1.1 We are committed to safeguarding the privacy of our website visitors and service users.
1.2 This policy applies where we act as a data controller with respect to the personal data of our website visitors and service users; in other words, we determine the purposes and means of processing that personal data.
1.4 In this policy, "we", "us," and "our" refer to Finestel.
2.1 In Section 2, we have set out: (a) the general categories of personal data that we may process; (b) the purposes for which we may process personal data; and (c) the legal bases of the processing.
2.2 We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type, and version, operating system, referral source, length of visit, page views, and website navigation paths, as well as information about the timing, frequency, and pattern of your service use. The source of the usage data is our analytics tracking system. We may process this usage data to analyze the use of the website and services. The legal basis for this processing is consenting to our legitimate interests, namely monitoring and improving our website and services.
2.3 We may process your account data ("account data"). The account data may include your nickname and email address. The source of the account data is you. We may process the account data to operate our website, provide our services, ensure the security of our website and services, maintaining back-ups of our databases, and communicate with you. The legal basis for this processing is our legitimate interests, namely the performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.
2.4 We may process your information, including your profile, on our website ("profile data"). The profile data may include your nickname, email address. We may process the profile data to enable and monitor your use of our website and services. The legal basis for this processing is our legitimate interests, namely the performance of an agreement between you and us and/or taking steps, at your request, to enter into such an agreement.
2.5 We may process information contained in any inquiry you submit to us regarding goods and/or services ("inquiry data"). We may process the inquiry data for offering, marketing and selling relevant goods and/or services. The legal basis for this processing is consent.
2.6 We may process information relating to our customer relationships, including customer contact information ("customer relationship data"). The customer relationship data may include your nickname, contact details, and information in communications between you and us. The source of the customer relationship data is you. We may process the customer relationship data to manage our relationships with customers, communicate with customers, keep records of those communications and promote our products and services. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
2.7 We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website ("transaction data"). The transaction data may include your contact details and the transaction details. We may process the transaction data to supply the purchased goods and services and keep proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
2.8 We may process information contained in or relating to any communication you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. We may process the correspondence data to communicate with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
2.9 We may process your cryptocurrency exchange transactions information ("trading data"). This data may include openings and closures and other details of your deals on cryptocurrency exchange markets. The source of this data is your accounts on cryptocurrency exchange platforms which you shared with us deliberately. This data may be processed to provide relevant goods and/or services to you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
2.10 We may process any of your data identified in this policy where necessary to establish, exercise or defend legal claims, whether in court proceedings or an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
2.11 We may process any of your data identified in this policy where necessary for obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
2.12 In addition to the specific purposes for which we may process your data set out in this Section 2, we may also process any of your data where such processing is necessary for compliance with a legal obligation to which we are subject or to protect your vital interests or the vital interests of another natural person.
2.13 Please do not supply any other person's data to us unless we prompt you to do so.
3.1 We may disclose your data to any member of our group of companies (this means our subsidiaries, our ultimate holding company and all its subsidiaries) insofar as reasonably necessary for the purposes and on the legal bases set out in this policy.
3.2 We may disclose your data to our insurers and/or professional advisers insofar as reasonably necessary to obtain or maintain insurance coverage, manage risks, obtain professional advice, or establish, exercise or defend legal claims, whether in court proceedings or an administrative or out-of-court procedure.
3.3 We may disclose your trading data to our users insofar as reasonably necessary for fulfilling our obligations as per an agreement with our users. The legal basis for this disclosure is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
3.4 Financial transactions relating to our website and services are handled by our payment services providers. We may share transaction data with our payment services providers only to the extent necessary to process your payments, refunding such payments, and deal with complaints and queries relating to such payments and refunds.
3.5 In addition to the specific disclosures of personal data set out in this Section 3; we may disclose your data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your data where such disclosure is necessary to establish, exercise or defend legal claims, whether in court proceedings or an administrative or out-of-court procedure.
4.1 This Section 6 sets out our data retention policies and procedures, designed to help ensure that we comply with our legal obligations regarding the retention and deletion of personal data.
4.2 Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
4.3 Notwithstanding the other provisions of this Section 4, we may retain your data where such retention is necessary for compliance with a legal obligation to which we are subject or in order to protect your vital interests or the vital interests of another natural person.
5.1 We may update this policy from time to time by publishing a new version on our website.
5.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
6.1 In this Section 6, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all details have been included in our summaries. Accordingly, it would help to read the relevant laws and guidance from the regulatory authorities to fully explain these rights.
6.2 Your principal rights under data protection law are:
(a) the right to access;
(b) the right to rectification;
(c) the right to erasure;
(d) the right to restrict processing;
(e) the right to object to processing;
(f) the right to data portability;
(g) the right to complain to a supervisory authority;
(h) the right to withdraw consent.
6.3 You have the right to confirm whether or not we process your data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned, and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply you with a copy of your data. The first copy will be provided free, but additional copies may be subject to a reasonable fee. You can access your data when logged into our website.
6.4 You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
6.5 In some circumstances, you have the right to the erasure of your data without undue delay. Those circumstances include: the personal data are no longer necessary to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes, and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; For compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
6.6 In some circumstances, you have the right to restrict the processing of your data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful, but you oppose erasure; we no longer need the personal data for our processing, but you require personal data for the establishment, exercise, or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your data. However, we will only otherwise process it: with your consent; for the establishment, exercise, or defense of legal claims; for the protection of the rights of another natural or legal person; or reasons of important public interest.
6.7 You have the right to object to our processing of your data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by a third party or by us. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing that override your interests, rights, and freedoms. The processing is for establishing, exercising, or defense of legal claims.
6.8 You have the right to object to our processing of your data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your data for this purpose.
6.9 You have the right to object to our processing of your data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation unless the processing is necessary for the performance of a task carried out for reasons of public interest.
6.10 To the extent that the legal basis for our processing of your data is: (a) consent; or (b) that the processing is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into a contract, Such processing is carried out by automated means; you have the right to receive your data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
6.11 If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work, or the place of the alleged infringement.
6.12 To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
6.13 You may exercise any of your rights in relation to your data by written notice to us, in addition to the other methods specified in this Section
7.1 A cookie contains an identifier (a string of letters and numbers) sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
7.2 Cookies may be either "persistent" cookies or "session" cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
7.3 Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
9.1 Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via these links:
(a) https://support.google.com/chrome/answer/95647?hl=en (Chrome);
(b) https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
(c) http://www.opera.com/help/tutorials/security/cookies/ (Opera);
(d) https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
(e) https://support.apple.com/kb/PH21411 (Safari);
(f) https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge);
9.2 Blocking all cookies will have a negative impact on the usability of many websites.
9.3 If you block cookies, you will not be able to use the full list of features on our website.
10.1 This website is owned and operated by Finestel.
10.2 You can contact us: (a) using our website contact form;
(b) by email, using the email address published on our website.