PRIVACY POLICY

Effective as of 15.06.2021

Latest Update: 15.07.2021

PRIVACY POLICY

This privacy policy describes how we collect, process, use and disclose your personal data in relation to your access and use of Colletra Finance services and according to all provisions laid by the General Data Protection Regulation (GDPR). Colletra Finance is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement.
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

For the purpose of providing our services we (Colletra Finance Limited) are the Data Controller. The ultimate liability lies with the Data Controller and you should address any questions you might have to the contacts details mentioned in this Privacy Policy.

TERMINOLOGY

  • ‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • ‘processing’ means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
  • ‘controller’ means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
  • ‘processor’ means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.

WHAT INFORMATION WE COLLECT


We ask for and collect from you the following personal information when you use the Colletra Finance services.
This information is necessary for us to comply with our regulatory obligations and to adequately perform our services.
When you sign up for Colletra Finance services, we require certain personal information such as:

  • First name and surname,
  • Nationality,
  • Registered address,
  • Date of birth,
  • Place of birth,
  • Mobile telephone number,
  • E-mail address,
  • Identification document and all data from the identification document such as Type of identification document Issue date, ID number, Issuing authority.
  • We may choose to collect other date in our enroll forms, which is necessary for your identification and verification.

In accordance with our legal obligations under the relevant Anti-money laundering and anti-terrorism financing regulations, we are obliged to verify your identity or the identity of the authorized user who is opening the Account.

In order to comply with relevant Anti-money laundering and anti-terrorism financing regulations we collect personal data regarding you related to your sources of income and any other similar financial information about you which would help us prevent money laundering and/or terrorism financing.

We may collect information about your computer, including your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and does not identify any individual. For the same reason, we may obtain information about your general internet usage by using a cookie file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us:

To estimate our audience size and usage pattern. To store information about your preferences, and so allow us to customize our site according to your individual interests. To speed up your searches. To recognize you when you return to our site.
You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of our site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you log on to our site.
Please note that our advertisers may also use cookies, over which we have no control.

Because of the way that World Wide Web communication standards work, when you arrive at or leave the Colletra website, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Website you visit while you are on the Colletra site, the type of browser you use and the times you access our Website. We use this information only to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with Colletra.

We collect information about your payment cards, which are issued to you by third-party issuers and are linked to your account. The information may be as follows: address of delivery of card, issue date, expiry date, IBAN or other payment account identifier to which card is linked to, currency, card transaction data, spending limits, expired cards’ details, SMS or other communication which the cardholder has received or has initiated with us, card status history, date of activation, linked cards or duplicates.

We collect information related to your payment transactions under Colletra Finance services for example when you make purchases from merchants, you receive money transfers, you accept card payments, we process payments executed by you, or you send money to friends and family.
The payment transaction information may include the payment instrument’s details used, date and time of transactions performed by you, amount of payment transaction, payment instrument expiration date and billing postcode, email address, IBAN or other account identifier information, your address and other related transaction details. This information is necessary for the adequately perform our services.

HOW WE USE THE INFORMATION WE COLLECT


We use, store, and process information, including personal information, about you to provide, understand, improve, and develop Colletra Finance services, create and maintain a secure environment, pursue our legitimate interests and comply with our legal obligations.
Initiate a payment, send or request money, acceptance of card payment, funding transaction of your Colletra account; authenticate your access to your Colletra account or your payment instrument; communicate with you about your Colletra account and payment instruments; communicate your personal information with third financial institution of Participants in your payment transaction; create an account connection between your Account and a third-party account or platform, if applicable; perform creditworthiness and other financial standing checks, evaluate applications, and compare information for accuracy and verification purposes. Detect and prevent fraud, abuse, security incidents, and other harmful activity by blocking Colletra Finance services or by applying other fraud prevention measures. Conduct security investigations and risk assessments. Conduct checks against databases and other information sources. Comply with legal obligations (such as anti-money laundering regulations). Enforce our rights, interests and claims arising from the Terms & Conditions. We process this information given our legitimate interest in improving the Colletra Finance services and our clients’ experience with it, and where it is necessary for the adequate performance of the contract with you as well as to comply with applicable laws.

WITH WHO WE SHARE PERSONAL DATA


We will not disclose your personal data to anyone except as described in this policy.

With third party service providers
We may share personal information with third party service providers that support us in providing our services, products and/or Platform with functions at our decision and our behalf. These third-party service providers may for example: verify your identity or authenticate your identification documents, facilitating technically the Video Call and/or store the Video Call recording; check information against public databases, conduct background or police checks, fraud prevention, and risk assessment, perform risk monitoring; perform product development, maintenance and debugging, allow the provision of Colletra Finance services through third party platforms and software tools (e.g. through the integration with our APIs); provide customer support; IT support and development services; card plastic production services; resell and distribute Colletra Finance products; provide technical support for Colletra Finance products; promote Colletra Finance services as business introducers, distributors, promoters, sales agents or similar; perform courier services on our behalf; provide cloud, storage or collocations services; provide audit and accountancy services; provide legal, compliance or other consultancy services. These providers have limited access only to your information necessary to perform the tasks for which they were contracted for on our behalf and are contractually bound to protect and to use it only for the purposes for which it was disclosed and consistent with this Privacy Policy.

With other financial institutions that we have contracted to enable us to provide effectively our services to our customers
These financial institutions may only use this information in order for us to provide you with the wider scope of payment features. Such may be: Correspondent banks for the purposes of settling money transfers and currency exchange operations; Domestic payment schemes for the purposes of processing domestic payments; international payment schemes for the purposes of processing euro payments; Card Organizations for the purposes of card issuing and acquiring; Financial Institutions.

With the other parties to transactions when you use our services, such as other Clients, merchants, and their service providers
We may share information with the other participants to your transactions, including other clients or payers/payees you are sending or receiving funds from, and merchants or their service providers when you use our services to pay for goods or services. The information includes: Personal Data necessary to facilitate the transaction; Personal Data to help other participant(s) resolve disputes and detect and prevent fraud; and

With other third parties for our legitimate interest or as permitted or required by law
We may share information about you with other parties for our legitimate interest or as permitted or required by law, including: if we need to do so to comply with a law, legal process or regulations; to law enforcement authorities or other government officials, or other third parties pursuant to a subpoena, a court order or other legal process or requirement applicable to us or our corporate family; if we believe, in our sole discretion, that the disclosure of Personal Data is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; to protect the vital interests of a person; with credit agencies and data processors for credit reference checks and anti-fraud and compliance purposes; to investigate violations of or enforce a user agreement or other legal terms applicable to any Service; to protect our property, Services and legal rights; to facilitate a purchase or sale of all or part of our business; in connection with shipping and related services for purchases made using a Service; in relation to promoting Colletra Finance services to end users by third party business introducers. To help assess and manage risk and prevent fraud against us, our clients and fraud involving our websites, mobile apps or use of our services, including fraud that occurs at or involves our business partners, strategic ventures, or other individuals, and merchants; to banking partners as required by card association rules for inclusion on their list of terminated merchants; to credit reporting and collection agencies; to companies that we plan to merge with or be acquired by; and to support our audit, compliance, and corporate governance functions.

We do not share your Personal Data with third parties for their marketing purposes without your consent.


Monitoring
We may monitor or record telephone calls, emails, web chat or other communications with you for regulatory, security, customer services or training purposes.

Social Media
We may review and use public comments and opinions made on social networking sites (e.g. Facebook and Twitter) to better understand our customers and our provision and development of Colletra Finance services.

YOUR RIGHTS

You may exercise any of the rights described in this section pursuant to the Terms and Conditions by sending an email from your e-mail registered to Colletra. Please note that we may ask you to verify your identity before taking further action on your request. Please note that upon receipt of your e-mail we shall try our best to provide you with the requested information and resolve your request in reasonable time, subject to all obligations which we or the related companies have under the applicable laws and the GDPR.

Managing Your Information.

You have the right to obtain the following:

  • confirmation of whether, and where, the we are processing your personal data;
  • information about the purposes of the processing;
  • information about the categories of data being processed;
  • information about the categories of recipients with whom the data may be shared;
  • information about the period for which the data will be stored (or the criteria used to determine that period);
  • information about the existence of the rights to erasure, to rectification, to restriction of processing and to object to processing;
  • information about the existence of the right to complain to any Regulator;
  • where the data was not collected from you, information as to the source of the data; and
  • information about the existence of, and an explanation of the logic involved in, any automated processing.
  • Additionally, you may request a copy of the personal data being processed.

Rectification of Inaccurate or Incomplete Information.

You have the right to ask us to correct inaccurate or incomplete personal information concerning you (and which you cannot update yourself via your online access to Colletra Account).

Data Access and Portability.

You have the right to:

  • receive a copy of your personal data in a structured, commonly used, machine-readable format that supports re-use;
  • transfer your personal data from one controller to another;
  • store your personal data for further personal use on a private device; and
  • have your personal data transmitted directly between controllers without hindrance.

In some jurisdictions, applicable law may entitle you to request copies of your personal information held by us.

Data Retention and Erasure.

We generally retain your personal information for as long as is necessary for the performance of the contract between you and us and to comply with our regulatory obligations. If you no longer want us to use your information to provide services to you, you can request that we erase your personal information and close your Colletra Account, providing your account is in good standing, not blocked or somehow limited for compliance, risk or regulatory reasons, or due to your outstanding obligation to us, court order, pledge or order by another regulator or other reason which prevent us by law to close your account or terminate the Service. In case the Data Controller is a regulated financial institution, such as credit institution, E-money institution or similar, such Data Controller is obliged under PSD and AML laws to keep your personal information and all transactions history for a period of 5 years after the termination of the relation with you. Please note that if you request the erasure of your personal information:

  • We may retain some of your personal information as necessary for our legitimate business interests, such as fraud detection and prevention and enhancing security. For example, if we suspend an Colletra Account for fraud or safety reasons, we may retain certain information from that Colletra Account to prevent that client from opening a new Colletra Account in the future. We are also obliged to retain personal data which we have collected for the purposes of complying with the relevant anti-money laundering and anti-terrorism financing for a period as defined under the applicable law.
  • We may retain and use your personal information to the extent necessary to comply with our legal obligations. For example, Colletra may keep some of your information for tax, legal reporting and auditing obligations.

Withdrawing Consent and Restriction of Processing.

Where you have provided your consent to the processing of your personal information by us you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Additionally, in some jurisdictions, applicable law may give you the right to limit the ways in which we use your personal information, in particular where (i) you contest the accuracy of your personal information; (ii) the processing is unlawful and you oppose the erasure of your personal information; (iii) we no longer need your personal information for the purposes of the processing, but you require the information for the establishment, exercise or defense of legal claims; or (iv) you have objected to the processing and pending the verification whether our legitimate grounds override your own.

Objection to Processing.

In some jurisdictions, applicable law may entitle you to require us not to process your personal information for certain specific purposes (including profiling for marketing purposes) where such processing is based on legitimate interest. If you object to such processing we will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims. Please note that Data Controllers which are regulated financial institutions, such as credit institutions, E-money institutions or similar are obliged under AML laws to make risk profiling of their customers upon opening of the relationship and constantly during the relationship and this is a legitimate reason. In case you do not wish us to process your personal data for certain specific purposes, which are legitimate purposes to us, you shall have to close your account or we may have to stop providing you some or all of the Services, subject to all conditions for the closing of the account.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes by sending an e-mail to the contact e-mails below.

COMPLAINTS


If you have any complaints you should try first to resolve the issue with us by sending an email, from you registered e-mail address with us, at dpo@colletra.com.

In case you are not satisfied with the response you can contact the respective data protection supervisory authority at commissioner@dataprotection.gov.cy .

PENALTIES

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation.

The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78 of the GDPR

SECURITY


We are committed to ensuring that your information is secure. To prevent unauthorized access or disclosure of information we have physical, electronic and managerial procedures in place to keep your information safe. Once logged into your Colletra Account, all internet communication is secured using Secure Socket Layer (SSL) technology with high security 256bit encryption, certified by Comodo.

However, this high level of protection can only be effective if you follow certain security practices yourself. You must never share your Colletra Account or login details with anyone. If you are concerned that any of your login details have been compromised, you can change them any time once you are logged on but you should always also immediately contact Customer Services and tell us why you think your login details have been compromised. Please read our Colletra Account Terms & Conditions for further information on how to keep your Colletra Account safe. Details of how to contact Customer Services are available from the “Support” section of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access. When transferring data outside the EU, we will take steps to ensure that your data is afforded substantially similar protection as data processed within the EU. Please be aware that not all countries have laws to protect data in a manner equivalent to that of the EU. Your use of our products and services will indicate to Us that you agree to the transfer of Your data outside the EU. You have the right to object to the processing of your data and to its transfer outside the EU on compelling legitimate grounds.

CHANGES TO OUR PRIVACY POLICY


We reserve the right to modify this Privacy Policy at any time in accordance with this provision. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. If you disagree with the revised Privacy Policy, you may cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of Colletra Finance Platform will be subject to the revised Privacy Policy. Contact, questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@colletra.com .

GOVERNING LAW


Your use of this Site is governed by the laws of the Republic of Cyprus. All disputes arising out of or relating to this website shall be resolved by the Courts of the Republic of Cyprus.

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