Privacy Policy

Our Privacy Policy

Privacy policy Last update: 08.08.2021

I. Why should you read this Privacy Policy? Finanpay is committed to the principles of personal data protection laid down in European law and recognizes the importance of safeguarding its customers' information. We are constantly improving our data processing activities and our privacy notices in order to provide you with as much transparency over the way we handle your data as we can. The present Privacy Policy explains the way we collect, use and store personal information about you, as well as and your rights if you want to change how we use your personal information.

If you have concerns about how we use your personal information, you can contact our data protection officer at bank@finanpay.online.

If you are unsure about the meaning of any term used in this Privacy Policy (such as "Finanpay "), you may check the definition in the other legal documents regulating the iCard Digital Wallet and iCard e-money account services to all of which this Privacy Policy forms an inseparable part.

1.1. About us.

When this policy mentions "we," "us," or "our," it refers to Finanpay or an Affiliate of Finanpay [1], which are responsible for your information under this Privacy Policy. The specific responsible entity for your personal data may vary for the different services provided though the Finanpay services. The responsible entity in each case is referred to as the "Data Controller".

1.2. The Services.

The Finanpay services, available at finanpay.online and the Mobile app consist of two main groups of functionalities.

The first group of functionalities consist of the Digital Wallet service, which is made immediately available to you after you successfully register for Finanpay . In general data provided or collected while you use this types of service shall be kept for no more than 6 months after the date of your last login, after which we will deem your use of these services to be terminated for reasons of inactivity and we shall proceed to delete or anonymize your data.

The second group of functionalities consists of payment and other financial services, available to clients which have accepted the Legal Agreement for Finanpay e-money account and have initiated the process for passing our customer due diligence requirements. We will keep all data related to these functionalities for a period of 5 years after the year of termination of your Finanpay e-money account agreement, which is a legal requirement under the applicable anti-money laundering legislation.

The Finanpay services not designed for business purposes and cannot be used by business entities and/or employers. If you wish to use iCard's payment services for business purposes you should try out our Finanpay for Business Service!

However, in case you have provided us with information about any third party, such as your employees, your children or spouse we will treat this information with the presumption that you have informed these third persons of the present Privacy Policy and you have received their consent for sharing their information with us. Examples of such cases may include:

Whenever you order an additional card embossed with the names of a friend; Whenever you order a GiftCard (plastic or virtual) in order to gift it to another person; Whenever you pay any kind of tax, fee, e-vignette or similar on behalf of another person, including a co-owner or similar; Other similar cases. IMPORTANT:

The present Privacy Policy does not cover any privacy topics concerning the provision of insurance services.

The responsible Data Controller for those type of services is the respective insurance provider that we have allowed to sell insurance policies though our app.

The Data Controller for insurance brokerage, if applicable, is the respective insurance broker.

You will be provided with the Privacy Notices or Privacy Policies of any such Data Controllers whenever you want to use the insurance services.

II. How do we process your personal information?

2.1. What information do we process about you?

There are two general categories of personal information that is collected for you. These are:

The information which we collect when you use our Wallet Services; The information which we collect when you use our payment and financial services. Information that we process in relation to our Digital Wallet . 2.2. Specific data sharing.

In any case, we may share any of your information for specific reasons, outlined below :

With other members of the iCard corporate family, for the purposes of our group consolidation .We may share your Personal Data with members of the Finanpay Group of companies or within our extended family of companies that are related by common ownership or control. Aggregated Data. We may also share aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information on the basis of regulatory compliance, industry and market analysis, demographic or other type of profiling, marketing and advertising, and other business purposes, on the basis of our legitimate interests. This shall not constitute the processing of personal data since the information is anonymized. With our legal counsels, auditors and similar for the purposes of protecting our legal rights . We may share any information which is necessary to protect our legal rights to legal counsels or similar parties. Business Transfers. If any of the companies that provide services is involved in any merger, acquisition, reorganization, sale of assets, transfer of portfolio, bankruptcy, or insolvency event, then we may sell, transfer or share some or all of our assets, including your information in connection with such transaction or in contemplation of such transaction (e.g., due diligence). In this event, we will notify you before your personal information is transferred to a different legal person and/or becomes subject to a different privacy policy. 2.3. Decisions based solely on automated processing.

Sometimes, our systems may take decisions based solely on automated processing. This does not mean that we will always use automated decision making for these processing activities. In case you believe that you have been unfairly treated by our automated decision-making systems you may ask that a person reviews the decision at all times by contacting us as described in the "How to file complaints" section. Such decisions may be done for processing activities that include:

2.4. Information collected about you from third parties .

We may ask certain entities for information about you when you are enrolling for our services. Such entities are generally fraud prevention agencies and Know Your Customer and Anti Money Laundering Checkup service providers which help us to fulfil our legal obligations for due diligence on our customers.

We may also collect information about you from public sources for Anti Money Laundering reasons or market research. This includes:

official public records, like your national Company register. information published by the press or on social media. In case you use any of the linked services, provided by one of our partners, such as the insurance services, they may share details with us about your deal.

2.5. Retention periods.

We retain your personal information during the course of our contractual relationships. We shall keep all data related to the Digital Wallet for no more than 6 months after our last interaction.

We shall keep all data related to the Finanpay e-money account for no more than 5 years after the year of our last interaction, as required by relevant national legislation.

We may however retain some of this data in exceptional cases, i.e. where it is necessary for the defence of our legal rights or in case there is any kind of active and ongoing investigation related in any way to you.

Because we maintain our records in a manner protecting from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time. III. Your rights.

You may exercise any of the rights described in this section before the Data Controller pursuant to the General Terms and Conditions for Finanpay by sending an email from your e-mail registered for the services to Finanpay . Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws.

3.1. Managing your information.

You have the right to obtain the following:

confirmation of whether, and where, we are processing your personal data; information about the purposes of the processing; information about the categories of data being processed; information about the categories of recipients with whom the data may be shared; information about the period for which the data will be stored (or the criteria used to determine that period); information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing; information about the existence of the right to complain to any Regulator; where the data was not collected from you, information as to the source of the data; and information about the existence of, and an explanation of the logic involved in, any automated processing. Additionally, you may request a copy of the personal data being processed. 3.2. Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to iCard Account).

3.3. Data Access and Portability.

You have the right to:

receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use; transfer your personal data from one controller to another; store your personal data for further personal use on a private device; and have your personal data transmitted directly between controllers without hindrance. In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

Because we maintain the iCard to protect from accidental or malicious loss and destruction, residual copies of your personal information may not be removed from our backup systems for a limited period of time. 3.4. Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by changing your Account settings or by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.

3.5. Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defence of legal claims. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, we may have to stop providing you some or all of the services.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.

We will also provide an opt-out option whenever we are using your personal information for marketing purposes.

3.6. How do I complain?

You should in first place try to resolve the matter by sending an e-mail to the Data Controller under this Privacy Policy from your registered e-mail for the Service: Data Protection Officer (DPO):

bank@finanpay.online

71 Mühlenweg, L-2155 Luxembourg.

Competent Regulator. In case you are not satisfied with the reply or resolution of the Data Controller, you have the right to lodge complaints about the data processing activities carried out by us before the competent data protection supervisory authorities as described below.

IV. Operating globally.

To facilitate our global operations, we may be required to transfer, store, and process your information within our family of companies or with service providers based in Europe, India, Asia Pacific and North and South America. Laws in these countries may differ from the laws applicable to your Country of Residence. For example, information collected within the EEA may be transferred, stored, and processed outside of the EEA for the purposes described in this Privacy Policy. Where we transfer store and process your personal information outside of the EEA we have ensured that appropriate safeguards are in place to ensure an adequate level of data protection.

V. International transfers.

5.1. Adequacy Decisions

Where we disclose any of your collected personal information outside, we shall comply with any relevant adequacy decision, where possible.

5.2. Other means to ensure adequate level of data protection.

In case personal information is shared with corporate affiliates or third-party service providers outside the EEA in absence of an adequacy decision, we have - prior to sharing your information with such corporate affiliate or third-party service provider - established the necessary means to ensure an adequate level of data protection and a valid legal ground under the applicable data transfer rules. We will provide further information on the means to ensure an adequate level of data protection on request.

VI. Security.

We take the responsibility to ensure that your personal information is secure, kept in an encrypted from on servers, collocated in Special data centres in Class A jurisdictions in Europe. To prevent unauthorized access or disclosure of information we maintain physical, electronic and procedural safeguards that comply with applicable regulations to guard non-public personal information. Once you are logged into your Account, all internet communication is secured using Secure Socket Layer (SSL) technology with High-grade security Encryption (AES-256, 256 bit keys, certified by StartCom Ltd). We restrict access to your personally identifiable information only to employees who need to know that information in order to provide products or services to you.

If you know or have reason to believe that your Finanpay Account credentials have been lost, stolen, misappropriated, or otherwise compromised or in case of any actual or suspected unauthorized use of your Finanpay Account, please contact us following the instructions in the Contact Us section below. While we are dedicated to securing our systems and Services, you are responsible for securing and maintaining the privacy of your password(s) and Account/profile registration information and verifying that the Personal Data we maintain about you is accurate and current.

VII. Can children use our services?

The services are not designed for individuals under the age of 18. We do not knowingly collect information, including Personal Data, from children or other individuals who are not legally able to use services. If we obtain actual knowledge that we have collected Personal Data from an individual under the age of 18, we will promptly delete it, unless we are legally obligated to retain such data. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under the age of 18.

VIII. Changes to this privacy policy.

We reserve the right to modify this Privacy Policy at any time in accordance with this provision. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on Finanpay Platform. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of Finanpay Platform will be subject to the revised Privacy Policy.

IX. Contact us.

If you have any questions or complaints about this Privacy Policy or our information handling practices, you may email us from your registered e-mail for the Services to the e-mails stated above in Section 3.6.

[1] For the purposes of the Privacy Policy of Finanpay , Finanpay or an Affiliate of Finanpay means an entity under common ownership or control with Finanpay , to which the Privacy Policy applies.

Depending on the specific service you are using, Finanpay or an Affiliate of Finanpay means: 1. For the Digital Wallet: Finanpay Services, Company Number CSSF 47/20. RCS B033722, seat and registered address at 71 Mühlenweg, L-2155 Luxembourg.

2. For the Digital Wallet: Finanpay Services, Company Number CSSF 47/20. RCS B033722, seat and registered address at 71 Mühlenweg, L-2155 Luxembourg.

[2] Please bear in mind that the respective Account scheme is a separate data controller for the purposes of the issued card. You may read more about the Account scheme’s data processing practices at their official webpage.