Privacy Policy

Effective Date: January 01, 2025

1. Introduction:

This Privacy Policy informs users about the terms and conditions regarding the collection, use, and processing of personal data during the use of the website www.finboo.io (hereinafter referred to as the “Site”) based on the GDPR requirements.

For the purpose of providing services to you, Finboo needs to process customers’ personal data. Depending on the type of service, the service providers are as follows:

Finboo Limited
, a company duly registered and operating under the laws of the Republic of Cyprus under registration No. HE 407056, located at Archangelou, 28B, Kaimakli, Nicosia 1022, Republic of Cyprus.
Finboo UK Limited
, a company duly registered and operating under the laws of the United Kingdom under registration No. 16012314, located at 80-90 Paul Street, London, United Kingdom, EC2A 4NE

Both hereinafter referred to as the “Finboo”

We prioritize the confidentiality of the information shared by users and are committed to transparency regarding data storage and processing.
This Privacy Policy outlines the types of data we collect, the ways in which this data is utilized, the potential recipients of the information when applicable, your rights concerning your personal data, and the procedures for exercising those rights.

This Privacy Policy is an integral part of the General Terms and Conditions. Every visitor or user who affirms this Privacy Policy, in connection with Finboo or its service providers, hereby grants explicit consent for the processing, storage (whether indefinite, for the legally prescribed duration, the period of membership, or the period designated by Finboo), analysis, classification, updating, and transfer of personal and/or non-personal data to third-party business partners and/or consultants for the purpose of delivering services provided by Finboo.

2. Collection of Personal Data

“Personal data” refers to any information that may be utilized to identify you, either directly or indirectly. The personal data collected by Finboo includes the information you provide to the Site and/or that is stored in accessible formats. Examples of personal data encompass, but are not limited to, the following: credentials, first name, last name, email address, telephone number, residential address, banking information, Internet Protocol (IP) address, and, for corporate customers, company name, registration number, VAT number, and any additional information that you provide or consent for us to access.

In the course of utilizing Finboo’s services, we may collect information regarding your interactions with our services from various sources.

We may collect personal data that can identify you directly or indirectly, including but not limited to:

Personal Details
– full name (surname and given name), gender, personal identification code, date of birth, nationality, contact postal address, e-mail address, mobile phone number, and other related information.
Legal entity details
– legal entity name, registration number, registered and operational address, VAT number, authorised representative full name (surname and given name), beneficial owner full name (surname and given name), contact postal address, e-mail address, mobile phone number, and other related information.
Identification Data
– information obtained from a copy of a passport, including document number, issue date, expiry date, issuing authority, photo, and the URL of a portfolio or LinkedIn profile.
Verification Data
– information collected by Finboo for the purpose of conducting Customer due diligence under applicable anti-money laundering laws and Sanction Regulations.
Background Data
– data gathered and processed by Finboo for conducting adverse media checks on the Customer via open sources.
Profile Data
– Customer’s Google profile information, including name, e-mail address, language preference, and profile picture.
Payment Data
– information related to payments for Finboo’s services, such as account number (IBAN), account holder name, bank name, and transaction details. If the Customer opts to pay for services via credit card, their payment details are not stored or accessible by Finboo.
For Finboo Users, who receives remuneration for provided services through the Finboo, payment date could include account number (IBAN), account holder name, bank name, credit card number, credit card holder, credit card issuer bank country, crypto wallet addres, VASP (virtual asset service provider) name, PayPal registerred email address (PayPal ID).
Business-Related Data
– for compliance purpoces Finboo collects and processes information about the Customer’s intended field of activity. Finboo gathers and processes details about the business description, including planned services and service volumes.
Device Data
– information about the device used to access Finboo’s website or app, including the device model, name, or any other identifier, as well as the IP address.
Preference Data
– User preferences while using Finboo’s website or app.
Customer Support Data
– communications between Finboo and the User (inquiries submitted via the website, e-mail, social media, or chat).
Usage Data
– data related to the User’s interactions within Finboo’s website or app.

3. Purpose of Data Processing

The information we collect may be used for the following purposes:

Service Provision and Maintenance
We use personal data to provide, operate, and maintain our services, ensuring seamless functionality and user experience.
Service Improvement and Personalization
Personal data helps us analyze usage patterns, enhance features, and personalize content to improve your overall experience.
Transaction Processing
We process personal data to facilitate payments, verify transactions, and send transaction-related communications (e.g., invoices, confirmations, and payment receipts).
Communication and Customer Support
We may use your contact information to respond to inquiries, provide customer support, and send important service updates.
Security, Fraud Prevention, and Compliance
We process personal data to detect, investigate, and prevent fraudulent activities, security threats, and technical issues. Additionally, we use data to comply with legal and regulatory obligations.

4. Data Sharing and Transfer

We do not sell or rent your personal data to third parties. However, we may share your personal data in the following circumstances:

With Service Providers and Affiliated Companies
We may share your data with trusted third-party service providers and affiliated companies that assist us in operating our website, processing transactions, or delivering our services. These parties are bound by strict confidentiality agreements and process personal data only as necessary to fulfill their obligations.
With Financial Institutions and Compliance-Related Third Parties
We may be required to share your personal data with:
Financial institutions and banks – for processing payments and verifying transactions. Payment service providers (PSPs) – to facilitate payment processing, refunds, and related services.
Virtual asset service providers (VASPs) – if transactions involve cryptocurrencies or other digital assets.

These entities may request personal data to meet regulatory compliance requirements, including anti-money laundering (AML), counter-terrorist financing (CTF) and Sanction legislation obligations.
With Public Authorities and Law Enforcement Agencies
We may disclose personal data if legally required to do so, such as:
To comply with applicable laws, regulations, or legal processes (e.g., subpoenas, court orders).
To respond to government or law enforcement agency requests.
To protect the rights, property, or safety of Finboo, its users, or others.

Your personal data may be transferred to and processed in countries outside your jurisdiction, including countries that may not provide the same level of data protection as your home country.

To ensure adequate protection of your data, we implement the following safeguards:

Standard Contractual Clauses (SCCs)
– approved by the European Commission for data transfers outside the European Economic Area (EEA).
Binding Corporate Rules (BCRs)
– where applicable for internal data transfers within corporate affiliates.
Adequacy Decisions
– ensuring that the recipient country has adequate data protection standards recognized by regulatory authorities.
Encryption and Security Measures
– to prevent unauthorized access during transmission and storage.

5. Data Security

We prioritize the security of your personal data and take comprehensive measures to ensure its protection against unauthorized access, loss, destruction, or alteration. In compliance with the General Data Protection Regulation (GDPR) (Regulation (EU) 2016/679), we have implemented a combination of technical, administrative, and organizational safeguards to maintain data confidentiality, integrity, and availability.

We apply advanced security protocols and encryption technologies to protect the personal data we collect and process. These measures include, but are not limited to:

Data Encryption
– Personal data is encrypted using industry-standard TLS (Transport Layer Security) / SSL (Secure Socket Layer) encryption protocols during transmission to prevent unauthorized interception.
Access Control Mechanisms
– Strict role-based access control (RBAC) ensures that only authorized employees and third parties can access personal data.
Firewall and Intrusion Detection Systems (IDS/IPS)
– We deploy firewalls, intrusion detection, and prevention systems to monitor and block unauthorized access attempts.
Anonymization and Pseudonymization
– Where applicable, we anonymize or pseudonymize data to minimize risk in case of a breach.
Regular Security Patches and Updates
– We ensure that all software and systems are regularly updated to prevent vulnerabilities.
Data Backups and Recovery Plans
– Automated, secure backups of critical data are maintained, with defined disaster recovery procedures.

While we take every precaution to secure personal data, users also play a role in protecting their accounts. To enhance security, we strongly recommend that users:

6. Your rights as a data subject

Under applicable data protection laws, you have the following rights regarding your personal data:

Right to Access:
Request confirmation on whether your personal data is being processed.
Right to Information:
Obtain details regarding data processing activities.
Right to Purpose Limitation:
Learn why and how your data is being used.
Right to Third-Party Information:
Be informed about third parties to whom your data has been disclosed.
Right to Rectification:
Request corrections if your personal data is inaccurate or incomplete.
Right to Erasure (“Right to be Forgotten”):
Request deletion of personal data when legally permissible.
Right to Notification:
Ensure third parties with whom your data was shared are informed of corrections or deletions.
Right to Object:
Challenge automated decision-making processes affecting you.
Right to Compensation:
Seek damages if you suffer harm due to unlawful data processing.

Additionally, if you believe your data protection rights have been violated, you have the right to file a complaint with a data protection authority, without prejudice to any other legal remedies.

While you may exercise your rights as outlined above, Finboo retains certain personal data required to meet legal obligations, contractual commitments, and record-keeping requirements.

7. Cookies

Cookies are small text files that help recognize returning users and are placed on the device you use to access our services. The lifespan of each cookie depends on its purpose and the reason for its use.

Cookies serve multiple functions, including:

Enhancing user experience and site functionality:
If you enable the “Remember Me” feature, we may store your username in a cookie to facilitate faster login.
Ensuring security:
Cookies help us verify user identities and determine whether a session remains active within Finboo.
Personalizing content based on user preferences:
We may store information such as preferred language settings in cookies to customize the content displayed to you.
Optimizing services and performance:
Cookies allow us to measure usage statistics, track navigation patterns, and sometimes display different versions of content. This helps us refine our services and improve the user experience.

8. Types of Cookies based on usage

Essential Cookies:
These cookies are critical for the website’s core functionality, such as preventing fraudulent activities and ensuring system stability. Disabling them may result in restricted functionality.
Analytical/Performance Cookies:
These cookies help us analyze website usage and interaction patterns, enabling us to make improvements. Users may opt out of these cookies.
Functionality Cookies:
These cookies store user preferences and allow the website to remember you between visits, providing quick access to certain content. Disabling them may impact personalized features.
Advertising Cookies:
These cookies track online behavior to display targeted ads. Disabling them will not remove advertisements entirely but will result in non-personalized ads instead.

9. Types of Cookies based on retention period

Persistent Cookies:
These remain on your device for a specified period or until manually deleted. They are used to remember user preferences and browsing behavior.
Session Cookies:
These separate user visits into sessions and do not collect personal information. They are automatically deleted when the user becomes inactive or closes the website.

Third-party service providers may use tracking cookies to deliver services and improve their effectiveness. Such cookies can record visited web pages, collect personal data (such as IP addresses), and serve targeted ads.

Finboo may also use social media plug-ins, allowing integration with platforms such as Facebook and LinkedIn. When interacting with these plug-ins, your browser establishes a direct connection with the respective social network’s server, which may then process your data in accordance with its own privacy policies.

Since Finboo does not control how social networks handle your data, we recommend reviewing their respective privacy policies for more details.

10. Managing Cookies

Most internet browsers accept cookies by default. However, users may modify browser settings to disable cookies at any time. Please note that disabling cookies may affect the availability of certain services on our website.

If you do not adjust your browser settings to disable cookies, your continued use of our website will be considered as consent to our use of cookies.

11. Data retention

The retention period for personal data collected by Finboo is determined based on:

Legal obligations:
If applicable laws specify a mandatory retention period, we comply with those regulations. Once the required period ends, necessary actions will be taken.
Legitimate business needs:
If no specific retention period is outlined by law, data is stored only as long as necessary for legitimate business purposes. Any data that no longer aligns with lawful retention principles will be deleted, anonymized, or destroyed.

Personal data processed under applicable regulations will be erased either automatically by Finboo or upon request from the data subject, provided that the legal grounds for data processing no longer exist.

12. Updates to this Privacy Policy

Finboo reserves the right to update this Privacy Policy at any time. Any changes will be published on our website. In significant cases, we may also notify users via email or other appropriate communication methods.

Your continued use of our services following such updates constitutes acceptance of the revised Privacy Policy. If you disagree with any changes, you may choose to discontinue using our services or delete your account.

13. FINAL REMARKS

For any questions regarding this Privacy Policy or data protection rights, you may contact Finboo at info@finboo.io.