FinQTech™ Privacy Policy
Introduction
Welcome to our privacy policy.
We respect your privacy and we are committed to protecting your personal data. This policy describes the ways FinQTech™, Co., hereinafter, “FinQTech™”, “we”, “our” or “us”) collect, store, use and protect Personal Data. This privacy policy will inform you as to how we look after your personal data when using our Services (as defined in the finqtech.com, https://finqtech.com/new-card-landing.com , the FinQTech™ and Quantum Shield™ Quantum Bits™ /Qbits™ phone apps and other sites owned by FinQTech™, Co. (“Sites”) Terms and Conditions (“T&Cs”)) or when visiting our Sites. Unless otherwise stated, defined terms used in this privacy policy shall have the same meanings given to them as the T&Cs.
The purpose of this policy is to
ensure that FinQTech™ complies with applicable United States (US)
federal and state regulations, and European Union (hereinafter, “EU”)
data protection laws such as the General Data Protection Regulation
(hereinafter, “GDPR”). FinQTech™’s Services include blockchain as a
service, products, or any other features, technologies or
functionalities (hereinafter: “Services”) offered by FinQTech™. Users
accept this Policy by visiting our website and/or by using our Services.
This privacy policy tells you
about your privacy rights and how the law protects you. Please also use
the Glossary to understand the meaning of some of the terms used in
this privacy policy.
IMPORTANT INFORMATION AND WHO WE ARE
THE DATA WE COLLECT ABOUT YOU
HOW IS YOUR PERSONAL DATA COLLECTED?
HOW WE USE YOUR PERSONAL DATA
DISCLOSURES OF YOUR PERSONAL DATA
INTERNATIONAL TRANSFERS
DATA SECURITY
DATA RETENTION
YOUR LEGAL RIGHTS
GLOSSARY
Purpose of this privacy policy
This privacy policy aims to give you information on how we
collect and process your personal data when you visit our Sites, and any
data you may provide when you register for or use our Services, sign up
for alerts or newsletters,
contact us with a question or request for help, participate in
any renewals, promotions or surveys.
The Sites are not intended for minors below 18 and we do not knowingly collect data relating to minors.
It is important that you read this privacy policy together with
any other privacy policy or fair processing policy, we may provide on
specific occasions when we are collecting or processing personal data
about you so that you are
fully aware of how and why we are using your data. This privacy
policy supplements other notices and privacy policies and is not
intended to override them.
Controller
FinQTech™, Co., a company incorporated in Florida, United States
of America, is the controller and responsible for your personal data
(together with its affiliates collectively referred to as “we“, “us”
or “our” in this privacy policy).
Contact details
To communicate with our Data Protection Officer, please
email finqtech@protonmail.com Subject to applicable law, you also have
the right to lodge a complaint with your local Data Protection
Authority. If you are residing
within the European Union and believe we maintain your Personal
Data within the scope of the GDPR, you may direct questions or
complaints to our lead supervisory authority.
Changes to the privacy policy and your duty to inform us of changes
We keep our privacy policy under regular review. This version was
last updated on the date above written. If we change our privacy policy
and you have already registered with us we will let you know in advance
by email.
It is important that the personal data we hold about you is
accurate and current. Please keep us informed if your personal data
changes during your relationship with us.
Third-party links
The Sites 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 Sites , we
encourage you to read the privacy policy of every Third Party Site you
visit or use. Any
use of Third Party Sites are the responsibility of the User.
The data we collect about you
Personal data, or personal information, means any information
about an individual from which that person can be identified. It does
not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
Identity Data includes first name, maiden name,
last name, username or similar identifier, marital status, title, date
of birth and gender, a visual image of your face, tax identification
number, national
identity cards, passports or other form of identification
documents including proof of address such as a utility bill or bank
statement.
Contact Data includes billing address, delivery address, home address, work address, email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments
to and from you and other details of any transactions you enter into
using products and services you have purchased from us.
Investment Data includes information about your investment objectives, investment experience and prior investments.
Technical Data includes internet protocol (IP)
address, your login data, browser type and version, time zone setting
and location data, browser plug-in types and versions, operating system
and platform, and other technology or information stored on the
devices you allow us access to when you visit the Sites, such as friends
lists or other digital content.
Profile Data includes your username and
password, requests by you for products or services, your interests,
preferences, feedback and survey responses.
Usage Data includes information about how you use our Sites, app, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
As explained above under Identity Data, we may
also collect a visual image of your face which we will use, in
conjunction with our sub-contractors, to check your identity for
onboarding purposes. This data
falls within the scope of special categories of data (see
Special Categories of Data below). When we ask to collect a visual image
of your face you will be asked for your specific consent. You can
refuse to provide this but
it means that we may be unable to register you and provide you
with our Services.
In addition, the law also treats certain other categories of
personal information as special. This includes details about your race
or ethnicity, religious or philosophical beliefs, sex life, sexual
orientation, political opinions,
trade union membership, information about your health, genetic
and biometric data, as well as details of criminal records. We will not
collect or use these types of data (known as Special Categories of Data)
without your consent
unless the law allows us to. If we do, it will only be when it
is necessary:
for reasons of substantial public interest (for example to use
criminal records to help prevent, detect, and prosecute unlawful acts
and fraudulent behaviour); or
We also collect, use and share Aggregated Data such
as statistical or demographic data for any purpose. Aggregated Data
could be derived from your personal data but is not considered personal
data in
law as this data will not directly or
indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific
website feature. However,
if we combine or connect Aggregated Data with your personal data
so that it can directly or indirectly identify you, we treat the
combined data as personal data which will be used in accordance with
this privacy policy.
If you refuse to provide personal data
Where we need to collect personal data by law, or under the terms
of a contract we have with you, and you refuse to provide that data
when requested, we may not be able to perform the contract we have or
are trying to enter into
with you (for example, to provide you services). In this case,
we may have to cancel a product or service you have with us but we will
notify you if this is the case at the time.
How is your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your
Identity, Contact and Financial Data by filling in forms, providing a
visual image of yourself via the Sites, by email or otherwise. This
includes personal data you provide
when you:
apply for our products or services;
create an account on our Sites;
subscribe to our service or publications;
make use of our Services;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you
interact with us via our Sites, we will automatically collect Technical
Data about your equipment, browsing actions and patterns. We collect
this personal data by
using cookies, server logs and other similar technologies. We
will also collect Transaction Data and Investment Data. We may also
receive Technical Data about you if you visit other websites employing
our cookies. Please refer
to our main website, where you can access the Cookie Consent
banner for more details.
Third parties or publicly available sources. We
also obtain information about you from third parties (such as employers,
credit reference agencies and fraud prevention agencies) who may check
your personal data
against any information listed on other databases.
How we use your personal data
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following
circumstances:
Where we need to perform the Sites T&Cs we are about to enter into or have entered into with you.
For the provision of our Services.
Where it is necessary for our legitimate interests (or those of a
third party) and your interests and fundamental rights do not override
those interests.
Where we need to comply with a legal obligation.
Please refer to the GLOSSARY, LAWFUL BASIS sections to find out
more about the types of lawful basis that we will rely on to process
your personal data.
Generally, we do not rely on consent as a legal basis for
processing your personal data although we will get your consent before
sending third party direct marketing communications to you via email or
text message. You have the
right to withdraw consent to marketing at any time by contacting
us.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all
the ways we plan to use your personal data, and which of the legal bases
we rely on to do so. We have also identified what our legitimate
interests are where appropriate.
Note that we may process your personal data for more than one
lawful ground depending on the specific purpose for which we are using
your data. Please contact us if you need details about the specific
legal ground we are relying
on to process your personal data where more than one ground has
been set out in the table below.
| Purpose/Activity |
Type of data |
Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| To register you as a new customer |
Identity Contact Financial |
Performance of a contract with you Necessary to comply with a legal obligation (to comply with rules and guidance from regulators). |
| To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us |
Identity Contact Financial Transaction Technical Marketing and Communications |
Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey |
Identity Contact Profile Transaction Marketing and Communications |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To manage risk and crime prevention including: Detect, investigate, report and prevent financial crimeobey laws and regulations which apply to usresponding to complaints and resolving them |
Identity Contact Financial Technical Transactional Investment Data |
Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to develop and improve how we deal with financial crime) |
| To enable you to partake in a prize draw, competition or complete a survey | Identity Contact Financial Technical Transactional Investment Data |
Necessary for our legitimate interests (for
running our business, provision of administration and IT services,
network security, to prevent fraud and in the context of a business
reorganisation or group restructuring
exercise) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Profile Usage Marketing and Communications Technical |
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage |
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity Contact Technical Usage Profile Marketing and Communications Investment Data |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your Identity, Contact, Technical, Transactional,
Usage and Profile Data to form a view on what we think you may want or
need, or what may be of interest to you. This is how we decide which
products, services and offers
may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have
requested information from us or purchased from us and you have not
opted out of receiving that marketing.
Third-party marketing
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out
You can ask us or third parties to stop sending you marketing
messages at any time by following the opt-out links on any marketing
message sent to you.
Where you opt out of receiving these marketing messages, this
will not apply to personal data provided to us as a result of a
product/service purchase, warranty registration, product/service
experience or other transactions.
Cookies
You can set your browser to refuse all or some browser cookies,
or to alert you when websites set or access cookies. If you disable or
refuse cookies, please note that some parts of the Sites may become
inaccessible or not function
properly. For more information about the cookies we use, please
see refer to our main website, where you can access the Cookie Consent
banner for more details.
Change of purpose
We will only use your personal data for the purposes for which we
collected it, unless we reasonably consider that we need to use it for
another reason and that reason is compatible with the original purpose.
If you wish to get
an explanation as to how the processing for the new purpose is
compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we
will notify you and we will explain the legal basis which allows us to
do so.
Please note that we may process your personal data without your
knowledge or consent, in compliance with the above rules, where this is
required or permitted by law.
Disclosures of your personal data
We may share your Personal Data with:
Other FinQTech™ entities, in order to help detect and prevent
potentially illegal acts and violations of our policies, and to guide
decisions about our products, services and communications;
Service providers under contract who help with our business
operations. We will make sure that these third parties have appropriate
internal controls in place to protect any Personal Data that might be
transferred;
Law enforcement, government officials, or other third parties
pursuant to a subpoena, court order, or other legal process or
requirement applicable to FinQTech™, Co.; or when we believe, in our
sole discretion, that the disclosure of Personal
Data is necessary to report suspected illegal activity or to
investigate violations of our Terms of Use.
In cases of suspected fraud or in connection with an ongoing
investigation, we may share certain shopper information with our
merchants.
Please note that these third parties may be in other countries
where the laws on processing Personal Data may be less stringent than in
your country. We deploy the following safeguards if we transfer
Personal Data originating from
the European Union or Switzerland to other countries not deemed
adequate under applicable data protection law:
Data security
We have put in place appropriate security measures to prevent
your personal data from being accidentally lost, used or accessed in an
unauthorised way, altered or disclosed. In addition, we limit access to
your personal data to
those employees, agents, contractors and other third parties who
have a business need to know. They will only process your personal data
on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected
personal data breach and will notify you and any applicable regulator of
a breach where we are legally required to do so.
Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably
necessary to fulfil the purposes we collected it for, including for the
purposes of satisfying any legal, regulatory, tax, accounting or
reporting requirements. We
may retain your personal data for a longer period in the event
of a complaint or if we reasonably believe there is a prospect of
litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data,
we consider the amount, nature and sensitivity of the personal data, the
potential risk of harm from unauthorised use or disclosure of your
personal data, the purposes
for which we process your personal data and whether we can
achieve those purposes through other means, and the applicable legal,
regulatory, tax, accounting or other requirements.
By law, we may be required to keep basic information about our
customers (including Contact, Identity, Financial and Transaction Data)
for at least 5 years after they cease being customers for regulatory
purposes.
In some circumstances, you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so
that it can no longer be associated with you) for research or
statistical purposes, in which case we may use this information
indefinitely without further notice to
you.
Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data:
Request access to your personal data.
Request correction of your personal data.
Request erasure of your personal data.
Object to the processing of your personal data.
Request restriction of processing your personal
data.
Request transfer of your personal data.
Right to withdraw consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or
to exercise any of the other rights). However, we may charge a
reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we could
refuse to comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us
confirm your identity and ensure your right to access your personal data
(or to exercise any of your other rights). This is a security measure
to ensure that personal
data is not disclosed to any person who has no right to receive
it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month.
Occasionally, it could take us longer than a month if your request is
particularly complex or you have made a number of requests. In this
case, we will notify you and
keep you updated.
Glossary
LAWFUL BASIS
Legitimate Interest means the interest of our
business in conducting and managing our business to enable us to give
you the best service/product and the best and most secure experience. We
make sure we consider
and balance any potential impact on you (both positive and
negative) and your rights before we process your personal data for our
legitimate interests. We do not use your personal data for activities
where our interests are
overridden by the impact on you (unless we have your consent or
are otherwise required or permitted to by law). You can obtain further
information about how we assess our legitimate interests against any
potential impact on
you in respect of specific activities by contacting us.
Performance of Contract means processing your
data where it is necessary for the performance of a contract to which
you are a party or to take steps at your request before entering into
such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
YOUR LEGAL RIGHTS
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request“). This enables you to receive a copy of the personal data we hold about you and to check that we are
lawfully processing it.
Request correction of the personal data that we
hold about you. This enables you to have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the
accuracy of the new
data you provide to us.
Request erasure of your personal data. This
enables you to ask us to delete or remove personal data where there is
no good reason for us continuing to process it. You also have the right
to ask us to delete
or remove your personal data where you have successfully
exercised your right to object to processing (see below), where we may
have processed your information unlawfully or where we are required to
erase your personal data
to comply with local law. Note, however, that we may not always
be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of
your request.
Object to processing of your personal data where
we are relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you want
to object to
processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where
we are processing your personal data for direct marketing purposes. In
some cases, we may demonstrate
that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
If you want us to establish the data’s accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise
or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to
you or to a third party. We will provide to you, or a third party you
have chosen, your personal data in a structured, commonly used,
machine-readable format.
Note that this right only applies to automated information which
you initially provided consent for us to use or where we used the
information to perform a contract with you.
