Privacy Policy
Last updated: 9. February 2024
Last updated: 9. February 2024
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.
For the purpose of processing your personal data, the Company (we)
Floin AG, Äulestrasse 45, 9490 Vaduz, Liechtenstein
acts like Controller regarding the processing of your personal data
To better serve your privacy, we have appointed a Data Protection Officer (DPO), which is reachable through e-mail address [email protected] or at the postal address Floin AG (for DPO), Äulestrasse 45, 9490 Vaduz, Liechtenstein.
Interpretation
The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access our Service or parts of our Service.
Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to the Controller as defined in first chapter.
Cookies are small pieces of data that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
Country refers to any country member of EU or EEA.
Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.
Personal Data is any information that relates to an identified or identifiable individual.
Service refers to the Website.
Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Website refers to Floin, accessible from https://floin.com, https://floin.io, https://floin.de and all of its subsites (subdomains).
You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
General personal Data
While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:
Contact information, such as name, home or business address, email address and telephone number
Account information, such as username, password, Account settings and preferences
Financial information, such as occupation, bank account numbers, bank statement and trading information
Identity verification information, such as gender, ID number, tax number or images of your government-issued ID, passport, national ID card or driver’s license. We also use third-party authentication services that may collect biometric data as part of the account creation and identity verification process, and those entities may collect your biometric identifiers or information
Residence verification information, such as utility bill details or similar information
Demographic information, such as age, income, education, and employment status
Image in photo or video form (where required as part of our know-your-customer checks), which may also include biometric data processed during a video verification process
Records of our discussions, if you contact us or we contact you (including records of phone and video calls)
Information regarding the way in which you use our Services, such as when you used our Services, and the specific Services you used
Other information relating to communications with us, whether through the Website or via e-mail, over the phone or via any other medium
We need to collect above types of information for compliance with legal requirements relating to our anti-fraud/anti-money-laundering/counter-financing-of-terrorism/know-your-customer obligations or to assure our contract obligations for you. If this information is not provided, we may not be able to provide a Service for you.
It is important to note that the Personal Data we collect when you create an Account will be retained for the mandatory retention period set forth by applicable law as it is necessary for us to maintain an exhaustive documentation of our operations as required from us as regulated financial sector professionals, even if your Account has not been successfully activated (e.g. if Account verification has not been completed) or no transaction has been made using it.
Usage Data
Usage Data is collected automatically when using the Service in order to prevent frauds and to be able to support you using our excellent solution.
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.
We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.
The personal data from this section will be retained for maximum 12 months after the data has entered our system. Then they will be anonymized.
Tracking Technologies and Cookies
We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze Our Service. The technologies We use may include:
Cookies or Browser Cookies. A cookie is a small file placed on Your Device. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse Cookies, our Service may use Cookies.
Flash Cookies. Certain features of our Service may use local stored objects (or Flash Cookies) to collect and store information about Your preferences or Your activity on our Service. Flash Cookies are not managed by the same browser settings as those used for Browser Cookies. For more information on how You can delete Flash Cookies, please read "Where can I change the settings for disabling, or deleting local shared objects?" available at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_
Web Beacons. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).
For more information about the cookies we use and your choices regarding cookies, please visit our Cookie Policy.
The Company may use Personal Data for the following purposes:
To provide and maintain our Service, including to monitor the usage of our Service.
To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.
For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.
To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application's push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
To manage Your requests: To attend and manage Your requests to Us.
For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.
Your personal data for above purposes will be processed based on necessity to perform our contract to you (GDPR 6(1)b) or our legal obligations (GDPR 6(1)c) for at least 10 years after ending of the calendar year in which your Account has been closed, or for other period if so required by applicable Laws (whichever is longer).
To provide You You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.
We will process the personal data mentioned above based on your consent (GDPR 6(1)a and e-Privacy directive) for a maximum of three months after you have revoked your consent.
For other purposes: We may use Your information for other purposes if you gave us your consent for Analytics, Performance, Advertising and Marketing cookies, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.
We will process the personal data based on our legitimate interests (GDPR 6(1)f) as mentioned by each of the bullets above for maximum of two years, then Your personal data will be anonymized.
We may share Your personal information in the following situations:
With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.
For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.
With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.
With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside.
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to a third country or international organization unless there are adequate controls in place including the security of Your data and other personal information.
Business Transactions
If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide timely notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
Law enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Other legal requirements
The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:
Comply with a legal obligation
Protect and defend the rights or property of the Company
Prevent or investigate possible wrongdoing in connection with the Service
Protect the personal safety of Users of the Service or the public
Protect against legal liability
The security of Your Personal Data is important to Us, but you are kindly asked remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
You have the right to:
request from Us access to, rectification or erasure of personal data or restriction of processing concerning You or to object to processing as well as the right to data portability;
withdraw Your consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
lodge a complaint with a supervisory authority, which is Datenschutzstelle, Städtle 38 PO Box 684, FL-9490 Vaduz, Liechtenstein, https://www.datenschutzstelle.li/
get informed whether the provision of personal data is a statutory or contractual requirement, or a requirement necessary to enter into a contract, as well as whether which personal data You are obliged to provide and of the possible consequences of failure to provide such data; and
get the information about existence of automated decision-making, including profiling;
in case Your personal data have not been obtained from you, the information, from where the data concerning You have been obtained.
We will do our best to obey your rights within 30 days after your request, however in rare cases it might happen we will prolong the above period for no more than two months.
Our Service does not address anyone under the age of 18. We do not knowingly collect personally identifiable information from anyone under the age of 18. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 18 We take steps to remove that information from Our servers.
Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions about this Privacy Policy, please contact us: [email protected].