1. Important information and who we are
Purpose of this Privacy Policy
The purpose of this Privacy Policy is to provide you with specific information regarding how we collect and process your personal data when you visit our Sites, use our Services and any data you may provide when you use the Services, opt in to receiving communication from us in any form, contact us for any reason, or otherwise participate in and use our Services and systems in any form.
All Services are not intended for minors below the age of 18 years in any jurisdiction and we will not knowingly collect, process, or store data relating to minors or individuals under the age of majority in their jurisdiction.
It is important that you read this Privacy Policy carefully together with any other privacy policies or terms and conditions, we provide when we are collecting or processing your personal data.. This Privacy Policy supplements other policies and privacy notices and does not override or otherwise negate any other privacy notices you may have agreed to in the past or future while using our Services.
Note that we are in compliance with GDPR, CCPA, and PIPEDA among other global privacy legislation and take our obligations with regard to this seriously. You, as a Data Subject, have certain rights with regard to the collection and processing of your data including:
- The right to consent to usage of your data
- The right to have your data redacted, deleted or otherwise rendered useless
- The right to be excluded from automated processing of your data
- The right to access data we may hold about you
- The right to correct or rectify erroneous data
- The right to data portability to other providers
We take privacy and data subject rights seriously. Please email [email protected] for any questions about our privacy practices and policies.
Data Controllers
Connect Fintech Services S.A., a company incorporated under the laws of Panama, with a registered address: BICSA Financial Center – Floor 51 Suite 5102 Panama City, Panama, is the controller and is responsible for handling of your personal data, if you are a resident of the European Union, Singapore, Canada, or Australia.
Data Protection Officer, Complaints and Contact details
Connent Services has appointed a Data Protection Officer (DPO) that is responsible for overseeing questions in relation to our privacy and data protection practices. If you have any questions or concerns contact our team directly at: [email protected]
Complaints
You have the right to contact our Compliance team at any time to discuss the processing of your personal data. Where a formal complaint has been lodged our team will:
- Respond within 30 days in writing
- Evaluate your complaint carefully with regard to our Terms & Conditions, this privacy policy, and other relevant documents
- Provide a final disposition/response within 60 calendar days of receiving your complaint
Changes
Our Privacy Policy is regularly reviewed and updated by our team. This version was last updated on the date above. Existing members are always notified of changes to this policy according to the contact settings they configure in the app.
We are required to keep up to date information on all of our users as part of the nature of services we provide. Please ensure your personal information is up to date in our app at all times.
Third-party links
The Site and App may include links to third-party websites, plug-ins and applications ("Third Party Sites"). Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these Third-Party Sites and are not responsible for their privacy statements. When you leave our Site or App, we encourage you to read the privacy notice of every Third Party Site you visit or use.
2. Personal Data We Collect
Personal data or information, means any information about an individual or entity that may be used to identify that person, it does not include anonymous data that does not correspond to an identity.
Data we collect includes, but is not limited to:
- Identity data
- First and last name
- Username
- Date of birth
- Gender
- Visual image(s) of your face (selfie)
- SSN, SIN, VAT, or equivalent tax identifier
- Identity documents including
- License
- Passport
- Utility bill
- Bank statement
- Contact data
- Address
- Email address
- Telephone number
- Financial information
- Bank information
- Payment card information
- Crypto/wallet addresses
- Additional alternative payment method/ewallet data
- Transaction information
- Your history of usage on our platform including all movement of crypto and fiat funds in and out
- Technical information
- IP addresses
- Username/password used at login
- Browser information
- Operating system and platform
- Time zone and geolocation
3. How is data collected and processed?
We use different methods to collect data from and about you including through:
During Signup and Usage. During registration and time to time thereafter you may be required to, or voluntarily provide, your personal and identity information and technical information about the machines and devices you use to access our Services.
Third Parties and Public Information. During registration and throughout the lifetime of your usage of our services we utilize third party providers such as fraud prevention services, sanctions screening services, social media data aggregators, and other to validate the information you provide.
4. Using Your Personal Data
We only use identity and personal information as legally permitted. Commonly this includes:
- As a condition for providing you the Services
- Where required by law
- When we are subject to a subpoena or other third-party request for information
During registration, and after, you provide and reaffirm your consent to the usage of your personal information. This includes configuring contact preferences to receive updates from us including promotions, marketing, and so on. Note that you may update your contact preferences at any time.
How we Use Your Data
We use your data, as provided by you under your consent, for a number of reasons including:
- Verifying your identity during registration
- Process your instructions and transactions during usage of the app
- Contacting you per your preferred contact methods and preferences
- Sending you receipts and confirmations of transactions according to your preferences
- Manage risk and deter crime
Marketing and Promotions
We will use your contact details to send you marketing and promotion material as allowed by your usage and communication preferences.
Third Parties
We do not share your information with any third party without your consent except as required by law.
Opting out
You may opt out of marketing and other communications at any time within the app. We will continue to provide receipts and other confirmations of your usage of the platform throughout your usage.
Cookies
We use cookies to optimize our Services and our provision of same to you. You may disable or refuse cookies however this may impact your usage of the services. We accept no responsibility or liability for limitations on your usage caused by your refusal of cookies.
Changes
We only use your personal data for the purposes outlined here as consented to by you. If we plan a material change to usage of your personal and identity information you will be notified of same.
5. Disclosures
We only use your personal, identity, financial, and contact information as part of providing you with the Services and only under your consent to do so. This includes disclosure to third parties, employees, contractors, and subcontractors.
We may share your data with the following entities:
- Companies and entities that aid us in processing transactions on our platform and the Connect branded payment card
- Identity verification, fraud prevention, sanctions screening and other entities that assist us in complying with regulations
- Outsourced customer support providers
- Regulatory and law enforcement authorities
6. Cross Border Transfers
We may transfer data among companies within our group or to third parties as outlined above. This is only done per this policy under your consent and as dictated by your usage.
7. Security
We have implemented multiple security and protection measures to ensure your data is secure. Additionally, no internal staff may access more of your data than required to do their job. This includes no staff member having access to your 16 digit account number if you use our branded card.
We anonymize and encrypt all personal data in our system.
We comply with breach legislation to the extent we are required in jurisdictions we are bound by.
8. Data Retention
We will retain your data, under your consent, for the lifetime of your usage of the platform OR for 5 years after you cease to use the platform, whichever comes first.
Where you request your data be deleted or redacted we will retain data as required to meet our legal obligations BUT will encrypt it so as to be unusable.