Registered office at: The Financial Services Centre, Stoney Ground, Kingstown, Saint Vincent and the Grenadines
Last updated: Oct 18th, 2022
TABLE OF CONTENT
INTRODUCTION (New Data Protection Regulations)
1. GENERAL INFORMATION
3. SHARING INFORMATION WITH THIRD PARTIE
4. PERSONAL INFORMATION WE COLLECT FROM USERS
5. YOUR RIGHTS
6. CONTACT DETAILS AND HOW CAN YOU COMPLAIN
7. WITHDRAWAL OF CONSENT
8. KEEPING INFORMATION SECURE
To the extent applicable, both Parties (User/Client and the Company) shall comply with the relevant laws relating to the protection of Personal Data including but not limited to the General Data Protection Regulation 2016/679 (Data Protection Legislation).
The Parties shall process personal data only to the extent and in such manner as is necessary for the purposes of performing their respective obligations.
The Client shall ensure that: it has all necessary notices and authorizations in place to enable lawful transfer of the Personal Data to the Company and any data subject has been or will be informed on the personal data processing related to this Agreement.
1. General information
1.4. We do not collect any personal information about You unless You voluntarily provide it to us. However, You may be required to provide certain personal information to us when You elect to use certain products or services available on the Site. These may include:
- registering for an account on our Site;
- signing up for special offers from selected third parties;
- sending us an email message;
- submitting Your credit card or other payment information when ordering and purchasing products and services on our Site. To wit, we will use Your information for, but not limited to, communicating with You in relation to services and/or products You have requested from us. We also may gather additional personal or non-personal information in the future.
- What personally identifiable information is collected from you through the web site, how it is used and with whom it may be shared.
- What choices are available to you regarding the use of your data.
- The security procedures in place to protect the misuse of your information.
- How you can correct any inaccuracies in the information.
- You can access our website home page and browse our site without disclosing your personal data.
2. ACCEPTANCE OF THE COMPANY POLICY
3. SHARING DATA WITH THIRD PARTIES
3.1. The Company may, from time to time, contact You on behalf of external business partners about a particular offering that may be of interest to You. In those cases, Your unique personally identifiable information (e-mail, name, address, telephone number) is transferred to the third party. The Company may share data with trusted partners to help perform statistical analyses, send You email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using personal information except to provide these services to the Company, and they are required to maintain the confidentiality of Your information.
3.2. The Company may disclose Your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to:
(a) conform to the edicts of the law or comply with legal process served on the site;
(b) protect and defend the rights or property of the Company and/or;
(c) act under exigent circumstances to protect the personal safety of users of the Company, or the public.
Personal data held by us may be transferred to:
- Other Companies member firms;
We may share personal data with other Company member firms (affiliated companies) where necessary for administrative purposes and to provide professional services to our clients (e.g. when providing services involving advice from Company member firms in different territories).
- Third parties that provide applications/functionality, data processing or IT services to the Company;
- Banks and payment providers – to authorise and complete payment transactions;
- Third party identity checking or credit reference agencies – for the purposes of identity checking and bank account verification;
- Organisations within the payment card industry to help prevent online fraud;
3.3. We use third parties to support us in providing our services and to help provide, run and manage our internal IT systems. For example, providers of information technology, cloud-based software as a service providers, identity management, website hosting and management, data analysis, data back-up, security and storage services. The servers powering and facilitating that cloud infrastructure are located in secure data centers around the world, and personal data may be stored in any one of them;
- Third parties that otherwise assist us in providing goods, services or information;
- Auditors, lawyers and other professional advisers;
- Law enforcement or other government and regulatory agencies or to other third parties as required by, and in accordance with, applicable law or regulation;
3.4. We may receive requests from third parties with the authority to obtain disclosure of personal data (Financial inspection, Financial Intelligence Unit, etc), such as to check that we are complying with applicable law and regulation, to investigate an alleged crime, to establish, exercise or defend legal rights. We will only fulfil requests for personal data where we are permitted to do so in accordance with applicable law or regulation.
3.5. The Company may keep track of the websites and pages of our users, in order to determine what services are the most popular. This data is used to deliver customized content and advertising within a Company to customers whose behavior indicates that they are interested in a particular subject area.
3.6. Information about Your computer and software may be automatically collected by the Company. This information can include Your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the service, to maintain quality of the service, and to provide general statistics regarding use of the Companies website.
3.7. If a Company is involved in a merger, acquisition or sale of all or a portion of its assets, your Personal Information will be shared with the relevant co-party.
3.8. When we provide Personal Information to these third parties, it is possible that this will involve transferring your Personal Information to countries outside the European Economic Area (“EEA”). Where this is the case, we will ensure that there are measures in place so that your Personal Information has an adequate level of protection.
4. PERSONAL INFORMATION WE COLLECT FROM USERS
4.1. Personal data is any information that can be linked to a person. This includes identity data such as:
- surname, first name, patronymic of the User;
- date of birth of the User
- gender of the User
- postal address of the User
- contact phone of the User
- e-mail address
- place of residence of the User (if necessary)
- photo (if necessary).
- passport details and scan-copies of the User personal documents;
- card payment information;
- operations performed at a branch;
- agreements you have entered into;
- information we obtain about You in your communication with our Consultation Center.
4.2. The data we collect depends on the services You use. We may collect information such as name, identification code, date of birth or preferred language of communication, KYC documentation, including but not limited to, amendments and revisions and updates as these are deemed necessary, from time to time, for the provision of the services. You can control what data you want to share with us. Your personal data will be stored no longer than necessary for the purpose of the processing activity.
4.3. We collect Your basic payment information and we may also ask you to confirm your home address. When you create an Account on our website, we may ask, among other things, for your name, email address, postal address, phone number, bank account details.You may decline to provide us with your Personal Information, but this may prevent you from using certain services.
4.4.We keep your data only for as long as it is needed for the purpose for which your data were registered and used. For example: In accordance with the Law on the Prevention of Money Laundering and Terrorist Financing we may store copies of the identity documents of the customer, the identity data of the beneficial owner, the identity data of the beneficiary, direct video streaming/direct video broadcasting recordings, other data received at the time of establishing the identity of the customer and account and/or agreement documentation (originals of the documents) for eight years from the date of termination of transactions or business relationships with the customer, and the period may be prolonged for up to additional two years.
4.6 Upon express request, fully verified DFX AG users may have their personal KYC data transferred to MN IT Services LLC in order to use MN IT Services LLC services without re-verification. Please see our Terms & Conditions for further information.
5. YOUR RIGHTS
5.1. You can obtain insight into the personal data we registered and use, where it comes from and what we use it for. You can obtain information about for how long we store your data and about who receives data about you, to the extent that we disclose data. Your right of access may, however, be restricted by legislation, protection of other persons’ privacy and consideration for our business and practices. Our know-how,business secrets as well as internal assessments and material may also be exempt from the right of insight.
5.2. If the data is incorrect, incomplete or irrelevant, you are entitled to have the data corrected or erased with the restrictions that follow from existing legislation and rights to process data. These rights are known as the “right to rectification”, “right to erasure” or “right to be forgotten”.
5.3. If you believe that the data we have registered about you is incorrect, or if you have objected to the use of the data, you may demand that we restrict the use of these data to storage. Use will only be restricted to storage until the correctness of the data can be established, or it can be checked whether our legitimate interests outweigh your interests.
5.4. If we use data based on your consent or as a result of an agreement, and the data processing is automated, you have a right to receive a copy of the data you have provided in an electronic machine-readable format.
6. CONTACT DETAILS AND HOW YOU CAN COMPLAIN
6.1. You are always welcome to contact us if you have questions about your privacy rights and how we register and use personal data. You can contact our Data Protection Officer by writing to the: e-mail: firstname.lastname@example.org
7. WITHDRAWAL OF CONSENT
7.1. You can withdraw your consent to disclose data that requires your consent at any given time. To withdraw consent to our processing of your personal data please email us at email@example.com or, to stop receiving an email from a Company marketing list, please click on the unsubscribe link in the relevant email received from our Company.
8. KEEPING INFORMATION SECURE
8.1. We invest significant resources to protect your Personal Information from loss, misuse, unauthorised access, modification or disclosure. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.
8.2. While we use encryption to protect sensitive information transmitted online, we also protect your information off-line. Only employees who need the information to perform a specific job (for example, lawyers, compliance department, etc) are granted access to personally identifiable information.