Privacy notice

Last update: April, 2024

General Information

This Privacy Notice (the “Privacy Notice”) explains how VERIDAN AXIS GROUP LTD, a company incorporated in the Republic of Cyprus with the registered office at Fysco Lotus Plaza, Flat 406, 8 Valter Gkropious 8, Limassol 3076, Cyprus, registration No. HE459899 , operating under the brand “FINTIKO”, (the “COMPANY”) manages the personal information it collects, uses and discloses. Personal information means information about an identifiable individual. Personal information does not include aggregate information that cannot be associated with a specific individual, and in certain jurisdictions, it may also exclude business contact information.

In this Privacy Notice, “You” and “Your” shall refer to THE COMPANY Customers who may provide personal information to the COMPANY and “We”, “Us”, “Our” and “Ourselves” shall refer to the COMPANY.

We respect Your privacy, protect and process Your personal data in accordance with the rules of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter – “GDPR”) Law providing for the Protection of Natural Persons with regard to the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018) of the Republic of Cyprus and other applicable regulatory enactments (“Data protection regulation”).

This Privacy Notice outlines the principles and the detailed practices We follow in protecting and managing Your personal information. This includes personal information We collect from customers or prospective customers of the COMPANY (“Customers”). This includes the personal information We collect when You access or use our website www.fintiko.com (the ”Website”), product, and services (collectively, the “Services”); or when You otherwise interact with Us. This Privacy Notice does not apply to information that is not personal information. This Privacy Notice does not apply to Websites that You may be able to access via links on Our Website and/or activities offered by third parties. We are not responsible for the collection or use of Your personal data from these third party Websites. Please ensure You review any relevant policies on these sites.

The COMPANY is committed to protecting Your privacy and will take all appropriate steps to ensure that Your personal data is treated securely and will be collected, used, stored and disclosed in accordance with this Privacy Notice. This Privacy Notice (together with our Terms and Conditions applying to any specific services You may purchase or use) applies to (together these are all referred in this Privacy Notice as “Services” or “Our Services”):

to the Website features and services provided to You when You visit Our Website, portals or Our payment gateway our customers may use on their Websites;
when You apply to use and/or use the COMPANY products and services, as Well as when You request changes to the services You are using;
to Your use of software including terminals, mobile and desktop applications provided by the COMPANY; and to email, other electronic messages including SMS, telephone, Web chat, Website/portal and other communications betWeen You and the COMPANY.

Collecting and holding your information

We collect and store the following information through the following means:

Information You provide Us when You or Your business contact Us for or apply for Our Services; register and/or use any of Our Services; upload and/or store information with us using Our Services; and when

You communicate with us through email, SMS, Our Website or payment gateway, or the telephone or other electronic means, e.g., in the context of contacting us about Your account or transactions.

Information we collect may include:

An individual’s identification data, such as name, surname, personal identity number, date and place of birth, identification document data (such as passport copy, ID card, photo, short video of individual and selfie) or another document containing personal data;
An individual’s contact details (postal address, phone, email, Skype name, IP address, communication language with the customer, etc.);
Data on tax residency (for example, nationality, country of residence, tax residence, taxpayer number, social insurance number);
Data of related persons (for example, representatives and authorised persons of customer, employees, heirs, guarantors and other related persons of customers);
Financial and Wealth origin data such as accounts, income, ownership, transactions, commitments, data on the customer’s counterparties and personal activities (information on accounts, payments made, agreement and invoice copies, information on business activities, origin of funds, certificates of income, loans and other liabilities, information on accounts with other credit institutions);
Professional data such as education or professional career (for example, information on salary, previous places of employment, education etc.);
Audio / visual data (for example, records of phone conversations of the COMPANY and customers, records of surveillance cameras placed in objects belonging to the COMPANY and areas adjacent to them), communication data collected when the customer visits the COMPANY, or communicates with the COMPANY, email and other communications data obtained from visiting Our Website.
Information We collect about You automatically when You interact with the COMPANY (for example by way of “cookies” or similar technology; for more information see Our Cookie Notice).
Technical information, including the Internet protocol (IP) address used to connect Your computer or device to the Internet, Your login information, browser type and version, equipment type, time zone setting, browser plug-in types and versions, operating system platform, frequency and length of visits, and what links You click on;

When You apply for Our services, We search your records at fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil Our legal obligations. We may also collect information about you from public sources for AML reasons or market research. This includes:

Official public records, like Company registers, and other relevant third parties;
Information published by the press or on social media.

If You give Us information about other individuals, You must have informed them in advance (for example, by obtaining their consent and providing them this Privacy Notice) and You must ensure You have the right to do so.

Legal basis for personal data processing

The main legal basis of Personal data processing are:

Your consent to the Personal data processing;
Conclusion and performance of the contract with You or Your customer;
Fulfilment of legal obligations under applicable legislation;
Our legitimate interests

We collect and process Your Personal data only for legitimate purposes in accordance with Data protection regulation. While processing Your Personal data We will comply with Data protection regulation, which means that Your Personal data will be used lawfully, fairly and in a transparent way; relevant to the purposes We have informed You about and limited only to those purposes; accurate and kept up to date; maintained only for as long as necessary for the purposes We have informed You about; kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organizational measures.

We perform processing of data for the following purposes:

Compliance with legal acts;
Identification, due diligence and monitoring of individuals;
Performance of a contract and provision of services;
Management of relationship with clients, partners and other related persons;
Ensuring physical and information security and protection of Our and clients’ interests;
Risk management and personnel management;
Commercial communications, promoted marketing campaigns and similar activities

Limiting use, disclosure and retention

We will use or disclose Your personal information only for the purposes for which it was collected, except with Your consent or as required or permitted by law. We will retain your personal information as long as necessary for the fulfilment of those purposes, subject to statutory or regulatory retention requirements and legitimate business reasons.

In the course of daily operations, access to personal and other sensitive information is restricted to authorized employees who have legitimate business purposes for accessing it.

We do not license, sell, rent or trade Your personal information to third parties unless it is necessary to provide You with requested services and You authorize or consent to the disclosure, or when such disclosure is otherwise described in this Privacy Notice or permitted or required by law.

We may disclose or share Your personal information with third parties in situations where:

We have Your consent;
The third parties are (a) Our suppliers or partners who assist us in providing, maintaining, and improving Services; and (b) financial institutions, processors, payment card associations, and other entities that are part of the payment process;
We are required or permitted to do so by law or applicable regulators and self-regulatory organizations; and
Merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of Our business is involved.

In such situations, the COMPANY only shares the personal information with third parties for appropriate purposes in providing the requested products and services to Customers. Additionally, We use contractual means to ensure that personal information shared with third parties is provided with comparable levels of protection and management as provided under this Privacy Notice. It is possible such third parties are subject to their own respective jurisdictions.

We retain your personal information as long as necessary for the fulfilment of the identified purpose(s). We make reasonable efforts to ensure that personal information, which is no longer required to be retained, is disposed of or destroyed in a secure manner.

Your rights

You can exercise your rights in relation to your Personal data in accordance to the relevant data protection legislation. In total, you have right to: access, correction, delete, limitation of data processing, transfer, objection on processing, objection on profiling, consent withdraw and complaint to the data protection authority. If you have any questions in relation to our use of your Personal data, contact us.

Your exercise of these rights is subject to certain exemptions to safeguard the public interest, e.g., the prevention or detection of crime, and our interests, e.g., the maintenance of legal privilege. If you exercise any of these rights, we will check your entitlement and respond in within a month.

Where we store your data

We may transfer and store the data we collect from you to organisations outside the European Economic Area (EEA). When we do this, we make sure that your data is protected and that:

The European Commission says the country or organisation has adequate data protection, or
We’ve agreed to standard data protection clauses approved by the European Commission with the organisation.

How we protect your data

We comply with Our obligations under the applicable Data protection regulation by:

Keeping Personal data up to date;
Storing and destroying it securely;
Not collecting or retaining excessive amounts of data;
Protecting Personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical and organizational measures are in place to protect personal data.

The transmission of information via the internet is not completely secure. Although We will do Our best to protect Your Personal data, We cannot guarantee the security of Your Personal data transmitted to Our Website, unless You are communicating with us through a secure channel that We have provided. Once We have received Your Personal data, We will use strict procedures and security features to try to prevent unauthorised access.

How long we keep your data

Your Personal data is stored for as long as its storage is required for appropriate purposes for the processing of Personal data, as Well as in accordance with the applicable Data protection regulation.

Personal data storage periods shall be determined based on applicable legal acts or Our legitimate interests.

Personal data may be stored in an electronic form and/or in paper format, provided always that Your Personal data will be stored securely and protected against unauthorized or unlawful processing and against loss or destruction, using appropriate technical and organizational measures.

When assessing the length of the storage of Personal data, We consider existing regulatory requirements, aspects of contractual performance, Your instructions, e.g., in case of consent, and Our legitimate interests. If Your Personal data is no longer needed for the purposes specified, We will delete it or destroy it.

Automated decision making and profiling

Profiling carried out by us involves processing of Personal data by automated means for the purposes of legislation relating to risk management and continuous and periodic monitoring of transactions in order to prevent fraud, money-laundering and terrorist financing events. However, We do not make automatic decisions based on profiling.

For direct marketing and statistical analysis, profiling may be carried out by using Google, LinkedIn, Facebook and other analytics tools.

The main legal basis of Personal data processing for these purposes is conclusion and performance of the contract with You, fulfilment of Our legal obligations and/or Our legitimate interests, such as managing risks related with the client and its transactions.

Use of services by minors

Consistent with this Notice, We will not knowingly collect Personal data from anyone under the age of 18 (eighteen), and no part of Our Website or Our Service is designed to attract anyone under the age of 18 (eighteen). Because We do not intentionally collect any information about individuals under the age of 18 (eighteen), We also do not knowingly distribute such information to third parties. If You have reason to believe that a person under the age of 18 (eighteen) has provided Us with Personal data or is otherwise using or seeking to use Our Website and/or Service, please contact Us and We will immediately delete such information or terminate such Service, subject to Our compliance with applicable law and regulation.

Updates

We may update, change or replace any part of this Privacy Notice from time to time to ensure that it remains accurate by posting updates, amendments and/or alterations (all collectively “changes”) on Our Website. Please check back from to time to time for changes. If You continue to use and/or access the Website following the posting of any changes, this automatically constitutes acceptance of those changes. In the event You disagree with any changes You shall immediately terminate the use of Our Website and/or Services.

Contact us

You may contact Us at any time and submit Your questions, requests and complaints via email: info@fintiko.com.