Privacy policy

At FitechFuel we understand that your privacy is important to you and that you care about how your personal data is used. We will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the applicable local legislation. This Privacy Policy sets out the basis on which we may collect, use or otherwise process personal data via our website https://fintechfuel.com/ (Website), downloadable software, mobile applications, desktop applications, content, features, function and/or via any other services provided by us and on which a link to this Privacy Policy is displayed, and/or all other communication with you through written or oral means, such as email, chat or phone (collectively the “Services”) when you use our Services and the choices you have associated with that personal data.

Please note that this Privacy Policy is addressed to our prospective, current and former clients. If you are, were or may be a potential, FinTech employee your personal information will be used in connection with your employment in accordance with our separate policy which are available at security@fintechfuel.com.

We use your personal data to provide and improve our Services. Your acceptance of this Privacy Policy is deemed to occur upon your first use of our website and any of the Service.

Who We Are

FINTECHFUEL LTD, a corporation registered in the Republic Marshall Islands under registration number 121558 and have our registered office at Trust Company Complex, Ajeltake Road, Ajeltake Island, Majuro, Republic of the Marshall Islands, MH 96960 (hereinafter “FinTech” or “Company”). FinTech is the controller and responsible for the personal information you disclose to us to make use of our Services.

FinTech has partners and affiliated entities across the world, so when we mention “FinTech”, “FinTech Affiliates”“Company”, “we” or “us” in this Privacy Policy we are referring to the relevant partner or affiliated company responsible for collecting and/or processing your personal data when you use the Services. FinTech respects your privacy and therefore all the companies within the FinTech Affiliates, are committed to protect your data, which it collects and/or has access to.

DATA COLLECTIONS AND PROCESSING

We collect, process, store and transfer different kinds of personal data about you for various purposes in order to be able to provide and improve our Service to you. Depending upon your use of the Service we may collect some or all the personal data set out below as follows. Please also see the Cookies Section for more information about our use of Cookies and similar technologies.

• Identity Data includes first name, last name, and patronymic (if available), date of birth gender, passport, ID, Driver’s number, and copy of photo.
• Contact Data includes billing address, email address and telephone numbers.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in type and versions, operating system and platform, and other technologies on the devices you use to access the Website and use of cookies stored on your device.
• Usage Data includes information about how you use Website, products and Services and IP history.
• Data in KYC (Know your customer) includes identity document information, including copies of recent dated Utility Bills, Identity Card, Passport, and/or Driver’s License, Tax Identification Numbers (TIN).
• Location Data includes details on your actual location when interacting with our Website (for example, a set of parameters that determine regional settings of your interface, namely residency country, time zone, and the interface language)
• Audio Data includes full voice recordings of calls that you receive from us or make to us.
• Aggregated Data includes statistical or demographic data for any purpose. Such data can be derived from your data but may not be considered personal data in law as it will not directly or indirectly reveal your identity. An example of such Aggregated Data could be that we aggregate your Usage Data to calculate the percentage of users accessing a specific website feature and/or services/product preference. Notwithstanding the above, if FinTech combines Aggregate Data with data in a way that the end result can in any way identify the data subject, FinTech shall treat such combined data as data which will be treated as per the provisions herein contained. (the above collectively referred to as “personal data”).

We may obtain information about you during direct interactions with us. You may provide us with your personal information (including personal identifiers, financial information, government identifiers, and professional or employment data) by filling in forms such as our account application, by contacting us regarding our Services, or by responding to our marketing activities. We may also obtain information about you through our affiliates, vendors, and other third parties.

We may also obtain personal information about you from publicly available sources and from companies that we do business with, such as consumer and investigative reporting agencies we use to conduct background checks, verify your identity, creditworthiness, and Know Your Customer (“KYC”) requirements. Furthermore, your interactions with third parties linked to our Services, your interactions with our social media sites, ad campaigns, and other information from publicly available sources, such as public websites, may also provide us with personal information. Please be aware that third-party websites and social media sites are governed by their own privacy policies separate from our own.

CHILDREN

Our Website is not intended for children and we do not knowingly collect data relating to children. As we do not allow users under the age of 18 to use our services, we need to obtain your birth date in order to confirm the Clients’ age checks.

PROCESSING OF YOUR DATA

FinTech may process your personal data for any of the following reasons:

• To perform its contract with you,
• To comply with its legal and regulatory obligations, including without limitation to the,
• To perform compliance checks, such as verification of your identity, and helping to detect fraudulent or malicious activity on our site or services,
• To maintain our accounts and records,
• To manage our business needs, such as monitoring, analysing, and improving the Services and the Website’s performance and functionality,
• To comply with all applicable laws and regulations;
• For the purposes of safeguarding our legitimate interests and your interests and fundamental rights do not override those interests; and/or
• Other grounds.

DATA RETENTION

We will not keep your personal data for any longer than is necessary considering the reason(s) for which it was first collected in accordance with this Privacy Policy.

To comply with the applicable legal, regulatory, tax, accounting requirements we keep your personal data for a minimum period of 5 years from the date our business relationship is terminated. We may retain your information for a longer period where deem appropriate for any reason and/or where we need the information to comply with regulatory or legal requirements or where we may need it for our legitimate business purposes, such as to respond to queries or complaints, fighting fraud and financial crime and responding to requests from regulators.

At the expiration of the personal data retention period the personal data is erased by irreversible destruction and we also inform all third parties, to whom the personal data was transferred, regarding such erasure and request implementation of similar actions on their part.

DATA SECURITY

We protect your data by adhering to industry standard regulations on data protection by categorising them into data types (e.g. technical, personal data, cookie data, etc) while applying relevant protection processes and due diligence procedures. Therefore, we apply appropriate technical and organisational controls to protect your data, including secure computer systems adopting least privilege access in order to prevent unauthorised access, disclosure, modification, or destruction of personal data. Any hard copy documents are locked in a secure cabinet, and destroyed once no longer required.

Encryption of your data in transit. Encryption provides a high level of security and privacy for your personal data. When personal data in provided when using our Services, we use strong encryption technologies (such as Transport Layer Security) to protect the personal data during transmission from your devices to our servers.

For providing more trust and security we use digital EV (Extended Validation) Certificates issued by trusted Certificate Authorities. You can see the ‘Green Bar’ in the supported browser versions which confirms what all transmitted personal data is secure.

Protection of your personal data in our infrastructure. We make it a priority to develop Services that are secure "by default". The "default" security of our Services means that every new services and features are designed with strict security requirements in mind before we even begin development. This is the key to guaranteed protection and privacy of all personal data that our Services handle and store, once the service or new feature is released.

To secure personal data, we use the pseudonymisation which allows most of our Services to operate without using your actual data. Instead of that, our services use a system ID that can't be traced back to identify you.

FinTech is always vigilant about the Security of the personal data stored in our infrastructure. Because of that we locate all our equipment used for your personal data processing in secure personal data centres. Network access to this equipment is isolated from the Internet. We use network segmentation for isolation of Services which need different level of security from each other. In addition, we restrict logical access to the personal data for our employees on "need to know" basis. So, only personnel, who really require access to the personal data for the purpose of providing you with our best Service, will have access to it.

Threats protection. FinTech is highly knowledgeable about modern threats to personal data security and privacy, and we are well prepared to combat them. All events that occur in our infrastructure are continuously monitored, analysed and responded, which allows us to ensure proper protection of your personal data, keeping it safe from threats, vulnerabilities, and the effects of malware.

In the event of a failure that affects the accessibility of your personal data, we have personal data backup and recovery procedures in place that will help us to restore your personal data in a short time. For further guarantee the quick recovery we use high availability mode enabled for most critical databases which allows us to minimise downtime.

Employee awareness of data security. Our employees may handle your personal data in order to provide you with the first-class Service. To guarantee the security and confidentiality of your personal data, we monitor all employees’ actions with access to your personal data in our systems and grant access strictly on a "need to know" basis: only employees who need access will receive it. We hold regular training sessions to make sure that each employee understands the principles that FinTech follows to achieve robust data security and privacy.

If you choose not to give your personal information. In the context of our business relationship we may need to collect data by law, or under the terms of a contract we have with you. Without this data, we are, in principle, not in a position to close or execute a contract with you. If you choose not to give us this data, it may delay or prevent us from meeting our obligations. It may also mean that we cannot perform the Services.

To what extent we carry automated decision-making and profiling. In establishing and carrying out a business relationship, we generally do not use automated decision-making. If we use this procedure in individual cases, we will inform you of this separately. In some cases, we may proceed with profiling in order to evaluate certain personal aspects. We shall inform you accordingly in case we perform any profiling. In general, any data collection that is optional would be made clear at the point of collection.

DATA COLLECTIONS

We use different methods to collect data from and about you including through:

Direct Interactions. You will provide to us your Identity, Contact and Financial Data online through the Website and/or by completing and filling online forms and/or by corresponding with us by emails or otherwise.

We require to collect the above data in order to that we are able to (i) provide our services efficiently, (ii) to comply with our ongoing legal and regulatory obligations, including, inter alia, (a) to prevent fraud and money laundering acts and/or (b) conduct the assessment of suitability and appropriateness test.

If you fail to provide the data when requested we may not be able to perform the contract we have or trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a Service you have with us but we will notify you if this is the case at the time.

It is important that the data we hold about you is accurate and current. Please keep us informed if your data changes during your relationship with us.

Automated Technologies or Interactions. When using our services, your device automatically transmits to us its technical characteristics. Locale (a set of parameters that determine regional settings of your interface, namely, residence country, time zone and the interface language) is used for the purpose of providing you with the best possible service within our platform.

Using the information about IP address, cookies files, information about browser and operating system used, the date and time of access to the site, and the requested pages addresses allows us to provide you with the optimal operation on our web application, mobile and/or desktop versions of our application and monitor your behaviour for the purpose of improving the efficiency and usability of our Services.

We use web analytics tools to track performance of our website and marketing source of user by cookies in order to optimize our marketing costs and provide users with better experience.

You may at any time request that we refrain from any such transmissions (to the degree this is possible and subject to any of our legal obligations) by sending your request to the DPO using our details in the OUR CONTACT DETAILS below using the registered email address you disclosed and registered with us. We will address your request within 30 business days.

COOKIES

A cookie is a small amount of data that often includes a unique identifier that is sent to your computer or device browser from a website's computer and is stored on your device's hard drive for tracking site usage. A website may send its own cookie to your browser if your browser's preferences allow it, but, to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other websites. First-party cookies are those placed directly by us and are used only by us. We use cookies to facilitate and improve your experience of our Website and to provide and improve our products and Services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is always protected and respected.

By using our Website, you may also receive certain third-party cookies on your computer or device. Third-party cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to the table below. All Cookies used by and on our Website are used in accordance with applicable legislation on the use of cookies

Our Website uses analytics services, which are a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Website is used. This, in turn, enables us to improve our Website and the Services offered through it. You do not have to allow us to use these cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Website, it does enable us to continually improve our Website, making it a better and more useful experience for you.

You will be required to provide cookie consent by acknowledging the privacy and cookie policies during registration of your account. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended.

You can choose to delete cookies on your computer or device at any time, however you may lose any information that enables you to access our Website more quickly and efficiently including, but not limited to, login and personalisation settings. It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

You can instruct your browser to enable or disable cookies, refuse all cookies or to indicate when a cookie is being sent. Please note that by doing so you may not be able to use all the provided functions of our Website and/or Services in full.

We use the following cookies:

Please see our https://fintechfuel.com/cookie-policy for further details.

DISCLOSURE OF DATA

We strive to maintain discretion with respect to client related matters and assessments of which we acquire knowledge. We may disclose data that concerns you only if (i) we deem so and/or we are legally required to do so; (ii) if required when you expressly order us to process a transaction or any other service and (iii) it is required for the provision of our services under our contractual relationship and/or (iv) protection of our legitimate interests, in accordance with the provisions of local applicable laws and applicable local legislation as amended from time to time.

The following are examples of where and how your information may be transferred, but please note this is not an exhaustive list and that due to ongoing changes in our IT and operational infrastructure this may change at any time:

• We may share your data between the FinTech Affiliates on a confidential basis in order to provide you with our Services.

• We may have to share your personal data with third parties service providers, processing data on our behalf, who help us with our business operations. When your personal data is shared with a third party, we will take reasonable steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law. Your personal data is shared with third party organisations/entities including but not limited to:

  1. Service Providers. We may share your personal data with our trusted third party service providers, who, on our behalf, operate, maintain, and/or support our IT systems and IT infrastructure, our websites, manage our payment solutions, perform statistical analysis, marketing and advertising purposes, sending newsletters, provide customer support and perform other important services for us, including to maintain any legal obligation we may have. We will store and process your data following industry best practice and security. Some of that processing takes place at our offices and data centres in Amsterdam and Frankfurt.
  2. Regulator and state authorities. The Company will make such disclosure only if required to be disclosed by the Company by applicable law, regulation or court order and to the minimum required extent.
  3. Other disclosures. Non-affiliated companies that may assist us with, for example, transaction processing, conducting research and development, or providing custodial services. In addition to where you have consented to a disclosure of the data or where disclosure is necessary to achieve the purpose(s) for which, it was collected, data may also be disclosed in special situations, where we have reason to believe that doing so is necessary to identify, contact or bring legal action against anyone damaging, injuring, or interfering (intentionally or unintentionally) with our rights or property, users, or anyone else who could be harmed by such activities, or otherwise where necessary for the establishment, exercise or defence of legal claims.
  4. International Transfers. We process data within and outsed the EEA and countries deemed by the European Union as having adequate safeguards for protecting personal data. These countries are recognised by the EU as having suitable safeguards for the rights and freedoms of individuals and recourse processes by which data subjects can exercise their rights.
  5. Marketing. For sending you marketing communications that we believe may be of interest to you;
  6. Consent. Any other party where we have first obtained your prior consent.

If you want to obtain further information on any data transfers mentioned above please contact us using the registered email address you disclosed to us through the points of contact listed in the Section OUR CONTACT DETAILS.

ACCESS AND CHOICE

1. We may offer features through the Services that enable you to correct, update, or amend your personal information. You may also e-mail customer support (see the “Contact Us” section below), and we will comply with such a request to the extent required by law. Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion. There may also be residual information that will remain within our databases and other records, which will not be removed.
2. If you decide at any time that you no longer wish to receive marketing e-mails from us, please follow the “unsubscribe” instructions provided in such e-mails or through your account. Please note that you cannot opt out of administrative e-mails, such as regulatory, billing or service notifications.

CONTACT US

FinTech only processes your personal data in compliance with this Privacy Policy and in accordance with this Privacy Policy, while meeting highest possible data protection standards, and as such, we treat data protection complaints with all seriousness. So, should you have any reservations or complaints as to how we process(ed) your personal data, you can contact us through the following address:

To enable us to process your request, please contact us using the registered email address you disclosed and registered with us. We may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification. This is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.

If you have any questions, or want more details about how we use your data, you may contact us at the above contact details and we will be happy to provide you with further details.

CHANGES TO THIS PRIVACY POLICY

We may provide links to third party websites in our Website. These linked websites are not under our control, and we therefore cannot accept responsibility or liability for the conduct of third parties linked to our websites, including without limitation to the collection or disclosure of your data. Before disclosing your data on any other website, we encourage you to examine the terms and conditions of using that website and its privacy policies.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy was last updated in February 2024.

We have the right, at our discretion, to change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection and in order to ensure that the information herein provides relevant and adequate information about our collecting and processing of your data

In case of any changes will be posted on the revised Privacy Policy on our Website Changes will take effect as soon as the revised version is made available on our website above. Thus, we recommend that you check the Website regularly to keep up-to-date. Your comments and feedback are always welcome. You may contact us at any time through the points of contact listed in the Section OUR CONTACT DETAILS.