Privacy Policy

 

1. General

This Privacy Policy governs the collection, processing, and use of your Personal Information by CifroPay (hereinafter referred to as the “Company,” “we,” “us,” or “our”) when you access or use the website www.cifropay.com (hereinafter referred to as the “Website”) or related services provided by the Company through the Website or as per our agreement with you (hereinafter referred to as the “Services”).

“Personal Information” refers to data that identifies an individual, such as name, address, email address, financial information, and banking details. Personal Information does not include anonymized or aggregated data that cannot be used to identify a specific user. The Company is committed to safeguarding your privacy, and this Privacy Policy aims to describe:

• The types of Personal Information we collect and how it may be used.
• How and why we may disclose your Personal Information to third parties.
• The transfer of your Personal Information.
• Your rights regarding access, correction, updating, and deletion of your Personal Information.
• The security measures we employ to protect your Personal Information from loss, misuse, or alteration.
• The Company’s data retention policy.

This Privacy Policy also addresses some aspects of our use of cookies. For more detailed information, please refer to our Cookie Policy. We are responsible for the methods of collecting your Personal Information and determine the purposes for which we use this information. As a data controller, we comply with the General Data Protection Regulation (GDPR) and other applicable European data protection laws.

2. Collection and Use of Personal Information

A. Personal Information We Collect

We collect the following Personal Information:

• Contact Information: This includes your name, home address, and email address.
• Account Information: This includes your username and password.
• Financial Information: This includes bank account numbers, bank statements, trading activity and history, and commissions charged, among others.
• Identity Verification Information: This includes images of government-issued IDs, passports, national ID cards, driver’s licenses, or other documents as requested by our compliance department.
• Residence Verification Information: This includes utility bill details or similar information.
• Other Information: This pertains to data gathered during our Know Your Customer (KYC) procedures, such as information about your financial state and the source of your funds.

We also automatically collect certain computer, device, and browsing information when you access the Website or use our Services. This information is aggregated to provide statistical data about user browsing activities and does not personally identify individuals. It may include:

• Information about the computer or mobile device you use to access our Website, including hardware model, operating system and version, web browser, IP addresses, and other device identifiers.
• Website Usage Information: This covers server log data, including login details, visit dates and times, pages viewed, IP addresses, time spent on our Website, and the websites visited immediately before and after ours.
• Device Statistics: This includes bandwidth upload and download speeds, available storage space, and other device-related statistics.
• Even if you abandon the completion of an online application or registration form, we may automatically capture, store, and process your information.

B. Use of Cookies and Similar Technology

Our Website uses cookies, which are small text files placed on your computer by websites you visit. Cookies serve various purposes, such as making websites work efficiently and providing information to site owners. Cookies are typically stored on your computer’s hard drive.

We use cookies to:

• Enable you to use the Website and our Services efficiently.
• Distinguish you from other users, improving your browsing experience.
• Provide statistical data about user behavior on our Website.
• For more detailed information on our cookie usage, please refer to our Cookie Policy.

C. How We Use Your Personal Information

We may use your Personal Information to:

• Process your transactions, limited to the purpose for which it was provided.
• Fulfill our legal or regulatory requirements.
• Verify your identity in compliance with applicable legislation and our Anti Money Laundering policy.
• Detect, investigate, and prevent fraudulent or unauthorized activities.
• Protect our rights and property.
• Personalize your Services experience.
• Analyze Website usage and improve our offerings.
• Respond to customer service requests and support needs.
• Contact you about Services-related information, updates, promotions, and company news.
• Administer contests, promotions, surveys, and other features.
• Link or combine Personal Information to carry out various purposes.

We do not engage in behavioral tracking of customer activities on our Website or across different websites, nor do we allow third-party data collection through our services. If you wish to stop receiving marketing communications from us, please contact us at [Contact Email] to opt out.

3. Disclosure and Transfer of Personal Information

A. Disclosures to Third Parties

During transaction processing, we may share some of your Personal Information with third-party service providers assisting in our business operations. We do not sell, exchange, or share your information with third parties without your consent, except as required by law. Your use of our Website or Services implies consent to the disclosures described in this Privacy Policy. Non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses. Our third-party service providers are contractually obligated to protect and use such information only for the purposes disclosed, in compliance with applicable data protection laws.

B. Disclosures to Legal Authorities

We may share your Personal Information with law enforcement, data protection authorities, government officials, and other relevant authorities when:

• Compelled by subpoena, court order, or other legal procedures.
• Disclosure is necessary to prevent physical harm or financial loss.
• Required to report suspected illegal activity.
• Necessary to investigate violations of this Privacy Policy or our agreement with you.

C. International Transfers of Personal Information

We store and process your Personal Information in data centers worldwide, wherever Company facilities or service providers are located. Such transfers comply with our legal and regulatory obligations and are conducted only via secure channels.

D. Other Circumstances for Disclosure of Personal Information

We may disclose your Personal Information in the following situations:

• With your consent or at your instruction, such as when you choose to share information publicly.
• To our parent companies, affiliates, subsidiaries, and related companies under common control or ownership with us.
• To protect our rights and property, or the rights and property of our parent companies, affiliates, subsidiaries, and related companies.

4. External Websites

Our Website may provide references or links to external websites (“External Websites”). We do not control these External Websites or their content. We are not responsible for External Websites, including their content, policies, failures, promotions, products, services, actions, or any damages, losses, failures, or issues arising from these sites. External Websites typically have separate privacy policies, so we encourage you to review them. While we aim to protect the integrity of our site, we welcome feedback regarding External Website information provided on our Website.

5. Your Rights Regarding Personal Information

You have several rights related to your Personal Information, provided they do not conflict with legal requirements related to preventing money laundering, terrorist financing, record-keeping obligations, etc. These rights include:

• The right to be informed about the processing of your Personal Information.
• The right to data portability, allowing you to receive your Personal Information in a machine-readable format in certain circumstances.
• The right to object to the processing of your Personal Information.
• The right not to be subject to automated decision-making, including profiling, if it does not affect the contract between you and us.
• The right to access, correct, update, and block inaccurate or incorrect data.
• The right to withdraw your consent for the processing of your Personal Information.
• The right to have your Personal Information erased from our servers upon a justified request (right to be forgotten).

To exercise these rights, please contact us at [Contact Email]. We will provide your Personal Information within 40 days of receiving your written request. We may request additional information to confirm your identity, and you may be required to present official documents containing accurate data.

In certain cases, we may be unable to change your Personal Information, such as when your data has already been used during the execution of an agreement or transaction or is specified in an official document.

If you withdraw your consent for data processing or exercise your right to be forgotten, we may not be able to provide our products or services. We reserve the right to terminate any ongoing agreements with you, subject to legal consequences.

6. Security of Personal Information

We employ various security measures to maintain the confidentiality of your Personal Information and protect it from loss, unauthorized access, misuse, alteration, or destruction. These security measures include, but are not limited to:

• Password-protected directories and databases.
• Secure Sockets Layer (SSL) technology to encrypt information transmitted over the Internet.
• Limited access to hosting servers using two-factor authentication (2FA) and traffic encryption.
• Encryption of all financially sensitive and/or credit information in our database.
• Authorization limited to authorized Company personnel, who are bound by confidentiality obligations.

These security measures are reviewed regularly to align with legal and technological developments.

7. Retention of Personal Information

We retain Personal Information for as long as necessary to fulfill the purposes described in this Privacy Policy and comply with legal and regulatory obligations. We retain account and other Personal Information for a minimum of five years after termination of the relevant agreement.

8. Updates to This Privacy Policy

This Privacy Policy may be revised, modified, updated, or supplemented at any time at our sole discretion. When changes occur, we will notify all users through our Website and make the revised Privacy Policy available for review on our Website.

9. Data Protection Officer

To exercise your rights, submit queries, or report privacy-related issues, please contact our Data Protection Officer at contact@cifropay.com.

This Privacy Policy was last updated on 30/08/2023.