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CALMSWAP S.R.O. PRIVACY POLICY
1. THE INTRODUCTION
1.1. Calmswap s.r.o., ID: 21246823, registered office address at Czech Republic, Cimburkova 916/8, 130 00 Prague – Žižkov, registered in the Commercial Register kept by the Municipal Court in Prague, Section C, File 398874, hereinafter the ‘Company’, also ‘we’, or ‘us’
1.2. Calmswap s.r.o. is a personal data controller
1.3. This Privacy Policy describes how we collect, process, store and secure our customers’ personal data.
1.4. We respect the individual’s right to privacy and make all reasonable efforts to ensure the security and confidentiality of personal data and other information processed by us.
1.5. It’s of our great importance that the customer carefully reads information provided below in this Policy. We assume that the customer has carefully got acquainted with this Policy and agrees to its provisions. If the customer does not agree with this Privacy Policy, please do not apply and use our services.
1.6. If any questions subject to the provisions of this Privacy Policy occur, please do not hesitate to contact us by sending your inquiry to our support team email: [email protected], specifying in subject line - ‘Privacy Issue’. Our support team will process your request with due care, when necessary, forwarding the issue for our legal team consideration.
2. THE SCOPE
2.1. We handle your personal data in accordance with our legal obligations set by the following legal acts:
2.2. This Privacy Policy is applicable to any private individual visiting our website, applying for our services or already using our services (prospective or existing customer, director, beneficial owner or representative of the customer - legal entity), or corresponding with us (for example by email or by filling messaging forms on the website).
2.3 This Policy sets purposes for which we process personal data, who we share it with, what rights private individuals have in relation to that data and everything else we think is important for individuals to know.
2.4. To the maximum extent permitted by applicable legal acts to process personal data, we may engage third persons acting as data processors. In such a case, we will take all reasonable measures to ensure that personal data is processed by the personal data processors in strict compliance with instructions provided by us and applicable legal acts. We will also ensure that personal data processors will implement appropriate measures for the security of personal data corresponding to the highest security standards. All data processors are under the strict non-disclosing obligation and will not be able to use personal data processed for any other purpose, except to the extent necessary to perform their contractual obligations assigned by us.
2.5. We use different methods to collect data from and about the customer including through:
3.THE PERSONAL DATA WE COLLECT
3.1. To start provision of our services we need first to establish and verify the identity of the customer.
3.2. We are bound by applicable anti-money laundering, counter terrorism and proliferation financing (AML/CTF/CPF) regulatory requirements to (i) get full understanding of who the customer is – Know Your Customer (KYC) measures, (ii) conduct mandatory sanctions and PEP screenings, (iii) maintain actual data about the existing customer and his/her identity at any time within the lifetime of the established business relationships – Due Diligence (DD) measures, (iv) assess or reassess AML/CTF risk type a particular customer poses; (v) get full understanding of customer’s transactions and behaviour, detect in a timely manner any suspicious activity – Ongoing monitoring measures (date, information of payer and payee, i. e. name, surname, wallet and card number, payment account number, purpose of transaction, amount of transaction and etc.); (vi) AML/CTF/CPF collected data and documents retention.
3.3. To meet our regulatory requirements specified above in this Section, we retain the right to collect, process and store the following personal data:
3.4. The list of required data provided in Cl. 3.3 above is not exhaustive and may vary case by case and the scope of information requested is at our sole discretion. When that is necessary, the customer will be prompted to provide such information without undue delay.
3.5. For more information subject to our AML/CTF/CPF regulatory obligations and applicable KYC measures please refer to our AML Policy available on our website.
3.6. If the customer contacts us, we will keep a record of that correspondence (i.e., date of the letter, subject, the content of the correspondence, communication channels, etc.).
3.7. We collect and process personal data to satisfy customers’ complaints, refund requests and chargebacks (claims and complaints, responses, messages, details of such communication).
3.9. We collect and process customer’s personal data to support the customer in respect of services provided and any other matter the customer may have in relation to the services provided; to let the customer know about upcoming amendments to the legal documents available on the website, fee schedule, services provided, website and/or mobile APP, if any, as well as other important information.
3.10. We collect and process customer’s personal data to ensure the functionality of the website and mobile APP, if any, and to provide further updates and improvements (cookies, IP addresses, clicks, visited sections, cookies and other searching preferences).
3.11.We process customer’s personal data on the following legal grounds:
3.12. The customer may at any time edit, update, or delete his/her personal data contacting our support team.
3.13. Please note that amendments to personal data or data deletion request may lead to suspension or even termination of provision of services and our cooperation. Each such request will fall under comprehensive legal and compliance team investigation.
3.14. Please also note that personal data being in our possession may not be deleted under the customer’s request in breach of the minimal data retention period set by applicable AML/CTF laws and regulations. Since the minimum regulatory set data retention period is met, your personal data will be deleted automatically.
3.15. If customer provides personal data of any individual other than customer (director, beneficial owner, representative) to get our services and become a customer of us or within the lifetime of already established business relationships, then the customer prior to submit us third person’s data should obtained consent from such individual to disclose his/her personal data. Customer shall bear full responsibility towards such individuals if the customer has not received proper consent for third person’s personal data submission and the customer undertakes to indemnify us for any liability which may appear due to unlawful provision and/or disclosure of third person’s personal data. This liability provision does not apply if such individual personally provides personal data processing consent directly to us (in person, via the website or mobile APP, or in any way described above in this Privacy Policy).
3.16. We do not knowingly collect personally identifiable information from or about children under 18 years of age. In the case we discover that a child under 18 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to take necessary actions.
4. HOW WE SHARE PERSONAL DATA
4.1. To provide the services and meet our regulatory obligations, we use third parties' services, and such third parties use personal data in delivering their services to us.
4.2. We may share personal data we collect with our service providers (data processors) such as:
4.3. We share personal data only with those data processors which ensure safeguards and use technical and organisational security measures equivalent to the ones required by the Czech Republic and European Union EU and applied by us.
4.4. The personal data that we collect will be transferred to, and stored at, a destination inside the EU and the European Economic Area (EEA).
4.5. Personal data may be processed outside the EU or EEA to fulfil our contractual obligations towards the customers to provide the services (to execute an international payment, process payment details, provide global AML/CTF/CPF solutions, and provide ongoing support services). We will take all steps to ensure that personal data is treated securely and in accordance with this Privacy Policy.
4.6. We will expressly inform the customer that his/her personal data will be processed outside the EU or EEA, providing data transferring and processing purpose and legal ground. If the customer after such notification continues to use our services, it shall be treated as the customer’s consent to personal data transfer outside the EU or EEA. If the customer does not agree to data transfer outside the EU or EEA, the customer shall stop using the services immediately and terminate business relationships with us.
4.7. We may need to share customers’ personal data to state and public authorities. We will only do so when we are legally required to provide information (we are regulatory bound to provide customers and transactions data to the supervising authorities for reporting and supervising purposes) or when we need to take legal action to defend our rights, as well as the cases, where we have a belief in good faith that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request, enforce applicable Terms of Services, including investigation of potential violations, detect, prevent or otherwise address AML/CTF/CPF crimes, fraud, security or technical issues.
5. CUSTOMER’S RIGHTS
5.1. The customer is entitled to request:
5.2. The right to object to processing of personal data when processing is carried out based on legitimate interest: this right can be exercised in a situation where we are relying on our legitimate interest (or those of a third party) but such processing impacts on customer’s fundamental rights and freedoms.
5.3. The customer also has the right to object where we are processing his/her personal data for direct marketing purposes.
5.4. To exercise any of the rights mentioned above, please reach out to our support team via email [email protected]. We may ask the customer to verify his/her identity and for more information regarding such request.
6. PERSONAL DATA RETENTION
6.1. We will only retain personal data for as long as reasonably necessary, at least for a 5 (five) years period, to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory (including AML/CTF/CPF), tax, accounting or reporting requirements.
6.2. We may retain personal data for a longer period in the event we are required to do so by applicable legal acts, in case of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with the customer.
7. THE COOKIES
7.1. We use cookies to collect information and to improve our services.
7.2. Customer has the option to either accept or refuse cookies. If the customer chooses to refuse our cookies, some of our services may not be available.
7.3. We use the following cookies:
7.4. When the customer enters our websites for the first time, we provide opportunity to accept or decline the usage of cookies. The customer is able to granularly accept cookies, meaning that customer will have a choice on what type of cookies customer will allow. The customer can also delete and block cookies at any time from our website through his/her browser. However, note that some features on this website will not function without cookies.
7.5. Our website may contain links to other websites. If the customer clicks on a third-party link, the customer will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise reviewing a privacy policy applicable to those websites. We have no control over and take no responsibility for the content, privacy policies, cookies or practices of any third-party sites or services.
8. COMPLAINTS
8.1. The customer is entitled to lodge a complaint with the Office for Personal Data Protection of the Czech Republic (UOOU), pplk. Sochora 727/27, 170 00 Prague 7 – Holešovice, tel.: +420 234 665 111, https://uoou.gov.cz, email: [email protected], if the customer may reasonably believe that his/her rights may have been infringed.
8.2. We would, however, appreciate the chance to deal with customer’s concerns before the customer approaches the UOOU and find a solution at customer’s satisfaction. So please contact us in the first instance.
9. CHANGES TO THE PRIVACY POLICY
9.1. This Privacy Policy will regularly be updated to reflect any changes in the way we handle your personal data or any changes in applicable laws.
9.2 .We will notify the customer in a timely manner on any changes to this Privacy Policy. If the customer does not agree to the amendments made, the customer shall stop using our services and shall terminate business relationships established with us in a time and manner set in our Terms of Services.
9.3. If the customer continues to use our services irrespective of the amendments made by us to this Privacy Policy, it should be treated as the customer's consent to the amendments made and updated version of this Policy.
9.4. We retain the right to notify the customer on any amendments made to this Privacy Policy by emailing the customer or by posting amendments on our website. Please follow any new releases and information posted on our website.
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