Data Processor – a person or an entity who Processes Personal Data on behalf of the Data Controller.
GDPR – Regulation (EU) 2016/679 (General Data Protection Regulation).
Personal Data – any information relating to an identified or identifiable living natural person.
Platform – a platform, programming interface (API), applications, materials, any products, services, solutions and other items provided by or on behalf of the Company and available through website fincor.io and any affiliated mobile websites and mobile applications, owned and/or operated by the Company.
Processing – any operation or set of operations performed with regard to Personal Data, whether or not performed by automated means, for example collection, recording, organisation, storage, adaptation, alteration, retrieval, gathering, use, combination, erasure or destruction.
Recipient – a natural or legal person, public authority or another body, to whom Personal Data may be lawfully disclosed by the Company.
What types of Personal Data we have and how we get it?
We currently Process the following information:
- Communication data, related to communication between you and the Company within the Platform, via email or by other means;
- Technical data, such as IP address, Mobile Device information, log information (date and time of visit, time spent on the Platform, features used, etc.). Such data are provided by you/your Mobile Device and are collected automatically.
- Communication data, related to communication between you and the Company via email or by other means;
- Data that you provide to us via our social network pages (e.g. Facebook, Twitter, Linkedin, etc.).
Legal grounds and purposes of Processing Personal Data
We only collect and process Personal Data about you where we have legal grounds. Legal grounds include consent (where you have given consent), contract (where processing is necessary for the performance of contract signed with you), legal obligations applicable to us and our legitimate interests. We are also Processing the Personal Data in order to authorize, provide, control and administer access to the Platform and the services within the Platform; to manage our relationships with you (including in relation to token sale, if such occurs).
Compliance with legal obligations
The Company needs to comply with legal obligations. Therefore, we are required to Process Personal Data in accordance with applicable laws. Examples of purposes for such Processing are:
- to comply with rules and regulations relating to accounting, legal investigations, anti-money laundering, etc.;
- to fulfil the obligations of applicable litigation laws.
The Company Processes Personal Data for our legitimate interests. This Processing is necessary for the purposes of a legitimate interest pursued by the Company, which we have considered outweighing the Data Subject’s interest of protection of the Personal Data. Examples of purposes for such Processing are:
- to develop, examine and improve the Platform and/or the Data Subject’s user experience by performing analyses, statistics, etc.;
- to prevent or investigate possible fraud or other violations of the contracts and/or attempts to harm other Platform users;
- to reply to the Data Subject’s requests;
- to establish and defend legal claims;
- to respond to your queries or communicate with you,
- for business statistics and analytics (aggregated data is mainly used for this purpose);
- for tracking and targeting the interests of our customers to improve functionality of the Platform or enhance user the experience on the Platform.
Some of the data may be Processed based on the Data Subject’s consent, e.g. when you subscribe to our newsletter. Where we rely on your consent to process Personal Data, you have the right to withdraw or decline your consent at any time by contacting us at [email protected]
Whom we disclose the Personal Data?
The Company may share some Personal Data with Recipients, such as competent authorities. The Company does not disclose more Personal Data than necessary for the purpose of disclosure. Recipients may Process the Personal Data acting as Data Processors and/or as Data Controllers. When Recipient is Processing Personal Data on its own behalf as a Data Controller, the Recipient is responsible for providing information on such Processing of Personal Data to the Data Subject.
The Company may disclose Personal Data to Recipients, such as:
- Data Processors invoked by the Company for development and/or maintenance of the Platform or our services;
- competent authorities, such as law enforcement agencies;
- financial and legal consultants, auditors, investment managers, other service providers and affiliates of the Company, to whom disclosing of the Personal Data is necessary and lawful.
How and how long we store the Personal Data?
As a general rule Data Subject’s Personal Data are Processed within the EU/EEA. The transfer and Processing of Personal Data outside of the EU/EEA could only take place if there is a legal basis and appropriate safeguards are taken.
We keep Personal Data for a limited time period and in any event no longer than necessary for the purposes for which the Personal Data were collected. The retention periods are defined by the laws or legitimate interests of the Company. After retention period comes to an end the Company will then delete the Personal Data.
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Use of Google Analytics
Google Analytics is integrated on our website fincor.io.
Google Analytics is a website analysis service. Website analysis refers to the collection, recording and analysis of data regarding the behaviour of visitors to the website. You can find more information about Google Analytics’ use of Personal Data here: https://policies.google.com/privacy?hl=en.
Data Subject’s rights and how to complain?
Under GDPR, you have the following rights:
Your right of access – you have the right to ask us for copies of your personal information.
Your right to rectification – you have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – you have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of Processing – you have the right to ask us to restrict the Processing of your information in certain circumstances.
Your right to object to Processing – you have the the right to object to the Processing of your information in certain circumstances.
Your right to data portability – you have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
If you make a request, we have one month to respond to you.
Please contact us at [email protected] if you wish to make a request.
You can also complain to the Lithuanian State Data Protection Inspectorate (website address: www.vdai.lrv.lt) if you are unhappy with how we have used your Personal Data.
Last updated: 2021.12.08