QuantoPay s.r.o is a company registered in Czech Republic with company number 08907641, QuantoPay LTD is a limited liability company registered in England and Wales with company number 09992090 and QTP HOLDINGS LTD is a limited liability company registered in Gibraltar with company number 117353 (jointly “QuantoPay”), having as business objectives to build and operate a technical platform that will facilitate and support financial services through a mobile application, dedicated to physical persons having an EEA residence and an UK residence.
If you have concerns about how we use your personal data, you can contact our Data Protection Officer at email@example.com for EU users for UK users please contact firstname.lastname@example.org
1. HOW, WHEN AND WHY DO WE COLLECT AND USE PERSONAL INFORMATION?
How we collect your personal information
- fill in any forms;
- correspond with us;
- register to use the Project app;
- open an account or use any of our services;
- take part in online discussions, surveys or promotions.
- speak with a member of our customer support team (either on the phone or through the Project app);
- enter a competition; or
- contact us for other reasons.
Personal Information that we collect. The types of information that we may collect from you (directly or indirectly) are the following:
- your name;
- your email address;
- your physical address;
- your IP address;
- any other information that you choose to provide to us when filling out a contact form on our Websites or contribute to our projects;
- your geographic location (country/territory where you are living and/or working);
- your bank account details (when the service provided require holding such information);
- your passport copy or any civil identification
- any other additional information we may be obliged to collect in order to comply
- with applicable AML and KYC laws, as follows:
- date and place of birth (for an individual);
- phone number;
- proof of a residential address (for an individual), or a principal place of
- business, local office, or other physical location (for a person other than an individual); and
- proof of identification with a photograph (selfie with passport in hand)
How we use your Personal Information. We may use your Personal Information for our business purposes such as:
- to process and respond to inquiries and provide our services or support to your
- QuantoPay PROJECTs/contributions of our projects
- to manage our relationship with you
- to market our services or events
- to send notices, newsletters, publications
- record keeping, internal reporting and research purposes;
- to ensure network and information security;
- to notify you about changes to our services;
- send information to you regarding changes to our Terms and Conditions of
- meet legal requirements;
- to investigate any complaint you make;
- to provide evidence in any dispute or anticipated dispute between you and us;
- to customise various aspects of our websites to improve your experience;
- to host, maintain and otherwise support the operation of our websites;
- for the detection and prevention of fraud and other criminal offences and for risk management purposes and compliance with AML and KYC laws and regulations;
- for business and disaster recovery (e.g. to create back-ups);
- for document retention/storage;
- for database management; or
- to ensure the quality of the services we provide to our users.
In addition, we may use your Personal Information for further specific purposes made clear at the point of collection. If you choose not to provide Personal Information requested by us, we may not be able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the Personal Information. If you wish not to receive any marketing materials, please contact us directly to email@example.com.
Legal grounds for collection and use of Personal Information. We process your personal information where we need to do so:
- to comply with our legal and regulatory obligations;
- for our legitimate interests in:
- responding to your queries;
- providing services and/or information to you;
We consider that the risk to your data protection rights in connection with Personal Information that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protections for your rights by ensuring proper retention periods and security controls.
2. HOW AND WHEN DO WE SHARE INFORMATION WITH THIRD PARTIES?
Some services that we provide require the involvement of third parties. We have carefully selected these third parties and taken steps to ensure that your Personal Information is adequately protected. Details about how we share Personal Information with third parties is set out below:
Sharing within the QuantoPay group of companies. Your Personal Information are shared within the QuantoPay group of companies:
- if you ask that we should do so;
- where we need to do so in order to provide the services or information that you have requested.
- When a group member would like to use your Personal Information for a new
- purpose, he will let you know about this first.
Sharing with other third parties. We share your Personal Information with:
- our accountants, auditors, lawyers or similar advisers when we ask them to provide us with professional advice, however, only after prior explicit consent from your side;
- aany other third party if we are under a duty to disclose or share your Personal Information in order to comply with any legal obligation, or to protect the rights, property and/or safety of the QuantoPay group of companies, our personnel or others; ora
- any other third party for the purposes of acting in accordance with the requirements of a court, regulator or government agency, for example, complying with a search warrant or court order or acting in accordance with an applicable law or regulation.
3. HOW LONG DO WE STORE PERSONAL INFORMATION?
It is our policy to retain your Personal Information for the length of time required for the specific purpose or purposes for which it was collected. However, we may be obliged to store some Personal Information for a longer time, taking into account factors including:
- legal obligation(s) under applicable law to retain data for a certain period of time;
- the statute of limitations under applicable law(s);
- (potential) disputes; and
- guidelines issued by relevant data protection authorities.
4. WHAT ARE YOUR RIGHTS ?
You have the right to
Reviewing, Correcting and Removing Your Personal Information. You have the following data protection rights:
- You can request access, correction, updates or deletion of your personal information;
- You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information;
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent; or
- You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.
To exercise any of these rights, please contact our Data Protection Officer We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
Our Acceptable Use Policy applies to us and to our contributors and, among other things, prohibits use of the QuantoPay PROJECT Service to send unsolicited commercial email in violation of applicable laws, and requires the inclusion in every email sent using the QuantoPay PROJECT Service of an "opt-out" mechanism and other required information. We require all of our contributors to agree to adhere to the Acceptable Use Policy at all times, and any violations of the Acceptable Use Policy by a contributor can result in immediate suspension or termination of the QuantoPay PROJECT Service.
You may unsubscribe from our marketing communications by clicking on the "unsubscribe" link located on the bottom of our e-mails, updating your communication preferences, or by sending us email our Data protection Officer.
Contributors cannot opt out of receiving transactional emails related to their account with us or the QuantoPay PROJECT Service.
Our Partners are solely responsible for their own marketing emails and other communications; we cannot unsubscribe you from their communications. You can unsubscribe from our Partners’ marketing communications by clicking on the "unsubscribe" link located on the bottom of their emails, or by contacting them directly.
6. HOW DO WE PROTECT YOU?
We have implemented reasonable administrative, technical and physical measures to protect your personal information against loss, misuse and alteration.
7. HOW DO WE PROTECT YOUR CONFIDENTIALITY?
SPECIFIC FURTHER EXPLANATION
1. HOW OUR CONTRIBUTORS USE THE QuantoPay PROJECT SERVICE?
Our online QuantoPay PROJECT Service allows any individual and company that uses it (our contributors) to use its overall service content. The QuantoPay PROJECT Service user adds its information, which will be stored and managed on our service providers' servers. This information is then used to contact contributors about their contribution and to provide own marketing, lead generation, and contributor service needs.
We may transfer Personal Information to companies that help us provide our service. Transfers to subsequent third parties are covered by the service agreements with our contributors.
2. WHAT INFORMATION WE COLLECT?
When You Visit our Websites
You are free to explore the Websites without providing any Personal Information about yourself. When you visit the Websites or register for the QuantoPay PROJECT Service, we request that you provide Personal Information about yourself, and we collect Navigational Information.
When You Use our Mobile Application
We use mobile analytics software to allow us to better understand the functionality of our Mobile Apps on your mobile device. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from. In addition to information we collect on our Websites, when you use our Mobile Apps we may also collect your city location, device model and version, device identifier (or “UDID”), OS version, and your QuantoPay PROJECT Service credentials.
We send push notifications from time to time in order to update you about events or promotions. If you no longer wish to receive such communications, you may turn them off at the device level. We may link information we store within the analytics software to Personal Information you submit within the Mobile App. We do this to improve services we offer you and improve our marketing, analytics and site functionality. "Personal Information" this refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business. Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers. Personal Information also includes Navigational Information or Payment Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to this website such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.
Please see the "Navigation Information" section below. Payment information includes We collect and process payment information from you when you subscribe to the QuantoPay PROJECT Service, including credit cards numbers and billing information, using third-party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.
When you use our services our view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by us for the. operation of the QuantoPay PROJECT Service, to maintain the quality of the. QuantoPay PROJECT Service, and to provide general statistics regarding use of our Websites. For these purposes, we do link this automatically collected data to Personal. Information such as name, email address, address, and phone number.
Information we collect from third parties
From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint. marketing activities, and publicly available sources such as social media websites.
Information About Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at firstname.lastname@example.org, so that we may delete the information.
3. HOW WE USE THE INFORMATION WE COLLECT?
We will never sell or otherwise passing on your Personal Information to any third party.
- improve your browsing experience by personalizing the Websites and to improve the QuantoPay PROJECT Service;
- send information to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
- promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
- provide other companies with statistical information about our users, but this information will not be used to identify any individual user;
- meet legal requirements. We may, from time to time, contact you on behalf of external business partners about a particular service that may be of interest to you. In those cases, we do not transfer your Personal Information to the third party. In addition to above mentioned, we use the information collected through our QuantoPay PROJECT Service by our contributors for the following purposes:
- to provide the QuantoPay PROJECT Service (which may include the detection, prevention and resolution of security and technical issues);
- to respond to contributor support requests; and
- otherwise to fulfil the obligations under the Terms of Service.
Legal basis for processing Personal Information (“UK” and “EEA” visitors only)
If you are a visitor/contributor located in the United Kingdom ("UK"), you can complain to the ICO if you are unhappy with how we have used your data.
The ICO’s address: Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, Helpline number: 0303 123 1113
If you are a visitor/contributor located in the European Economic Area (EEA), you can complain to the European Data Protection Supervisor (“EDPS”). If you think that we don’t protect properly your personal data
The EDPS address: European Data Protection Supervisor, Rue Wiertz 60, B-1047 Brussels, Belgium, E-mail: email@example.com
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.
If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.
Use of Navigational Information
We use Navigational Information to operate and improve the Websites and the. QuantoPay PROJECT Service. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about our project or related services.
Customer Testimonials and Comments
We may post contributor testimonials and comments on our Websites, which may contain Personal Information. We obtain each contributor's consent via email prior to posting the contributor's name and testimonial.
Use of Credit Card Informatio
If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.
Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures.
Social Media Features
We offer publicly accessible message boards, blogs, and community forums. Please keep in mind that if you directly disclose any information through our public message boards, blogs, or forums, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in "Opting Out and Unsubscribing" below.
Retention of Personal Information
How long we keep information we collect about you depends on the type of. information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible. We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required in order to contact you about the QuantoPay PROJECT Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements). When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not. possible, then we will securely store your Personal Information and isolate it from any. further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request, as described in "To Unsubscribe from Our Communications" below. If you provide information to our cooperation partners as part of their use of the. QuantoPay PROJECT Service, our cooperation partners decide how long to retain the. personal information they collect from you. If a cooperation partner terminates its. service for the QuantoPay PROJECT, then we will provide contributor with access to all information stored for the cooperation partner by us, including any Personal Information provided by you, for export by the cooperation partner according to our agreement with our partners. After termination, we may, unless legally prohibited, delete all cooperation partner information, including your Personal Information, from. the QuantoPay PROJECT. If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your QuantoPay PROJECT account. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
4. HOW WE SHARE INFORMATION WE COLLECT?
We employ other companies and people to provide services to visitors to our Websites, our contributors, and users of the QuantoPay PROJECT Service and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analysing data or performing statistical analysis, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing contributor service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and contributor data handling policies.
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by us on the Websites and the QuantoPay PROJECT Service. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses. of your Personal Information, and choices you may have regarding your Personal Information.
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.
5. HOW WE SHARE YOUR PERSONAL INFORMATION INTERNATIONALY?
International Transfers within QuantoPay’s Entities
International transfers to third parties
Privacy Shield Notice
If and once so required we are going to be in compliance with the EU-U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework and contributors would be informed which affiliated entities adhere to the Privacy Shield principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov.
You may direct any inquiries or complaints related to our Privacy Shield compliance to firstname.lastname@example.org. If you eventually should have an unresolved privacy or data use concern that we have not addressed satisfactorily, you may contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedbackform.truste.com/watchdog/request. Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.
UK transfers to third countries
Since Brexit, UK is not part of the EU-US privacy Shield framework anymore it has been decided on November 2020 with the Schrems II law to use the Standards Contractual Clauses validated by the ICO. We may use them for data transfers from UK to US and from UK to EU.
Cookie Title Description:
These cookies are used to store information, such as what time your current visit occurred, whether you have been to the site before, and what site referred you to the web page. These cookies contain no personally identifiable information but they will use your computer’s IP address to know from where in the world you are accessing the Internet. Google stores the information collected by these cookies on servers in the United States. Google may transfer this information to third-parties where required to do so by law, or. where such third-parties process the information on Google’s behalf.
Protecting Your Rights
We have developed the following tools in order to protect your rights:
- Internet Explorer: http://windows.microsoft.com/en-GB/windows7/Block-enable-orallow-cookies
- GoogleChrome: https://support.google.com/chrome/bin/answer.py?hl=enGB&answer=95647&p=cpn_cookies
- Mozilla Firefox: http://support.mozilla.org/en-US/kb/Blocking%20cookies
- Apple Safari: http://docs.info.apple.com/article.html?artnum=32467
Navigational Information Collected by Our Partners
Our Partners can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages as part or related to the QuantoPay PROJECT Service. However, we do not control our partners’ use of these tools, nor do we control the information they collect or how they use it.
You can log in to our site using a Single Sign-on (SSO) service like your Google account. This service will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our. sign up form. Such services may give you the option to post information about your activities on this Web site to your profile page to share with others within your network.
Flash Cookies and Other Third Party Tracking Technologies
Third Party Tracking Technologies
7. HOW WILL WE KEEP YOU UPDATED IN CASE OF ANY CHANGES TO THE PRIVACY NOTICE?
We keep our privacy notice under regular review and we will place any updates on our webpage. We will provide you with a new privacy notice if we make any material updates.