personal information, you have the right to withdraw your consent at any time by contacting us using the contact information provided below.

6. Improving Technology

We want to provide you with a better and improved experience through the constant development of technology. This may lead to changes in the way personal information is collected or used. The impact of any technological changes that may affect your privacy will be disclosed in this privacy notice at the time of the change.

7. Security and Storage of Personal Information

We take the protection of your data very seriously and take precautions to protect the security of your personal information. Our employees understand that they respect the confidentiality of your personal information.

We store personal information in secure computer storage, paper files, and / or other records.

When we decide that the personal information is no longer needed, we will delete all the details that identify you and securely destroy the records.

Please note that we are subject to certain laws and regulations that require us to keep a copy of the documents we used to fulfill our customer due diligence obligations, as well as supporting evidence and records of transactions with you and your relationship with us.

If we store any personal information in the form of a recorded message, by phone, electronically, in person or otherwise, this information will be stored in accordance with local regulatory requirements.

If you opt out of receiving marketing messages, we will store your data in our suppression list so that we know that you do not want to receive these messages.

8. Links to Third-party websites

Our websites or applications may contain links to external third-party websites. Please note that third-party websites are not subject to this privacy notice, and these websites are not subject to our company's privacy standards and procedures

Please consult with each third party regarding their privacy standards and procedures.

9. Cookies

A cookie is a small piece of text stored on your computer or device when you visit a website or app. We use cookies on our websites and apps to provide you with a more relevant and effective experience. For further information about cookies, please visit our website.


10. Your Rights

The Data Protection Act gives you a number of rights when it comes to the personal information we hold about you.

Under certain circumstances, you are legally entitled to:

* Be informed in an understandable manner about how we use your personal information and about your rights. That is why we are providing you with the information contained in this notice.