Privacy Policy

Privacy notice

This exchange platform (“website”) is owned by UAB ,,Kenlana” (“we”, “Company”). Company as a data controller shall process your personal data.

Your personal data may be processed for the purposes of:

• Customer onboarding and risk management procedure known as “Know your client” principle.
• Creation and administration of an account with us.
• Providing responses to your queries or communicate with you.
• Compliance with the requirements of the applicable laws.
• Provision of our direct marketing content including client satisfaction surveys (sent by email).
  Without any adverse effect you have a right to withdraw from receiving such content any time by calling our client service or by using an unsubscribe option in our communication.
• For the technical and functional management of the Exchange platform.
• When you make crypto exchange through our website, to process your sale/purchase.
• For a comprehensive list of data processing purposes, please refer to a full version of Privacy Notice.

Privacy rights. Data subjects have the following rights: to know what personal data is processed and how it is processed by the Company; to request for correction of inaccurate personal data; in certain circumstances, to request for rectification and erasure (except storage); in certain circumstances, restrict processing of personal data; in certain circumstances, a right to personal data portability; a right to object to the processing of personal data when the legal basis for processing is Company’s legitimate interest or your consent; a right to submit a claim to State Data Protection Inspectorate.

The Company shall ensure the confidentiality of the personal data received form you, however, the Company will be obliged to submit certain information on the performed monetary operation to regulatory authorities. The Company may also share personal data with its data processors, engaged in the provision of services (such as IT service providers, etc.). Personal data may be transferred outside EU or EEE. For certain data processing transaction, automated decision making may be used.

Find out more

UAB "Kenlana” (registered address at Šiaulių 10-56, Vilnius ) (“we”) respects your privacy and takes your privacy seriously. We are committed to protecting and securing any personal information you give us. This notice tells you why we collect information about you and what we do with it. Please note that all exchange transaction you perform through our platform at www.fincor.io will be governed by this Privacy Notice.

Please also read our Terms of Use relating to the service you are interested in. They provide more information about the way we do business, and any restrictions on eligibility that may apply.

What do we do?

We provide an exchange platform were you can trade crypto currency and otherwise monitor the transaction in the cryptomarket.

How do we collect information about you?

We may collect information about you in various ways.

• You may provide us with information directly (e.g. signing a contract, filling in a KYC form, or making a call to us).
• We may collect information automatically (e.g. through the use of cookies when you use our exchange platform). To learn about the cookies and similar technologies used on our exchange platform including how you can accept or refuse cookies, please see the Cookie notice.
• We may acquire information from third parties (e.g. in the course of onboarding procedure and performing an ongoing monitoring we will receive personal data from publicly available sources (the Database of Invalid Identity Documents http://www.ird.lt/paieska/dokumentai_lt.php ; the Register of Legal Entities of the Republic of Lithuania; the Population Register of the Republic of Lithuania, etc.) and/or third parties).
• We may also receive your information from your employer if we are in business relationship and you are a designated contact person or representative of your employer.

We may also collect information in other contexts made apparent to you at the time.

Why do we process your personal data?

If you submit your personal data to this web site, we may process it for the purposes described below.

a. For customer onboarding and risk management procedure known as “Know your client” principle. Please note, that we may use digital onboarding measures, which include processing of the video image.
b. To create and administer an account with us.
c. To respond to your queries or communicate with you.
d. To conduct ongoing monitoring of your business relationship, including scrutiny of transactions concluded throughout the Exchange platform to ensure that the transactions being conducted are consistent with the risk profile.
e. For the purposes of a merger, an acquisition or other type of business transfer.
f. For business statistics and analytics (aggregated data is mainly used for this purpose).
g. For tracking and targeting the interests of our customers to improve functionality of our website or enhance user the experience on our website.
h. For compliance with the requirements of the applicable laws.
i. For provision of our direct marketing content including client satisfaction surveys (sent by email). Without any adverse effect you have a right to withdraw from receiving such content any time by calling our client service or by using an unsubscribe option in our communication.
j. For the technical and functional management of the Exchange platform.
k. When you make crypto exchange through our website, to process your sale/purchase.
l. If you participate in promotions, to administer your participation.

What is the legal basis for such processing?

Legal basis for processing of personal data depends on the particular purpose and is a necessity for the performance of a contract (b, c, k), compliance with a legal obligation (a, d, h) and legitimate interest of the Company (c, e, f, g, i, j, l).

Where we do not base our use of information about you on one of the above legal bases, we will ask for your consent before we process the information (these cases will be clear from the context).

n some instances, we may use information about you in ways that are not described above. Where this is the case, we will provide a supplemental privacy notice that explains such use. You should read any supplemental notice in conjunction with this notice.

Who do we share your information with?

• Third parties who provide services to us (such as professional advisers, payment service providers, delivery providers, auditors, IT service providers and information services providers);
• Carefully selected business partners and advertisers (in areas connected with our services) so that they can contact you with offers that they think may interest you; and
• Other third parties, where required or permitted by law (such as regulatory authorities; government departments; etc.).

Where might information about you be sent?

We may be required to transfer information globally. Accordingly, if your information is collected within the European Economic Area, this means that your information may be transferred outside it.

When using information as described in this notice, information about you may be transferred either within or outside the country or territory where it was collected, including to a country or territory that may not have equivalent data protection standards.

We will make sure that any transfer of personal data is:

• made on the basis of a European Commission adequacy decision;
• subject to appropriate safeguards, for example the EU Model Contracts, or
• necessary to discharge obligations under a contract between you and us (or the implementation of pre-contractual measures taken at your request) or for the conclusion or performance of a contract concluded in your interest between us and a third party, such as in relation to travel arrangements.

In all cases, appropriate security measures for the protection of personal information will be applied in those countries or territories, in accordance with applicable data protection laws.

How do we protect information about you?

Your personal data is treated confidentially and we have taken technical and organizational security measures against loss or unlawful processing of this data. We use several security techniques including secure servers, firewalls and encryption, as well as physical safeguard of the locations where data is stored. We also require our service providers to comply with strict data privacy and security requirements.

How long will information about you be kept?

We will retain information about you for the period necessary to fulfil the purposes for which the information was collected. After that, we will delete it. The period will vary depending on the purposes for which the information was collected. Note that in some circumstances, you have the right to request us to delete the information. Also, we are sometimes legally obliged to retain the information, for example, for tax and accounting purposes.

• Most of the information in your trader profile is kept for the duration of our relationship with you; for example, while you continue to use the website, or respond to our communications. However, some elements of your profile, such as your sale/purchase history, may need to be stored for a longer period of time, in most cases up to 10 years from the transaction.
• If you commence registering yourself in the website, but do not complete the process, we will retain your data for only 6 months (for example, if you don’t complete the process, or you don’t accept the Terms of Use) to allow you to complete the process if you return.
• Exchange records. We keep records of sales, purchases, payments made and received and supporting documents (such as contracts and e-mails) in accordance with tax requirements, typically 10 years. We also keep records of KYC checks carried out on you for as long as we are required to comply with ALM and other regulatory obligations. This may exceed our business relationships with you.
• Visitor records. If you visit our office, visitor records are retained typically for a period of only a few months.
• CCTV records. If you visit our buildings, CCTV records are retained typically for a period of only 14 days.
• Exchange platform audit logs. These logs are retained typically for a period of only a few months. However, some logs are retained indefinitely.
• Business analytics. Business analytics data is typically collected automatically when you use our website and are anonymised/aggregated shortly afterwards.

What rights and options do you have?

The rights you have depend on the laws of your country. If you are in the European Economic Area, you will have the rights set out below. If you are elsewhere, you can contact us to find out more.

You may have some or all of the following rights in respect of information about you that we hold:

• request us to give you access to it;
• request us to rectify it, update it, or erase it;
• request us to restrict our using it, in certain circumstances;
• object to our using it, in certain circumstances;
• withdraw your consent to our using it;
• data portability, in certain circumstances;
• opt out from our using it for direct marketing; and
• lodge a complaint with the supervisory authority in your country (if there is one).

We offer you easy ways to exercise these rights, such as “unsubscribe” links, or giving you a contact address, in messages you receive or by using the contacts at the end of this notice.

Links to other websites and social media

On our website you may find a number of links to other websites. Although these websites are selected with care, we are not responsible for personal data processed through these websites.

Automated decision making and profiling.

When assessing the risk of money laundering and/or terrorist financing, we apply a risk-based approach. For this purpose, we may use a risk scoring tool developed to assess the risk posed by you. Based on the risk level, our customers are allocated to certain groups. This may have an impact for the frequency of ongoing monitoring procedures.

Other important information

Persons below the age of 16 may only provide personal data to us if they have written permission of one of their parents or their legal guardian who has read this Privacy Notice.

We may be under the legal obligation to process special categories of data, namely, the political opinions in the case of politically exposed persons. Legal basis for such processing is the requirements of AML.

Who should you contact with questions?

If you have any questions, or wish to exercise any of your rights, you can contact us by email info@fincor.io or post Siauliu 10-56, Vilnius.

Changes to this notice

We may update this notice from time to time. We will notify you of the changes where required by law to do so.

Last modified 2018.12.20 .

Cookie policy

What are cookies?

Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

Cookies set by the website owner (in this case, fincor.io) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. interactive content and analytics). The parties that set these third party cookies can recognise your computer both when it visits the website in question and also when it visits certain other websites.

Why do we use cookies?

We use first party and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Website to operate, and we refer to these as “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Website. Third parties may serve cookies through our Website for analytics and other purposes. This is described in more detail below.

The specific types of first and third party cookies served through our Website and the purposes they perform are described in the table below:

How can I control cookies?

You have the right to decide whether to accept or reject cookies. You can exercise your cookie preferences by clicking on the appropriate opt-out links provided in the cookie pop-up window..

You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

How often will you update this Cookie Policy?

We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal or regulatory reasons. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.

This Cookie Policy was last updated on [xx].

Where can I get further information?

If you have any questions about our use of cookies or other technologies, please email us at info@fincor.io.