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Privacy policy

Privacy policy

Introduction

Our Privacy Policy applies to your use of:

  • The Finto site hosted on [www.finto.io] which can be accessed via desktop or mobile web (Site), once you have streamed the Site onto your mobile telephone or handheld device (Device).
  • Any of the services accessible through the Site .

Our Privacy Policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. This Site is not intended for children and we do not knowingly collect data relating to children without proper parental consent. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.

Important information and who we are

[Etihad Financial Technology (Finto)] is the controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this Privacy Policy).

If you have any questions about this Privacy Policy, please contact them using the details set out below.

Contact details

Our contact details are as follows:

  • Full name of legal entity: Etihad Financial Technology (Finto)
  • Email address: [hello@finto.io]

You have the right to make a complaint at any time to the competent supervisory authority.

Changes to the Privacy Policy and your duty to inform us of changes

We may update our Privacy Policy.

This version was last updated on [9 aug 2021]. It may be changed and if it does, these changes will be posted on this page and, where appropriate, notified to you [by email or when you next open the Site]. The new Privacy Policy may be displayed on-screen and you may be required to read and accept the changes to continue with your use of the Site or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us informed on any changes to your personal data during our relationship with you.

Our Site may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies, or for any personal data that may be collected through these websites or services, such as your contact or location information.

Please review the policies of these other websites before you submit any personal data to them or use their services.

The data we collect about you

We may collect, use, store and transfer different kinds of personal data about you as follows:

  • Identity Data
  • Contact Data
  • Financial Data
  • Transaction Data
  • Device Data
  • Content Data
  • Profile Data
  • Usage Data
  • Marketing and Communications Data
  • Location Data

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data could be derived from your personal data however it is not considered personal data in law, as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific Site feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data, which will be used in accordance with this Privacy Policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about yourself by filling in forms on the Site, or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the Site, subscribe to any of our Services, site share data via social media functions, enter a competition, promotion or survey, and when you report a problem with the Site or any of our Services. If you contact us, we will keep a record of that correspondence.

Information we collect about you and your device. Each time you visit our Site we will automatically collect personal data including Device, Content and Usage Data.We collect this data using cookies and other similar technologies.

Location Data. We also use GPS technology and other location technologies to determine your current location. Some of our location-enabled Services require your personal data for the feature to work. If you wish to use this particular feature, you will be asked to consent to your data being used for this purpose. You can withdraw your consent at any time by disabling Location Data in yourDevice’s settings.

Information we receive from other sources including third parties and publicly available sources.We will receive personal data about you from various third parties and public sources as set out below:

  • Device Data from the following parties:
    • analytics providers;
    • advertising networks; and
    • search information providers.
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
  • Identity and Contact Data from data brokers or aggregators;
  • Identity and Contact Data from publicly available sources; and
  • Cookies

We use/may use cookies and/or other tracking technologies to distinguish you from other users of the Site and to remember your preferences. This assists us in providing you with a good experience when you use the Site and also allows us to improve the Site. For detailed information on the cookies we use, the purposes for which we use them and how you can exercise your choices regarding our use of your cookies, see our cookie policy.

How we use your personal data

We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:

  • Where you have consented before the processing of the data.
  • Where we need to perform a contract we are about to enter or have entered with you
  • Where it is necessary for our legitimate interests (or those of a third party)and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal or regulatory obligation.

Please see Glossary: Lawful Basis below to find out more about the types of lawful basis that we will rely on to process your personal data.

We will only send you direct marketing communications by email or text if w e ave your consent. You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose / Activity

Type of data

Lawful basis for processing

To register you as a new Site user

  • Identity
  • Contact
  • Device

Your consent

To process in-Site purchases and deliver Services including managing payments and collecting payments

  • Identity
  • Contact
  • Financial
  • Transaction
  • Device
  • Marketing and Communications
  • Location
  • Your consent
  • Performance of a contract with you
  • Necessary for our legitimate interests (to recover payments due to us)

To manage our relationship with you including notifying you of changes to the Site or any Services

  • Identity
  • Contact
  • Financial
  • Profile
  • Marketing and Communications
  • Your consent
  • Performance of a contract with you
  • Necessary for our legitimate interests (to keep records updated and to analyze how customers use our Services)
  • Necessary to comply with legal obligations (to inform you of any changes to our Terms of Use, this Privacy Policy, etc.)

To enable you to participate in a prize draw, competition or complete a survey

  • Identity
  • Contact
  • Device
  • Profile
  • Marketing and Communications
  • Your consent
  • Performance of a contract with you
  • Necessary for our legitimate interests (to analyze how customers use our Services, to further develop such Services, and to grow our business)

To administer and protect our business and this Site including troubleshooting, data analysis and system testing

  • Identity
  • Contact
  • Device

Necessary for our legitimate interests (for running our business, provision of administration and IT services, and network security)

  • To deliver content and advertisements to you
  • To make recommendations to you about products or services which may interest you
  • To measure and analyze the effectiveness of the advertising we serve you
  • To monitor trends so we can improve the Site
  • Identity
  • Contact
  • Device
  • Content
  • Profile
  • Usage
  • Marketing and Communications
  • Location
  • Your consent
  • Performance of a contract with you
  • Necessary for our legitimate interests (to further develop our Services and to grow our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you to provide your consent to share your personal data with the third parties set out below for the purposes set out in the above data.

  • Internal Third Parties as set out in the Third parties section below.
  • External Third Parties as set out in the Third parties section below.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets with. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Policy.

International transfers

Whenever we transfer your personal data out of Jordan, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data.
  • Where we use certain service providers, we may use specific contracts which provide an adequate level of protection for personal data.
  • Please contact us if you want further information regarding transferring your personal data out of Jordan.

Indemnification

You agree to indemnify and hold us and our affiliates, officers, directors, employees, agents, suppliers or licensors harmless from and against any liabilities, losses, damages or costs, including reasonable attorneys' fees, incurred in connection with or arising from any third-party claims, allegations, disputes, actions or demands asserted against any of them as a result of or relating to your content, data, your use of our Site or services or any wilful misconduct on your part.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using [Secured Sockets Layer technology OR ALTERNATIVE ENCRYPTION TECHNOLOGY]. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way.

We will collect and store personal data on your Device using [application data caches and browser web storage (including HTML5)].

Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.

Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect of our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances, you can ask us to delete your data, see the Your legal rights section below for further information.

In some circumstances, we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Under certain circumstances you have the following rights under data protection laws in relation to your personal data:

Request access to your personal data (commonly known as a “data subject access request”).  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your personal data, where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

  • if you want us to establish the data's accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.  However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You also have the right to ask us not to continue to process your personal data for marketing purposes.

You can exercise any of these rights at any time by contacting us at [hello@finto.io].

Glossary: Lawful Basis

“Consent” means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.

“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

“Comply” with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

How we may use your personal information

We will only use your personal information as set out in our privacy policy.

Third parties

Internal third partiess

Other companies in the Finto group acting as joint controllers or processors, providing IT and system administration services and undertaking leadership reporting.

External third parties

Service providers acting as processors who provide IT and system administration services.

Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Regulators and other authorities

Description of categories of personal data

Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.

Contact Data: billing address, delivery address, email address and telephone numbers.

Financial Data: bank account and payment card details.

Transaction Data: includes details about payments to and from you and details of in-Site purchases.

Device Data: includes the type of mobile device you use, a unique device identifier, mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.

Content Data: includes information stored on your Device, including login information, digital content.

Profile Data: includes your username and password, in-Site purchase history, your interests, preferences, feedback and survey responses.

Usage Data: includes details of your use of any of our applications or your visits to any of our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.

Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.

Location Data: includes your current location disclosed by GPS technology or other location technologies.