Privacy policy

Introduction

The Privacy Policy (‘the Policy’) of the company UAB FINCH TECHNOLOGIES (’We’, ’Our’, ‘Us’ or ‘FinchPay‘), company code: 306113100, informs and explains You (‘You’ or ‘Your’) how We process any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for your identification or identifiability (‘Personal Data’) We receive from You when you are using Our service (‘Service‘). We use your Personal Data for operating and improving Our Website (‘Website‘) and Our Service and for the transfer to Third Parties in case of using outsourced services by Us for different purposes (’Third Party Services‘). By using the Website and Service, you agree to the processing of Personal Data in accordance with the Policy.

This Policy sets forth the basic rules and principles by which we process your Personal Data, and mentions our responsibilities while processing your Personal Data according to transparency obligations. While using the Service You agree to Your Personal Data processing in accordance with the Policy and affirm that. In case when You do not agree with the Policy partially or fully, You must stop using the Service. All data collected before the above-mentioned refusal will be processed in accordance with the Policy until Your direct prohibition is received. We do not intend to collect Personal Data of children or persons under the age of 13 (thirteen) years old.

Definitions

’Personal Data’ refers herein to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

‘Processing’ means any operation or set of operations that is performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

’Third Party Services’ refers herein to the third-party software which ensures that we meet the requirements of the regulators to verify and confirm the identity of the Service's customers. FinchPay applies to Third Party Services through the API for the following activities:

(1) identity verification;

(2) document verification;

(3) sanctions check;

(4) political affiliation check;

(5) financial background check;

as well as other checks not limited to those listed above, depending on the requirements imposed by regulators in the Service's geographic area of the presence or any other authorities.

‘Website‘ means the website of FinchPay located at https://finchpay.io.

Personal data and its processing methods

While providing our services we may collect the following:

IP address;

Cookies;

Information you may provide to Us, including, your name and surname, your email address, virtual currency addresses, mobile phone number, alias, password, and any personal documents, including ID cards, passports, proof of address, source of wealth or funds, your photos/video and any other information you choose to provide;

Device information, when You visit Our website or download the mobile version of Service, or use our Service through any of Our partners’ channels of distribution (e.g. widget) You may provide some information that may potentially identify You, such as the type (including identifiers) of the device, platform type, mobile phone number, Your internet service provider, operating system, geolocation information, browser You use, browser language, or the pages you visit.

Some of your behavior information may be provided by Our Website, such as You visiting the Website, clicking on ads, or other similar information. Such information may be received with additional related data (or metadata), such as the time, date, and location related to such information.

We collect Personal Data for the next targets and legal basis:

to provide services;

to perform transactions;

to provide You with information related to providing services;

to grant You access to Our services;

to keep the Service running (managing Your requests, remembering Your settings, hosting, and back-end infrastructure);

to provide newsletters/offers/updates/advertisements which may be interesting to You;

to prevent fraud, illegal activity, or any violation of the Terms of Use or the Policy. We may disable access to the Service, erase or correct personal data in some cases;

in order to improve the Service (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Service, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over your Personal Data and in some cases using third parties to do this);

to provide customer support;

to collect statistical or technical non-personalized data about the use of FinchPay’s website and the Service;

for the Our justified interest, for the purpose of fulfilling a contract, including for establishing violations of the contract or legislation, as well as to confirm such violations.

in order to comply with legal requirements.

If Personal Data processing is carried out in accordance with Our justified interests, You have a right to submit objections to such processes.

We do not store Your private keys, backup phrases, or passwords.

Personal data storage

We store Your Personal Data while it is necessary to process data, to protect Our interests, or on the grounds provided by legal acts requirements.

Depending on the type of Personal Data, We store data for the following time:

for accounting documents: 7 years from the end of the fiscal year in accordance with the Law;

within the period set by law, if any;

in other cases: 10 years after the agreement’s termination (including user agreement) between You and Company.

Cookies

Our Cookies Policy is available here

Security

We have implemented various technical and organizational measures to be compliant with applicable Personal Data, privacy, and data security legislation in the countries where We operate or where the applicable law applies to Us.

FinchPay is not responsible for the Personal Data protection measures violations if such violations are caused by actions performed by You or third persons.

Links to Third-Party Websites

The Service may contain links to other websites, which are outside Our control and are not covered by the Policy. If You access other sites using the links provided, including the case of using Third Party Services, the operators of these sites may collect information about You that will be used in accordance with their privacy policy, which may differ from Ours.

Your rights and obligations

In accordance with relevant legal acts (primarily – GDPR) You can exercise the following rights by contacting Us:

request access to Your own Personal Data;

request changes in Your own Personal Data;

request removal of Your own Personal Data;

submit objections to Your own Personal Data processing on any grounds.

FinchPay replies to Your requests and requirements within 1 month and notifies you about measures taken to perform provided requests and requirements. If Your request or requirement is too complicated or has a large volume FinchPay has a right to prolong the period for reply up to 2 months.

If the requests or requirements of the You are obviously not justified or excessive, primarily due to their repetitive nature, FinchPay has the right to refuse to perform requests or requirements.

You do not need to pay a fee to access information or other rights, but We may charge a reasonable fee if Your request is clearly unfounded, repetitive, excessive, or refuse to comply with your request in these circumstances.

In case when Personal Data is processed by Your consent, he/she always has a right to revoke his consent. If You revoke Your consent for Personal Data processing all the data processing performed before revoke considers to be legitimate and lawful.

You must notify Us about changes in Your contact details to keep them up to date.

In case of a violation of Your rights, You have a right to ask Personal Data Protection Inspectorate or court to protect Your rights.

Blockchain Transactions

Your blockchain transactions may be relayed through servers or nodes and will be publicly visible due to the public nature of distributed ledger systems.

Communication with Third-Party Servers

Exchange rates, balances, transactions, and other blockchain information may be read from or related to third-party servers. We cannot guarantee the privacy of your Internet connection.

Legal Limitations

Notwithstanding anything contrary to the Policy, We may preserve or disclose Your information if We believe that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our or our Users’ rights or property.

You acknowledge that the Website is not liable for any illegal or abusive use of your information. You acknowledge that in a case where You share Your information from the Website on social or other networks, or on other third-party sites and/or platforms, Your information is subject to the privacy policies of such third-party resources.

FinchPay may share Your Personal Data with law enforcement, data protection authorities, government officials, and other authorities only when FinchPay is legally bound to do so or has to protect the safety of its users and the Website.

Policy changing

The Policy can be changed to comply with changes in Law, Personal Data processing, or under instructions of supervisory authorities. In this case, FinchPay updates the Policy provided on the website and informs You about the changes when it is possible.

Contact details and questions

Any questions about this Policy, the processing of Personal Data, or data subject’s requests shall be directed to:

UAB FINCH TECHNOLOGIES (company code 306113100)

Address: Eišiškių Sodų 18-oji g. 11, Vilnius, 02194

Email: [email protected]