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PRIVACY POLICY

Last update: 31 March 2021

Fintecture SAS - 5 avenue de Général de Gaulle, 94160 Saint-Mandé, France.

Please use the address of our headquarters at 5 avenue de Général de Gaulle, 94160 Saint-Mandé, France for all correspondence.

Fintecture Contact

INTRODUCTION

This Privacy Policy sets out how Fintecture processes your personal data, in accordance with the EU General Data Protection Regulation 2016/679 (GDPR) and the amended law n°78-17 of 6 January 1978 known as "Loi Informatique et Libertés". As indicated in this Privacy Policy, "Fintecture", "we", "us" or "Company" refers to Fintecture SAS, a payment institution, authorised and supervised by the ACPR under number 17248, with its registered office at 5 avenue du général de gaulle 94160 Saint-Mandé, and registered with the Créteil Trade and Companies Register under number 834 500 548.

DATA CONTROLLER

Fintecture is responsible for the processing of your data in accordance with this Privacy Policy.

We have appointed a Data Protection Officer (DPO) to ensure that Fintecture manages and processes your personal information in accordance with applicable privacy and data protection laws and regulations, and in accordance with this Privacy Policy.

Our DPO can be contacted at contact@fintecture.com.

PERSONAL DATA WE PROCESS

In the course of our processing, we may process the following categories of data

  • Contact information, such as name, first name, postal address, e-mail address;
  • Financial information, such as account number, IBAN and transactions initiated or collected by Fintecture;
  • Identity verification information, such as your identity documents, residence ;
  • Information about how you use our services and how a specific service is used;
  • Information about your correspondence with us via our website, e-mail, telephone or post; and
  • Technical information about the device used when you use Fintecture's services or website.

We collect some of this data directly when you provide it to us via the payment module.

The following information may be collected indirectly through your beneficiary who guarantees to have obtained your prior consent:

  • Contact information, such as name, first name, postal address, email address.

PURPOSES OF PROCESSING AND LEGAL BASIS

We process your personal data for the following purposes and in accordance with the following legal bases:

  • Creation and management of your Fintecture account (including associated accounting) and provision of our services. The relevant processing operations are necessary for the performance of our contract with you;
  • To verify your or your customer's identity in accordance with applicable anti-money laundering, politically exposed persons, sanctions lists and other financial sector laws or regulations. This processing is necessary to comply with our legal obligations;
  • The establishment and maintenance of legal documentation in relation to our business and services. This processing is necessary to comply with our legal obligations;
  • Respond to your requests to customer service. This processing is necessary for the execution of a contract with you;
  • To manage any complaints and disputes. This processing is carried out in accordance with our legitimate interest in defending our rights;
  • To personalise our services and content according to your preferences. This processing is carried out in accordance with our legitimate interest in improving the services we provide to you;
  • Collect information about your use of our products and services. This processing is carried out in accordance with our legitimate interest in understanding the use of our services and improving them.

MARKETING

If you give us your consent to do so, we may send you marketing communications by email or other agreed forms of communication to ensure that you are always up to date with our services. We will respect your consent and your stored marketing preferences.

Please note that you can unsubscribe or subscribe at any time if you change your mind by emailing us at contact@fintecture.com.

RECIPIENTS OF YOUR DATA

In the course of processing your data, we may disclose your data to duly authorised Fintecture staff and to Fintecture's service providers who process your data on Fintecture's behalf and in accordance with its instructions.

For operational reasons, your name and e-mail address may be securely communicated to the merchant from whom you are placing the order. This allows your payment to be reconciled with your order and your purchase order to be processed more efficiently.

We may also be required to share your personal data with law enforcement, data protection authorities, administrative or judicial authorities and/or regulators, including

  • to comply with a court order or other administrative or judicial procedure;
  • when necessary to report illegal activity.

FINTECTURE ACTING AS IOBSP[1]

When you choose to use our payment service provider partner to open a payment account in your name in the partner's books, we act as an intermediary in banking and payment services (IOBSP) mandated by the partner, collecting and transmitting to the partner the information and documents that you provide to us for the opening of the account and facilitate the subscription of payment services offered by the partner. This information and documents requested by the partner are necessary to comply with the obligations of vigilance and reporting of suspicious transactions to the competent authorities applicable to the fight against money laundering and the financing of terrorism as defined in Articles L561-1 et seq. of the Monetary and Financial Code.

[1 ] Non-exclusive intermediary in banking and payment services (IOBSP)

DATA SECURITY

We implement appropriate security measures to protect the processing of your data. In particular, Fintecture uses encryption techniques for this purpose, especially for the transmission of data.

WE NEVER ASK FOR YOUR CREDIT CARD DETAILS OR PASSWORDS TO ACCESS YOUR BANK ACCOUNT.

You are responsible for the security of your account access code. Do not share it with anyone.

Please always check that the site on which you are asked for financial or payment information in connection with our services is operated by either Fintecture or your bank. If you receive a suspicious request, do not provide your information and report it by contacting our customer service immediately.

RETENTION OF PERSONAL DATA

We keep your personal data for as long as necessary for the purpose of the processing concerned.

In particular, in accordance with our record-keeping obligations, we will retain your account data, transactions, documentation and other associated data for five years after the end of the business relationship.

We retain data relating to the personalisation of our services and data relating to the study of your use of our services for the duration of the contract.

If personal data is relevant to an investigation or dispute, we will retain it until the issues are fully resolved.

TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

We store and process your personal data in data centres located in the European Economic Area (EEA). Fintecture may extend its activities outside the EEA and offer services or address customers in countries outside the EEA.

If you are affected by the services or become a customer and you reside in a country outside the EEA, Fintecture will ensure that the transfer of your data to your country of residence is subject to an adequate safeguard or one of the exceptions provided for by the applicable regulation, in accordance with the data protection rules established by the GDPR.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You have rights in relation to the processing of your personal data by Fintecture.

You can access your personal data, rectify it, request its deletion or exercise your right to limit the processing of your data. Where the processing of your data is based on your consent, you may withdraw your consent to the processing of your data at any time. You may also object to the processing of your data and exercise your right to the portability of your data, in accordance with the applicable legal conditions.

You also have the right to lodge a complaint with a supervisory authority, in particular with the Commission Nationale de l'Informatique et des Libertés (CNIL).

CONTACT

Please contact our DPO if you have any questions about the data collected about you or if you wish to exercise your rights regarding your personal data. You can do this by sending your request to contact@fintecture.com

COOKIES

When you use our products and services, we may use the standard practice of placing tiny data files called cookies, flash cookies, web beacons or other tracking tools on your computer or other devices you use when you interact with us.

We use cookies that are necessary to provide our services to you, for example to help us recognise you as a customer, or to collect information about your computer and other access devices to ensure compliance with our anti-money laundering obligations.

If you give us your consent to do so, we may also use cookies to personalise our services and content for you, and to collect information about your use of our products and services. Personalisation cookies and audience measurement cookies persist for 13 months.

If you wish to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies may prevent you from using certain features, our site or our services, such as conducting transactions.

 

PRIVACY POLICY

Latest update: 31th of March 2021

Fintecture SAS - 5 avenue de Général de Gaulle, 94160 Saint-Mandé, France.

Our registered office and the address you should use for all correspondence is at 5 avenue de Général de Gaulle, 94160 Saint-Mandé, France.

Fintecture Contact

INTRODUCTION

This Privacy Policy presents the way Fintecture processes your personal data, in accordance with the General Data Protection Regulation EU 2016/679 (GDPR) and with the amended law n°78-17 of 6 January 1978, known as the "Data Protection Act and Freedoms". As Indicated In this Privacy Policy, "Fintecture", "we", "us", "our" or "Company" refers to Fintecture SAS, a Payment Institution, authorized and supervised by the French Financial Regulator ACPR under the number 17248, with its registered address at 5 avenue du Général de Gaulle 94160 Saint-Mandé, and registered within the French Companies Registrar under the number R.C.S Créteil 834 500 548.

DATA CONTROLLER

Fintecture is responsible for processing your data, which it implements in accordance with this Privacy Policy.

We have appointed a Data Protection Officer (DPO) to ensure that Fintecture manages and processes your personal information in accordance with applicable privacy and data protection laws and regulations, and with this Privacy Policy.

You can contact our DPO at contact@fintecture.com

PERSONAL INFORMATION WE COLLECT

As part of the processing we implement, we are required to process the following data categories:

  • Contact information, such as name, home address, and e-mail address;
  • Financial information, such as bank account numbers, IBAN, transactions initiated with Fintecture;
  • Identity verification information, such as identity documents, residence;
  • Information regarding the way in which you use our services, such as when you used our services and the specific services used;
  • Information concerning your correspondence with us, whether through the Fintecture website, e-mail, over the phone or post; and
  • Technical information relating to the device used when you use Fintecture's services or website.

We collect some of this data directly when you provide it to us through the payment module.

The following information may be collected indirectly through your beneficiary who guarantees to have obtained your prior consent:

  • Contact information, such as last name, first name, postal address, email address.

PROCESSING PURPOSES AND LEGAL BASIS

We process your personal data for the purposes and in accordance with the following legal bases:

  • Create and administer your Fintecture account (including the associated accounting) and provide our services. This corresponding processing operations are necessary for the performance of our contract with you;
  • Verify your identity or your clients' in accordance with applicable anti-money laundering, politically exposed persons, sanction lists and other financial sector laws. This processing is necessary to comply with our legal obligations;
  • The establishment and maintenance of legal documentation relating to our activity and our services. This processing is necessary for compliance with our legal obligations;
  • Respond to your client service requests. This processing is necessary for the performance of our contract with you;
  • Manage any complaints and disputes. This processing is implemented in accordance with our legitimate interest in defending our rights;
  • Personalize our services and content according to your preferences. This processing is implemented in accordance with our legitimate interest in improving the services we provide to you;
  • Collect information about your use of our products and services. This processing is implemented in accordance with our legitimate interest to understand the use of our services and to improve them.

MARKETING

With your consent, we may send you marketing communications by e-mail or other agreed upon form of communication, to ensure you are always kept up-to-date with our latest services. We will respect your consent and your saved marketing preferences.

Please note that you can unsubscribe at any time if you change your mind by writing to us at contact@fintecture.com.

RECIPIENTS OF YOUR DATA

As part of the processing of your data, we may communicate your data to duly authorized Fintecture staff members, as well as Fintecture service providers who process your data on behalf of Fintecture and in accordance with its instructions.

For operational reasons, your name and e-mail address may be securely communicated to the merchant you are placing an order for. This allows the reconciliation between your payment and your order, and a more efficient processing of your purchase order.

We may also share your personal data with law enforcement, data protection authorities, administrative or judicial authorities and/or regulators:

  • In order to comply with a court decision, or other administrative or judicial procedure;
  • When disclosure is necessary to report an illegal activity

FINTECTURE ACTING AS IOBSP[1]

When you choose to use our payment service provider partner for the opening of a payment account in your name in the partner's books, we act as an intermediary in banking operations and payment services (IOBSP) mandated by the partner, by collecting and transmitting to the partner the information and documents that you provide to us to open the account and facilitate the subscription to the payment services offered by the partner. This information and documents requested by the partner are necessary to comply with the obligations of vigilance and reporting of suspicious transactions to the qualified authorities applicable in the fight against money laundering and the financing of terrorism as defined in articles L561-1 and seq. of the Monetary and Financial Code.

[1] Intermediary in banking operations and payment services, non-exclusive " Intermédiaire en opérations de banque et en services de paiement (IOBSP)

DATA SECURITY

We implement appropriate security measures to protect the processing of your data. Fintecture uses in particular cryptological techniques for this purpose, in particular for data transmission.

WE NEVER ASK YOUR FINANCIAL INFORMATION, YOUR CARD DETAILS OR SECRET PASSWORDS THAT ENABLE TO ACCESS YOUR BANK ACCOUNT.

You are responsible for keeping your account passcode safe and secure. Do not share it with anyone.

Please always check that any website on which you are asked for financial or payment information in relation to the presented services is operated by Fintecture or by your bank. If you do receive a suspicious request, do not provide your information and report it by contacting our client service immediately.

PERSONAL DATA RETENTION

We keep your personal data for the time necessary for the processing concerned.

In particular, in accordance with our record keeping obligations, we will retain data relating to your account, transactions, documentation, transaction and other personal associated data for five years by the end of the business relationship.

We keep data relating to the personalization of our services and data relating to the study of your use of our services for the duration of the contract.

If your personal data is relevant to an investigation or a dispute, we will keep it until the issues are fully resolved.

TRANSFERS OF PERSONAL DATA OUTSIDE OF THE EUROPEAN ECONOMIC AREA (EEA)

We store and process your personal data in data centres in the European Economic Area (EEA). Therefore, Fintecture may extend its activities outside of the EEA and offer services or address clients in countries outside of the EEA.

If you are concerned by the services or become a customer and you reside outside of the EEA, Fintecture will ensure that the transfer of your data to your country of residence is governed by an adequate guarantee or one of the exceptions provided by the applicable regulations, in accordance with the data protection rules established by the GDPR.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

You have rights in relation to the processing of your personal data by Fintecture.

Thus, you can access your personal data, rectify them, request their erasure or exercise your right to limit the data processing. When your data processing is based on your consent, you can withdraw your consent to the data processing at any time. You can also oppose your data processing and exercise your right to the portability of your data, in accordance with the applicable legal conditions.

You also have the right to file a complaint with a supervisory authority, in particular with the National Commission on Informatics and Liberty (CNIL, Commission nationale de l'informatique et des libertés).

CONTACT

Please contact our DPO if you have any question about the collected data or you would like to exercise your rights regarding your personal data. You can do so by sending your request on contact@fintecture.com

COOKIES

When you use our products and services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools on your computer or other devices used when you interact with us.

We use cookies that are necessary to provide our services to you, for example, to help us recognize you as a customer, or to collect information about your computer or other access devices to ensure our compliance with our anti-money laundering obligations.

With your consent to do so, we may also use cookies to personalize our services and content for you and to collect information about your use of our products and services. Personalization cookies and audience measurement cookies persist for a period of 13 months.

If you want to avoid using cookies altogether, you can disable cookies in your browser. However, disabling cookies might make it impossible for you to use certain features, our website or services, such as making transactions.