This privacy policy (“Privacy Policy”) regulates the processing of your personal data as a part of your use of our Website and the related services. The data controller collecting the data described herein is Finwise Ltd, which has its registered office at 25 Holmwood, Brennanstown Road, Dublin, D18 RX49, Ireland (also referred to hereinafter as “we” and “us”), registered in Dublin with company number 657924, in accordance with the applicable legislation on the protection of personal data.
By using our Website and/or our Services, you agree that you have carefully read this Privacy Policy and that you agree with it unreservedly. We reserve the right to regularly amend the Privacy Policy as we deem fit. Such amendment shall be communicated via the Website. “Cookies” or similar technology can be used as a component of the Website or services. Cookies are text files that are put on the hard disk of a device and that contain certain information, sometimes including personal data. You can find more information regarding the use of cookies in our cookie policy. Visitors are also able to send email through the site. Their messages will contain the user’s screen name and email address, as well as any additional information the user may wish to include in the message. If we intend to use your personal information to inform you about other services, we will notify you and give you an opportunity to decline to receive such communications.
What data do we process and why?
- We process personal data relating to you when you use the Website and/or Services:
- When? Use of the Website or Contact form
- Which? Identity of private individuals
- Why (aim)? To process a request
- On what legal grounds? Legitimate interest
- When? To contact us
- Which? Identity of private individuals
- Why (aim)? To later contact the person or send related information and supplements
- On what legal grounds? Permission
- In principle, we obtain the above-mentioned personal data directly from the visitor. We can also process your personal data in addition to the list above:
- to provide you with information on products and services that you request in a personalized and efficient manner, either via the Website, by email, by telephone or through social media channels;
- to process your personal data so that we can provide you with the correct service provision;
- for direct marketing purposes, i.e. to be able to provide you with targeted communication, promotions, offers and other advertisements that we would like to share with you. We will ask your permission for this;
- to provide to a financial institution or payment service provider, to enable your bank and the payment service provider to fulfil their obligations;
- to transmit to the police or judicial authorities as proof of possible crimes or, if there are any founded suspicious grounds of an unlawful act or crime committed by means of your registration with, or use of, the Website or Services;
- within the scope of a possible merger with, acquisition of/by means of or demerger by a third party, even if such third party is located outside the EEA;
- if and when your registration on the Website or use of the Website or services can be regarded as (a) a breach of the conditions or the property rights, (b) a threat to the security or integrity of our service provision, (c) a danger for the Website, Services or systems belonging to us or to our subcontractors as a result of viruses, Trojan horses, spyware, malware or any other form of malicious code, or (d) being in any manner whatsoever illegal or unlawful, discriminatory or insulting, we may process your data in our own interests and in the interests of our partners or third persons.
Do we share your data?
- We do not send your personal data in an identifiable manner to third persons if this is not necessary to provide the services without your express permission to do so.
- We can engage external processors to provide you with a Website that is as good as possible. We ensure that third-party processors may only process your personal data in our name and pursuant to our written instructions.
Where do we process data?
- We personally and our external processors will only process your identifiable personal data in the European Area.
How do we process data?
- We will do our utmost to process only your personal data that are necessary to achieve the aims stated in this policy. We will process your personal data lawfully and transparently. We will also do our very best to keep your personal data accurate and up to date.
- Your personal data will only be processed until the moment at which you withdraw your permission for the processing. Such permission withdrawal can imply that you are no longer able to use all or part of the Website services. If you have registered on our Website, we will remove your personal data if you remove your profile, unless a statutory or regulatory obligation or judicial or administrative order prevents that.
- We will take the appropriate technical and organisational measures to keep your personal data secured against unlawful access or theft and against unintentional loss, manipulation or destruction. Access by our personnel or personnel of our external processors shall only be possible on a need-to-know basis and is subject to strict obligations of confidentiality.
Your rights regarding personal data
- You have the right to request access to any personal data that we process about you. Requests that are clearly submitted with a view to causing us inconvenience or damage will not be dealt with, however.
- You have the right to request that any incorrect or inaccurate personal data about you are corrected free of charge.
- You have the right to withdraw permission previously granted for the processing of your personal data. This can be done be sending an email to info@finwise.com.
- Instead of withdrawing, you can also request us to limit the processing of your personal data if (a) you dispute the correctness of such data, (b) the processing is unlawful or (c) the data are no longer needed for the purposes stated but you need them to defend yourself in judicial proceedings.
- You have the right to object to the data processing if you can show that there are serious and legitimate reasons relating to special circumstances and that these justify such objection. However, if the intended processing is regarded as direct marketing, you have the right to object to such processing free of charge and without any justification.
- You can receive the personal data you provided in a structured format if they are processed on the grounds of permission or a contract and they are processed by automatic resources.
- Send an email to info@finwise.com if you want to submit a request to exercise one or more of the above-mentioned rights. It must be clearly stated in such request what right you wish to exercise and why. This must also be dated, signed, and accompanied by a digitally scanned copy of your identity card. If it appears that the request is founded, we will grant it as quickly as is reasonably possible and no later than thirty (30) days after we have received it.
- You can always contact us if you have a problem with our processing of your personal data. You can file a complaint with the competent Data Protection Authority, i.e. the Belgian Privacy Commission, if you are still dissatisfied with our response.