Fintecture

PRIVACY POLICY

Latest update: 26th of April 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 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 centers 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.