Privacy Policy

April 17, 2019

Introduction

Fintech Solutions SIA (we” or “us”) values its visitors’ privacy. This version of privacy policy is effective from 18.02.2019 and it summarizes what types of information we might collect from a registered user or other visitor (“you”), and what we will and will not do with the information collected. Please note that this privacy policy does not govern the collection and use of information by companies that Fintech Solutions SIA does not control, nor by individuals not employed or managed by Fintech Solutions SIA. If you visit a Web site that we mention or provide a link to, be sure to review its privacy policy before providing the site with information.

Controller

The controller responsible for processing your personal data in accordance with Article 4 (7) GDPR is:

SIA “Fintech Solutions”

Registration number 40203110273
Legal office: Duntes Street 6, Riga, LV-1013, Latvia

What personal information do we collect and why?

We are collecting your personal data in order to comply with the requirements of the International policy of “Know Your Customer” and “Anti Money Laundering and Fighting Against Terrorism” legislation. It is always up to you whether to disclose personal information to us, although if you elect not to do so, we reserve the right to refuse to provide you with any products or services. The amount of your personal data collected depends on the product or services in which you are interested.

We generally request the following documents from customers who are natural persons:

1) copy of passport or copy of ID card (the latter is applicable only to European citizens);
3) additionally, in some cases, we may request you to provide verification of your identity via vidеo call;
3) the documents that prove your residential address, for instance, could be a utility bill, personal bank statement or credit card statement (less than 3 months old) with clearly stated residential address;
4) contact details of the customer (phone number, e-mail address, fax);
5) contact details of all persons that will represent the customer (phone number, e-mail address, fax);
6) documents confirming the relevant level of experience (CV, professional certificates, etc.).

From customers who are legal persons, we may request information and documents about its authorized persons and beneficial owners.

We request the following documents from authorized persons:

1) copy of passport or copy of ID card (the latter is applicable only to European citizens);
2) additionally, in some cases, we may request verification of identity of authorized person via video call;
3) the documents that prove residential address, for instance, could be a utility bill, personal bank statement or credit card statement (less than 3 months old) with clearly stated residential address;
4) contact details of the authorized person (phone number, e-mail address, fax);
5) documents confirming the relevant level of experience (CV, professional certificates, etc.).

We need to get the following information from beneficial owners:

1) copy of passport or copy of ID card (the latter is applicable only to European citizens);
2) additionally, in some cases, we may request verification of the identity of Beneficial owner via vidеo call;
3) the documents that prove residential address, for instance, could be a utility bill, personal bank statement or credit card statement (less than 3 months old) with clearly stated residential address;
4) documents confirming beneficial owner’s good financial standing;
5) documents confirming the relevant level of experience (CV, professional certificates, etc.).

If the business activity of the customer is related to third parties’ money and falls under the requirements of the Anti-Money Laundering (AML) legislation, we request the following documents and information about the person who is responsible for AML issues:

1) the document confirming the appointment of the officer responsible for countering against money laundering (AML);
2) documents confirming the AML officer’s competence and responsibility for AML issues.

If you do provide personal information to us, either directly or through a reseller or other business partner, we will:

1) not sell or rent it to a third party without your permission;
2) we may use your contact information to provide you with information we believe you need to know or may find useful, such as (for example) news about our services and products and modifications to the Terms of Service;
3) take commercially reasonable precautions to protect the information from loss, misuse and unauthorized access, disclosure, alteration and destruction;
4) not use or disclose the information except:
• as necessary to provide services or products you have ordered;
• in other ways described in this privacy policy or to which you have otherwise consented;
• in the aggregate with other information in such a way so that your identity cannot reasonably be determined (for example, statistical compilations);
• as required by law, for example, in response to a subpoena or search warrant, to ensure accounting or to respond to legitimate requirements of governmental and municipal authorities;
• to outside auditors who have agreed to keep the information confidential;
• as necessary to enforce the Terms of Service;
• as necessary to protect the rights, safety, or property of Fintech Solutions SIA, its users, or others; this may include (for example) exchanging information with other organizations for fraud protection and/or risk reduction;
• to provide for the proof of business-related facts in a dispute, demand, claim or proceeding cases;
• to ensure protection of our legitimate interests or those of third parties, for example, while receiving the necessary legal or advisory assistance, complying with statutory notification obligation, etc.;

Other information we collect

We may collect other information that cannot be readily used to identify you, such as (for example) the domain name and IP address of your computer. We may use this information, individually or in the aggregate, for technical administration of our Web site(s); research and development; customer – and account administration; and to help us focus our marketing efforts more precisely.

Personal Data Sources

Personal data can be collected from you (as Data Subjects) and from external sources, such as public and private registers or third parties.

Cookies

Fintech Solutions SIA uses “cookies” to store personal data on your computer. We may also link information stored on your computer in cookies with personal data about specific individuals stored on our servers. If you set up your Web browser (for example, Internet Explorer or Firefox) so that cookies are not allowed, you might not be able to use some or all the features of our Web site(s).

Data storage

Personal data will only be processed for as long as necessary. The storage period may be based on a contract, our legitimate interests or the applicable regulatory enactments (for example, laws on accounting, extinctive prescription, civil rights, etc.). We may store your data on servers provided by third party hosting vendors with whom we have contracted.

We do not accept liability for any unauthorized access to personal data and/or personal data loss, if it does not depend on us, for example, due to your fault and/or neglect.

Usually, we process personal data in the European Union/European Economic Area (EU/EEA) and such data are not transferred and processed in non-EU/EEA countries, but we may need to transfer personal data to recipients outside the European Union. These activities can include dealings with the outsourcing of services to external providers located outside the EU and/or processing the data outside the EU (e.g. cloud computing, web-services), or when arranging staff work trips to non-EU countries.

According to the GDPR, such transfers are allowed when:

• the country’s protections are deemed adequate by the EU; or
• we take the necessary measures to provide appropriate safeguards, such as by including specific clauses in the contract concluded with the non-European importer of the personal data; or

we rely on specific grounds for the transfer (called ‘derogations’) such as the consent of the individual.

Who will process your data?

Your personal data will be or may be processed by:

• Fintech Solutions SIA staff who are specifically trained and authorised to process them;
• processors and third parties that we use to provide our services; these subjects have been adequately selected and offer a guarantee of compliance with the rules on the processing of personal data. These persons have been appointed as data processors and carry out their activities according to the instructions given by Fintech Solutions SIA and under its control.
The processors and third parties in question belong to the following categories: banking operators, internet providers, companies specialising in IT and telematic services; couriers; legal and financial advisers; companies that carry out marketing activities; companies specialising in market research and data processing.
• police and judicial and administrative authorities, in accordance with the law, for the detection and prosecution of crimes, the prevention and protection from threats to public security, to allow Fintech Soluitions SIA to ascertain, exercise or defend a right in court, as well as for other reasons related to the protection of the rights and freedoms of others.

Your rights

A data subject or their authorized representative has the following rights:

• to receive information on whether we process the personal data of the data subject and then access them if such are processed;
• to access their own personal data, based on a substantiated written request;
• if necessary, to modify, add or delete any personal data stored on them at any time, based on a substantiated written request;
• to transfer their own personal data from us to another controller, if it is technically possible;
• to object to the processing of personal data or to make us restrict processing in accordance with the requirements of the applicable regulatory enactments;
• not to be subject to fully automated decision making, including profiling, if taking such a decision has legal effects or a similar considerable effect on the data subject;
• at any time to withdraw their consent given to us for the processing of personal data;
• to address issues and complaints about the use of personal data to the Data State Inspectorate (dvi.gov.lv), if the data subject considers that the processing of their personal data violates their rights and interests in accordance with the applicable regulatory enactments.

Information collected from children

You must be at least 16 years old to use our Web site and service(s). Fintech Solutions SIA does not knowingly collect information from children under 16.

Data security

We secure our website and other systems through technical and organisational measures against loss, destruction, access, modification or distribution of your data by unauthorised persons. However, despite regular checks, complete protection against all risks is not possible.

Changes to this privacy policy

We reserve the right to change this privacy policy as we deem necessary or appropriate because of legal compliance requirements or changes in our business practices. If you have provided us with an email address, we will endeavor to notify you, by email to that address, of any material change to how we will use personally identifiable information.
Questions or comments?
If you have questions or comments about this privacy policy, send an email to info@universepay.eu, or contact us in any of the ways described in the About Us page at URL of company’s website.

Thank you for choosing Fintech Solutions SIA!

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