The Policy has been drafted in accordance with the Privacy Policy and governs the terms and conditions for the processing of customer data by Finexmo, (the “Terms”).
Finexmo (the “Company”) collects the Customer’s personal information if the Customer uses or wishes to use the Company’s services.
The Terms and Conditions apply from 25 May 2018, but also apply to the processing of Customer Data prior to that date.
General Terms and Conditions
These Terms and Conditions are available to Customers at https://finexmo.com/privacy-policy/
The Company has the right to amend the Terms and Conditions unilaterally at any time by notifying the Customer of any changes on the website. Unless a different date is stipulated, changes shall come into effect as soon as they are published on the website.
Definitions
Finexmo is a company by guarantee which provides business advisory services.
Client means an individual or entity who has used, uses or intends to use the services offered by Finexmo.
Personal Data – any information relating to the Client.
Client Data – any information about the Client which has been disclosed to Central Finexmo in connection with the Client’s use of Finexmo
Client Data Controller: Finexmo.
General data processing principles and types of data to be processed
3.1. Finexmo has the right to use employees to process Customer Data who have used, are using or intend to use the services offered by Finexmo. When transferring Customer Data to employees, Finexmo ensures that employees process customer data in accordance with the controller’s instructions, comply with confidentiality requirements and apply appropriate security measures.
3.2 Finexmo is guided by the applicable laws and takes necessary technical and organisational measures to ensure the security of Customer Data to prevent unlawful processing, access and disclosure to unauthorised persons.
3.3 Finexmo collects and processes only the following information relating to the services provided and the relationship with the Client:
3.3.1 Customer Data: details of the customer’s personal document (e.g. passport or ID card), name, personal identification code, date of birth and other personal data of the customer. Providing the relevant data for the purchase of services is mandatory, as it is not possible to provide services without providing the data;
3.3.2. the Customer’s contact information: address, telephone number, e-mail address;
3.3.3 Communication data: conversations about the provision of services, both by telephone and online environment, as well as other communication channels; as well as communication between Finexmo and the client by email or post.
3.3.4 Financial data: Personal bank account number and financial institution data (company name, address, telephone number, e-mail address and other data).
3.3.5 Service-related data: e.g. information, requests and complaints relating to the procurement of services, payments and consultations.
Purposes of customer data processing
Finexmo processes Customer Data in order to:
4.1 Provide high quality consulting services to the Client and manage client relationships.
Finexmo processes Customer Data for the purpose of entering into and executing a contract with the Customer.
4.2 Protect the legitimate interests of the Client and investigate the quality of the service.
4.3 Provide the Client with additional services, market analysis and statistical data, including making offers based on the Client’s consent or at the discretion of Finexmo to provide the best possible service to the Customer.
4.4 Prove and defend claims based on the fulfilment of a contract or other legal obligation or on the legitimate interests of Finexmo, e.g. to prepare legal claims, requests, etc.
4.5 Receive payments through payment service providers.
Persons entitled to receive Customer Data
5.1 Client Data may be shared and processed with the legal authorities in the European Union (e.g. notaries, bailiffs, judges and other officials) or another state for the purposes of the Client’s assignment.
5.2 Auditors, legal and financial advisors or other persons authorised by Finexmo.
Duration of data retention
6.1 Client Data will not be processed longer than necessary. The periods of service may be based on agreements with the Client, on the legitimate interests of Finexmo or applicable law (e.g. accounting laws, business regulations, other legal provisions).
Rights of private person
The client (private person) of Finexmo has the following rights with respect to the processing of personal data:
7.1 To apply for correction of inaccurate personal information if it is inadequate, inaccurate or incomplete;
7.2 Request information on whether Finexmo the Client’s personal information and access this data.
7.3 Withdraw consent to the processing of personal data;
7.4 Restrict the processing of personal data in accordance with applicable law, in particular when the Customer has applied to have his personal information corrected or deleted.
7.5 Request the deletion of his data, e.g. if the data is processed on the basis of consent and the Customer withdraws consent. Deletion of data cannot be requested if the personal information for which deletion is requested is also valid on other grounds, such as a contract or legal obligation.
7.6 Receive his personal information, which the Customer has provided and which is processed according to the agreement, in writing or electronically or, if technically possible, transfer the information to another provider (right of data transfer).
7.7 Submit objections to the processing of personal data
7.8. to submit a complaint against the processing of personal data to the Data Protection Inspectorate if the Customer believes that his personal data is processed unreasonably or in violation of the applicable laws and regulations.
Contact information
8.1 The Customer may contact Finexmo on any issues related to the processing of his personal information at the contact details listed on the website www.finexmo.com.