FintechOS Privacy Statement

Effective: 02 Aug 2023

1. Objective
The objective of this Privacy statement is to explain how we collect, use, share and protect your personal data and how we enable your rights when you interact with us or access our website and the content displayed on or through it (our “Website”). Any details as regards the terms and conditions of the website (“T&Cs”) can be found by accessing the following https://fintechos.com/terms-conditions/.
This document supports the following principles:

We are committed to process personal data honestly, ethically, with integrity, and always consistent with applicable law and our values.
We are transparent about the personal data we collect, use, share and store.
Individuals who interact with us or are accessing our Website should easily understand how we collect and process their personal data and their rights with respect to this personal data.

2. Who is collecting your personal data?
Each of Fintech OS SRL and its affiliated entities of the FintechOS Group is the data controller of your personal data. This means that each of these entities determine for what purposes and through which means your personal data is processed.

3. Definitions
In this privacy statement:

“we/us” or “FintechOS”	means Fintech OS S.R.L.;
“you” or “user”	means a visitor to our Website, acting individually or on behalf of a third-party or as a representative of an existing or potential customer or a supplier;
“third-party”	means someone who is not you or us or a part of FintechOS Group;
“FintechOS Group”	means Fintech OS SRL and any company or other organization in which FintechOS Holding BV owns directly or indirectly 50% or above of the share capital.

4. The Basics
Personal data we collect about you
The categories of personal data we may collect about you may include:

business contact details, such as first and last name, phone, email address and information related to the legal entity you represent;
interests and preference details, such as registrations for webinars and events, information about your interaction and activity with our Website, solutions or adverts, content accessed, downloads of content;
communication and customer satisfaction content, including any personal information you include in the communications with us and feedback, suggestions, or commentary on the Website, as well as other tools that help us streamline our operations;
online identifiers, device and technical information, such as advertising IDs, date and time of accessing our Website, IP address, operating system type and version, unique device ID, browser type, browser language, domain, and other operating systems or platform information. This information is usually collected through the use of cookies, which are small files that websites send to a computer or wireless device to uniquely identify a browser or mobile device or to store information in a browser setting.

As a general rule we do not process sensitive personal data about racial or ethnic origin, political opinion, philosophical beliefs, religion, sexual orientation, genetic data, health, criminal records or union membership unless required by law or union agreement for data subjects in some countries. In special cases, however, where there is a legal basis, or legitimate security reasons, sensitive data can be processed as allowed under applicable law in certain jurisdictions.

How do we use your personal data
FintechOS will process your personal data based in accordance with the following purposes and legal basis:

Purpose	Legal basis
Providing you with the services and content on our Website	The performance of the contract concluded with FintechOS as described in the Website’s T&Cs
Running and participating in events, including webinars, podcasts and related activities	Your contractual obligations and FintechOS legitimate interest to run and advertise its business activities
Sending you our latest news and updates if you subscribe on the Website or the information you requested	Your consent to receive such information
Conduct customer satisfaction surveys and collecting feedback	FintechOS’s legitimate interest to grow its business
Analyzing conversations, phone calls, or other type of communication that takes place between you and our team	FintechOS’s (i) legitimate interests in understanding our customers’ needs better, optimizing our service delivery, and enhancing our customer interactions, as well as (ii) consent, where call recording is involved
Researching prospects using publicly available information obtained from service providers (for example business to business lead generation service providers or social media networks)	FintechOS’s (i) legitimate interest to grow its business, as well as (ii) consent, in case such data is obtained via advertising cookies
Improving and developing the Website’s functions and content, including related support and maintenance.	FintechOS’s legitimate interest to run its business activity
Preventing, detecting and remediating any security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and taking action, as appropriate, against those responsible	FintechOS’s legitimate interest to protect its business activity, products and solutions
Compliance with a mandatory legal obligation	Legal obligation or legitimate interest to run its business activity

When you are visiting our Website, we may store on or retrieve information from your browser, mostly by using cookies. A cookie is a small software file stored temporarily or placed on the hard drive of your device in order to allow a web server to identify your device and the web browser you use, in order to recognize you when you are visiting our Website again. Cookies may also store preferences or other information about you. The information does not usually directly identify you, but it can give you a more tailored experience. For more information about the cookies we use and how to manage your cookies settings please visit our Cookie Policy.
As part of our endeavors to train our teams, learn from the interactions with your, and continually improve our service standards, we may record and analyze phone calls or other conversations that take place between you and our teams. We understand the importance of your privacy and want to ensure we are transparent about this practice and, thus, recording calls will only take place after obtaining your explicit consent. Your consent is entirely voluntary, and you have the right to refuse or withdraw your consent at any time. Refusal or withdrawal of consent will not affect your interaction with our teams.

Who we share information about you with
We may share personal data about you with:

Our affiliated companies within the FintechOS Group;
Companies or consultants who are engaged to perform services for, to, or on behalf of a company in the FintechOS Group, including for example, security, IT and software services and technical support providers, back-office, archiving and data storage services suppliers; These entities are carefully selected and regularly reviewed by us to ensure that your personal information is protected. These entities may only use the data for the purposes specified by us and are also contractually obligated to process your personal information in accordance with this privacy statement and applicable data protection legislation.
Consultancy services providers and any other similar services providers (e.g., lawyers, auditors, accountants, on various matters);
Third parties described in our Cookies Policy, including advertising and social networks;
A third party or body where such disclosure is required to satisfy any applicable law, or other legal, contractual or regulatory requirement;
In conjunction with any merger, sale or acquisition of a company in the FintechOS Group.
Where we process information about you.

In doing the above, we may need to transfer personal information about you to other companies in the FintechOS Group or third parties located (or whose servers may be located) in countries outside of where you are engaged, including countries outside of the European Economic Area (EEA). If we send personal information about you to a country that is not in the EEA, we will make sure that there is a legal basis for such transfer and that your personal information is adequately protected as required by applicable law, for example, by using standard agreements approved by relevant authorities and by requiring the use of other appropriate technical and organizational measures to protect your personal information.
Please contact the Privacy Officer if you would like to find out more about the way we comply with our legal obligations in relation to international data transfers.

How long we keep information about you
We will store your information for as long as you it is no longer required to serve the purpose of the processing. We may also retain some of that information for long as is necessary to fulfil any legal or regulatory requirements and the purposes for which it was collected as prescribed by the law.
Where we de-identify personal information and it no longer identifies an individual (for example for analytics and statistics purposes or to improve and develop our business and solutions) we may keep the information indefinitely.

Your rights
Depending on and subject to applicable laws, you have certain rights regarding the personal data that we hold about you. These rights may include the following:

Right to correct or update information: you have the right to have the information we hold about you corrected if it is not accurate.
Right to access: you have the right to be provided with access to data held about you by us and type of processing (purpose, categories of personal data processed, recipients / third parties having access to your data), retention period, your specific rights. You may also ask a free-of-charge copy of your personal data we process.
Right to object: you have the right to object to the processing of your personal information where we rely on our legitimate ground to do so. Your objection will be balanced against our specific legitimate ground for processing.
Right to deletion: in certain circumstances you have the right to request that we erase the personal information we hold about you.
Right to restrict the use of your information: if you feel the personal information we hold about you is inaccurate or believe we shouldn’t be processing your personal information, you may have the right to ask us to restrict the processing that information.
Withdrawal of consent: you may withdraw any consent to processing and prevent further processing if there is no other ground than consent under which FintechOS can process your personal data.
Right to data portability: in certain circumstances you will have the right to take the personal information you have provided to us with you. You can raise a request for data portability by contacting our Support Team.
Right to lodge a complaint with the competent data protection supervisory authority (such as, in Europe, in the EU Member State of your usual residence) about the way we handle or process your personal data.

These rights can be exercised by contacting us at dpo@fintechos.com. If we don’t take action based on any of the above requests, we will inform you of our reasons for this.

How do we keep your personal information secure
Within FintechOS the security and confidentiality of your personal information are very important, therefore we put in place all technical and operational security measures to protect your personal information for unauthorized access or use, ensuring that we can always restore information in case of data corruption, loss or disaster recovery situation. FintechOS is ISO 27001 & SOC 2 Type 2 certified, regarding the security of information management.

Revisions to this Privacy Statement
We may update this statement from time to time, so we encourage you to check it regularly. If we make a major change, we will reissue a revised privacy statement to the extent required by law.

How to contact us
If you have any further questions about this privacy statement or how we process your information, please contact us by sending an email to dpo@fintechos.com.
FintechOS Group affiliated entities:
FINTECH OS SRL, with its headquarters in Bucharest, Oregon Park, 46D-46E-48, Pipera Road, Building C, 2nd Floor, District 2, Trade Registry no. J40/14655/2017, Sole Identification Number RO38120136,
or
FINTECHOS TECHNOLOGY UK LTD, with its headquarters at Devonshire House, 60 Goswell Road, London, England, company number 11857916,
or
FINTECHOS EU BV, with its headquarters at Nieuwezidjs Voorburgwal 104, 1012 SG, Amsterdam, registration number 859964917,
or
FINTECHOS LLC, with its registered office at: Delaware, 8 The Green, STE R, Dover, zip code 19901.