) of Connectee, informs and explains the User how Connectee processes any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the User’s identification or identifiability (‘Personal Data’
) Connectee receives, when the User is using the Website and/or the Services and the rights the User has in relation to their Personal Data. The Policy should be read in conjunction with the Terms and Conditions.
This Policy sets forth the basic rules and principles by which Connectee processes the User’s Personal Data and mentions Connectee’s responsibilities while processing the User’s Personal Data according to transparency obligations. While using the Services the User agrees for the User’s Personal Data processing in accordance with the Policy. In case when the User does not agree with the Policy partially or fully, the User must stop using the Services. All data collected before the above-mentioned refusal will be processed in accordance with the Policy until the User’s direct prohibition is received.
The Services are not directed to people under the age of eighteen (18). If the User becomes aware that the User’s child has provided Connectee with Personal Data without the User’s consent, please contact Connectee at the email address listed below. If Connectee becomes aware that a child under eighteen (18) has provided Connectee with Personal Data, Connectee will take steps to remove such information and/or terminate the child’s Account.
Connectee (company Connectee OÜ, 14891451 and company UAB Cleverlee, 305935751) is the controller within the meaning of the General Data Protection Regulation (GDPR) and determine the purposes and means of processing the User’s Personal Data.Definitions‘Personal Data’
means any information relating to an identified or Identifiable Natural Person;‘Identifiable Natural Person’
is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.‘Processing’
means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.Personal Data and its processing methods
Connectee collects certain data about the User and their use of the Services. This data is collected through these three primary methods:
- data the User provides to Connectee;
- data Connectee collects from the User automatically;
- data Connectee collects from third parties.
While providing the Services Connectee may collect the following types of data:
- Data used for performing customer due diligence measures,
- the User’s data e.g. the User’s photo, name, date and place of birth, address;
- identity document data, e.g. photo of the document, number and validity;
- financial data, e.g. ownership and source of funds and/or wealth;
- contact details, including, the User’s email address or details of other means of communication the User chooses to provide Us;
- transaction data and the nature of using the service, e.g. transaction sums, counter-parties, bank account and card number(s) and account holders;
- other data e.g. media coverage, occupation and connection to other persons, and device information and location;
Purpose and Legal Basis for Personal Data Processing
- Usage data includes details about how the User uses the Website.
- Technical data includes internet protocol (IP) address, the User’s login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices which the User (whether a client or otherwise) uses to access and browse the Website.
- Website visit data includes the full Uniform Resource Locators (URL), clickstream to, through and from the Website (including date and time), products the User viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page.
- Marketing and communications data includes the User’s preferences in receiving marketing from Connectee or Connectee’s third parties and the User’s communication preferences. This may include information whether the User has subscribed or unsubscribed from any of Connectee’s mailing lists, accepted any of Connectee’s invitations, or attended any of Connectee’s events.
- Correspondence between the User and Connectee.
Connectee collects Personal Data for the next targets and legal basis:
- to provide the Services and carry out Connectee’s obligations arising from any contract the User enters into with Connectee;
- to perform transactions;
- to provide the User with information related to providing the Services;
- to grant the User access to the Services;
- to remember the User’s settings, manage the User’s requests, host, and back-end infrastructure;
- to provide newsletters/offers/updates/advertisements which may be interesting to the User;
- in order to improve the Website (testing features, interacting with feedback platforms, managing landing pages, heat mapping the Website, traffic optimization, and data analysis and research, including profiling and the use of machine learning and other techniques over the User’s Personal Data and in some cases using third parties to do this);
- to provide customer support;
- to collect statistical or technical non-personalized data about the use of the Website and the Services;
- for Connectee’s justified interest, for the purpose of fulfilling a contract, including for establishing violations of the contract or legislation, as well as to confirm such violations.
- in order to comply with legal requirements (including, compliance with KYC and AML regulations);
- in order to protect the User’s vital interests or the vital interests of another natural person.
If Personal Data processing is carried out in accordance with Connectee’s justified interests, the User has a right to submit objections to such processes.Disclosing the User’s Personal Data
Connectee only shares the User’s Personal Data when Connectee has a valid reason for it, namely, to provide the Services and products to the User and when Connectee is legally permitted to do so.
Connectee may disclose the User’s Personal Data to:
- Data processors (including banking partners, technology providers, customer support center) – Connectee uses carefully selected service providers (data processors) that provide sufficient guarantees to implement appropriate technical and organizational security measures to protect the User’s Personal Data. Connectee has concluded appropriate data processing agreements with the service providers and shall remain responsible for their actions in respect of the processing of the User’s Personal Data.
- Third parties – in some circumstances, Connectee also shares the User’s Personal Data with third parties who act as independent data controllers as regards the User’s Personal Data. Connectee only shares the User’s Personal Data with third parties if stipulated herein, if required under the applicable law (e.g., auditors, national regulators or other authorities), when Connectee needs to protect the User’s legal rights (e.g. disclosing Personal Data to attorneys or debt collection agencies) due to Connectee’s legitimate interest for the performance of an agreement, or with the User’s consent.
- Acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of Connectee’s business assets. In such case, Connectee makes sure that the User’s rights and conditions when the data may be processed as a data subject shall not be decreased.
- The User’s representatives, advisers, and other third parties the User has contacted regarding the Service or which the User has authorized to interact with Connectee on the User’s behalf. Please note that Connectee considers such authorization as the User’s consent and therefore the User’s request for such an activity must be present to Connectee in a written form.
- With the User’s Consent – Connectee may share information with other third parties with your express consent, unless otherwise described above. For example, you may agree to us sharing your information with a certain company or organization to hear about their products, services, or promotions. Use of the information you agree to share will be subject to those third parties' respective privacy notices.
Connectee will not sell the User’s Personal Data to any third party.Personal Data storage
Connectee stores the User’s Personal Data while it is necessary to process data, to protect Connectee’s interests or on the grounds provided by legal acts requirements. In accordance with Connectee’s record keeping obligations Connectee will retain wallets and personal information for at least a period of five years after they are closed by the User.Cookies
Our Cookies Policy
is available on the Website.Security and international transfers
Although generally the Personal Data is processed within the European Economic Area, certain activities may result in the transferring of Personal Data to Third Countries, meaning countries located outside the EU/EEA. Connectee only transfers the User’s Personal Data Third Countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission to the extent recognised by the competent Data Protection Authority or another statutory exemption) provided by local applicable law.
Connectee takes all necessary measures to protect the data against unauthorized access, modification, disclosure or destruction. Connectee has implemented various technical and organizational measures to be compliant with applicable Personal Data, privacy, and data security legislation in the countries where Connectee operates or where the applicable law applies to Connectee.
Connectee has put in place procedures to deal with any suspected Personal Data breach and will notify the User and any relevant regulator of a breach where Connectee is required to do so by law.
Connectee is not responsible for the Personal Data protection measures violations if such violations caused by actions performed by the User or a third person.Standard Contractual Clauses for transfer abroad
We only transfer your Personal Information abroad to countries which are considered to provide an adequate level of data protection, or in the absence of such legislation that guarantees adequate protection, based on appropriate safeguards (e.g., standard contractual clauses adopted by the European Commission to the extent recognised by the competent Data Protection Authority or another statutory exemption) provided by local applicable law)The User’s rights and obligations
In accordance with relevant legal acts (primarily – GDPR) the User can exercise the following rights by contacting Us:
- request an access to the User’s own Personal Data;
- request changes in the User’s own Personal Data;
- request removal of the User’s own Personal Data;
- withdraw consent to the Processing of Personal Data collected on the basis of the User’s consent;
- request the transmission of Personal Data directly to another data controller (portability);
- submit objections to the User’s own Personal Data processing on any grounds.
Connectee replies to the User’s requests and requirements within 1 month and notifies about measures took to perform provided requests and requirements.
If the requests or requirements of the User are obviously not justified or excessive, primarily due to their repetitive nature, Connectee has the right to refuse performing requests or requirements.
The User does not need to pay a fee to access information or other rights, but Connectee may charge a reasonable fee if the User’s request is clearly unfounded, repetitive, or excessive or refuse to comply with the User’s request in these circumstances.
In case when Personal Data is processed by the User’s consent, the User always has a right to revoke his consent. If the User revokes the User’s consent for Personal Data processing all the data processing performed before revoke considers to be legitimate and lawful.
Where Connectee needs to collect Personal Data by law, or under the terms of a contract Connectee has with the User and the User fails to provide this data when requested, Connectee may not be able to perform the contract Connectee has or are trying to enter into with the User (including the Services). In this case, Connectee may have to cancel the User’s use of the Services, but Connectee will notify the User if this is the case at the time.
The User must notify Connectee about changes in the User’s contact details to keep them up to date.
In case of the User’s rights violation, the User has a right to ask the Data Protection Inspectorate or court to protect their rights.
Users have a right to Curb or withdraw any permissions previously given by them.
Users have a right to Request their data to facilitate their move to a different company / services provider, this is called data portability.Legal Limitations
Notwithstanding anything to the contrary in the Policy, Connectee may preserve or disclose the User’s information if Connectee believes that it is reasonably necessary to comply with a law, regulation, legal process, or governmental request; to protect the safety of any person; to address fraud, security or technical issues; or to protect Connectee’s or the Users’ rights or property.
The User acknowledges that the Connectee is not liable for any illegal or abusive use of the User’s information. The User acknowledges that in a case where the User shares the User’s information from the Software or the Website in social or other networks, or in other third-party sites and/or platforms, the User’s information is subject to the privacy policies of such third-party resources.
Connectee may share the User’s Personal Data with law enforcement, data protection authorities, government officials, and other authorities only when Connectee is legally bound to do so or has to protect the safety of its users and the Website.Third-party links
The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about the User. Connectee does not control these third-party websites and is not responsible for their privacy notice or policies. Connectee strongly encourages the User to read the privacy notice of every website he visits, particularly when leaving the Website.Policy changing
Any questions about this Policy, the processing of Personal Data or data subject’s requests please contact Connectee via the help desk available on the Website or via email at email@example.com.