EEA Privacy Policy 🇪🇺

This Privacy Policy contains an overview of the collection, use, and disclosure of your personal data. In case the information covers only one of our services we will explicitly point this out to you. Please read this Privacy Policy carefully as it applies when you use our Services or visit our Website or use our App. We take privacy and protection of data seriously and are committed to handling the personal information of those we engage with, whether customers, suppliers or colleagues, responsibly and in a way that meets the legal requirements of the countries in which we operate.

This policy also applies to any mobile applications that we develop for use with our services and Team specific pages on the Site, and references to this "Site", "we" or "us" is intended to also include these mobile applications. Please read below to learn more about our information practices. By using this Site, you agree to these practices.

1. Who we are

UAB Wind Technologies ("Fin", "us", "we", "our") is responsible for the collection, use and disclosure of your personal information. If you have any questions about how we protect or use your data, please email us at compliance@fin.com.

2. Data we collect about you

We will collect the following data about you:

2.1 Information you give us.

(a) You may give us information, including personal information, about yourself when you sign up to use our Services, e.g. your name and email address. This also includes information you provide through your continued use of our Services, participate in discussion boards or other social media functions on our Website or App, enter a competition, promotion or survey, and when you report a problem with our Services. The information you give us may include your name, address, e-mail address, phone number, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, social security number, personal description and photograph.

(b) We may also need additional commercial and/or identification information from your e.g., if you send or receive certain high-value or high-volume transactions or as needed to comply with our anti-money laundering obligations under applicable law.

(c) In providing the personal data of any individual (other than yourself) that for example may receive payments from us as part of your use of our Services, you promise that you have obtained consent from such individual to disclose his/her personal data to us, as well his/her consent to our collection, use and disclosure of such personal data, for the purposes set out in this Privacy Policy;

2.2 Information we collect about you.

With regard to your use of our Services, we may automatically collect the following information, some of which may be or include personal information:

(a) details of the transactions you carry out when using our Services, including geographic location from which the transaction originates;

(b) technical information, including the internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(c) information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Website or App (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our Customer Support number.

2.3 Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. For example:

(a) the banks you use to transfer money to us will provide us with your basic personal information, such as your name and address, as well as your financial information such as your bank account details;

(b) business partners may provide us with your name and address, as well as financial information, such as card payment information;

(c) advertising networks, analytics providers and search information providers may provide us with pseudonymised information about you, such as confirming how you found our website;

(d) credit reference agencies do not provide us with any personal information about yourself but may be used to corroborate the information you have provided to us.

2.4 Information from social media networks.

If you log in to our Services using your social media account (for example, Facebook or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this Privacy Policy.

2.5 Children's information

Our products and services are directed at adults 18 years and over and not intended for children. We do not knowingly collect information from this age group. Part of the verification process prevents Fin from collecting such data. If any information is collected from a child without verification of parental consent, it will be deleted.

2.6 Your preferences

If you do not wish to share certain data with us or do not want us to use / share it for certain purposes (to the extent possible, in accordance with applicable laws and information in this notice), you can alter your preferences at any time. Where applicable, please check with your device provider's instructions for further information about how to do this.

3. How do we protect your information

3.1 Fin makes every effort to ensure that your Personal Data is secure on its system. Fin has staff dedicated to maintaining our data protection and security policies, periodically reviewing them, and making sure that Fin employees are aware of our data protection and security practices.

3.2 We use a secure server to store your personal information. All information you provide to us is stored on our secure servers. Any payment transaction information will be encrypted.

3.3 Although we will do our best to protect your personal information, we cannot guarantee the security of your information during transmission, and 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.

3.4 Fin has established policies and procedures for securely managing information and protecting Personal Data against unauthorized access. We continually assess our data privacy, information management and security practices. We do this in the following ways:

• Establishing policies and procedures for securely managing information;
• Limiting employee access to viewing only necessary information in order to perform his or her duties;
• Protecting against unauthorized access to Personal Data by using data encryption, authentication and virus detection technology, as required;
• Requiring service providers with whom we do business to comply with relevant data privacy legal and regulatory requirements;
• Monitoring our websites through recognized online privacy and security organizations;
• Engaging in regular third-party audits of our policies and practices; and
• Conducting background checks on employees and providing training to our employees.

3.5 If you have any further questions about our security and processing activities, please contact the Fin team or refer to our Terms of Use. To the extent permitted by applicable law, Fin expressly disclaims any liability that may arise should any other third parties obtain the Personal Data you submit through fraud or otherwise where it is no fault of Fin.

4. Uses made of the information

4.1 We use your information in the following ways:

(a) where you have given us your consent to process your data;

(b) to carry out our obligations relating to your contract with us and to provide you with the information, products and services;

(c) to comply with any applicable legal and/or regulatory requirements including laws outside of your country of residence or to comply with any legal process;

(d) to notify you about changes to our Services;

(e) to customize our Services and the information we provide to you, and to address your needs - such as your country of address and transaction history. For example, if you frequently send funds from one particular currency or token to another, we may use this information to inform you of new product updates or features that may be useful for you;

(f) as part of our efforts to keep our Services safe and secure;

(g) to administer our Services and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

(h) to improve our Services and to ensure that they are presented in the most effective manner;

(i) to measure or understand the effectiveness of advertising we serve and to deliver relevant advertising to you;

(j) to allow you to participate in interactive features of our Services, when you choose to do so;

(k) to allow us to pursue available remedies or limit the damages that we may sustain and to enforce our terms and conditions

(l) so that we can provide you with information regarding our public policy advocacy efforts.

(m) to provide you with information about other similar goods and services we offer;

(n) to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you; or

(o) to combine information we receive from other sources with the information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

5. Disclosure of your information

5.1 We may share your information with selected third parties including:

(a) 3rd party api providers that we use to provide our services to you

(d) our group entities or subsidiaries - which can be found by clicking here

5.2 We may disclose your personal information to third parties:

(a) 3rd party api providers that we use to provide our services to you

(b) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;

(c) if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Customer Agreement and other applicable agreements; or to protect the rights, property, or safety of Fin, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction;

(d) to assist us in conducting or co-operating in investigations of fraud or other illegal activity where we believe it is reasonable and appropriate to do so;

(e) to prevent and detect fraud or crime;

(f) in response to a subpoena, warrant, court order, or as otherwise required by law;

(g) to assess financial and insurance risks, and to protect our operations and those of any of our affiliates;

(h) to allow us to pursue available remedies or limit the damages that we may sustain

(i) to recover debt or in relation to your insolvency; and

(j) to develop customer relationships, services and systems;

(k) if you consent, to share your details when using our Services.

5.3 We do not have a published list of all of the third parties with whom we share your data with, as this would be heavily dependent on your specific use of our Services. However, if you would like further information about who we have shared your data with, or to be provided with a list specific to you, you can request this by writing to compliance@fin.com.

5.4 We do not share customer mobile number data with third parties/affiliates for marketing/promotional purposes. Additionally, sensitive information is stored through end-to-end encryption

6. Sharing and storing your personal data

6.1 We will take all steps reasonably necessary to ensure your Personal Data is processed fairly and lawfully, in accordance with the DP Law, other applicable laws and this Policy. By submitting your Personal Data (including Log, Device and / or Demographic Information), we expect you to understand that such transfer, storing or processing in order for Fin to perform its general administrative functions is necessary and will be done in a proportionate, lawful manner, including but not limited to responding to enquiries you raise via the App or Website Services, oversight of the business entities registered in DIFC's jurisdiction or other jurisdiction and maintaining contacts for future informational or promotional activities. Unless otherwise notified, Fin does not ordinarily rely solely on automated decision making when processing your Personal Data.

6.2 In order to conduct our operations or fulfill regulatory obligations, we must transfer the Personal Data described in this Policy to and from, and process and store it in, the United Arab Emirates and (where applicable or required) with processors in other countries, some of which may have less protective privacy laws than those where you reside. In all such cases, and generally for any processing operations, we take appropriate security measures to protect your Personal Data in accordance with this Policy.

6.3 To preserve the integrity of our databases, to carry out on-going Website Services or provide the App on behalf of all Users, for research, analytics, and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Data submitted by Users for a reasonable length of time unless otherwise prescribed by applicable law.

6.4 Fin is not responsible for the accuracy of the information you provide and will modify or update your Personal Data in our databases when you provide updated information or ad hoc upon your request, as further outlined below. We will erase or put beyond active use your Personal Data upon request, unless we are required to retain it in accordance with DIFC or other applicable laws or to perform agreed services, in which case we align with applicable principles such as purpose specification and data minimization.

6.5 If it is not disproportionate or prejudicial, and required beyond this policy's notices, we will contact you to let you know we are processing your personal information.

6.6 By accessing or using the App or Website Services to which this Policy applies, we can reasonably expect that you understand that all information submitted by you through the App or Website Services or otherwise to Fin may be used by Fin to support these processing operations, in accordance with applicable laws and its policies.

7. Cookies

7.1 We use small files (known as cookies) to distinguish you from other users, see how you use our site and products while providing you with the best experience. It also enables us the ability to improve our services, for detailed information on cookies and other technologies we use and the purposes for which we use them see our Cookie Policy.

8. Retention of your information

8.1 As a regulated financial institution, Fin is required by law to store some of your personal and transactional data beyond the closure of your account with us, see your rights below. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary.

8.2 We will always delete data that is no longer required by a relevant law or jurisdiction in which we operate.

8.3 Retention periods defined for the storage of your data can be found by clicking here.

9. Third-party links

9.1 Our Services may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.

10. Changes to our privacy policy

To keep up with best practices, new legislation, and changes in how we collect and use personal information, we may modify this Privacy Policy from time to time. If we make significant changes in the way we treat your Personal Data, or to the Policy, we will endeavor to provide you notice through the App or Website Services or by some other means, such as email. Your continued use of the App or Website Services after such notice constitutes your understanding of the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices

11. Data Subject To Law

11.1 UAB Wind Technologies is located and operates its website in Vilnius, Žalgirio g. 88-101, LT-09303. Depending on where you live, the information that you provide and that this Site collects may be stored on servers that are outside of your state, province, country or other governmental jurisdiction, and the privacy laws that apply may not be as protective as those in your home jurisdiction. If you are located outside Europe and choose to provide information to us, transfer personal information to other countries and process it there. By using this website, you consent to this transfer and processing of data.

12. Your Rights and Choices

12.1 Marketing and Preferences

Fin supports Users' legal rights to opt-in or subsequently opt-out of receiving communications from us and our partners. You have the option to ask us not to process your Personal Data for marketing purposes and to remove it from our database, to not receive future communications or to no longer receive our App or Website Services. You may change your preferences at any time. Please note that we may continue to send you transactional or service-related emails despite your desire to not receive promotional or marketing e-mail messages. Additionally, please note that if you elect to opt-out of or unsubscribe from receiving promotional or other similar emails or messaging from one of our Website Services or the App, you may continue to receive promotional emails from our other websites, providers, or other, non-affiliated marketers whose services you may have accessed via Fin Website Services or App. Finally, while we may remove your individual contact information from our professional contacts database, please be aware that if such information is in a different, third party's marketing directory through your request or election, you will need to request removal with such third party directly.

12.2 Access to and Correction of Your Personal Information

You have the right to access information held about you. Your right of access can be exercised for any reason, at any time, in accordance with DIFC and other applicable laws. You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. You may also request that we restrict the processing of, erase, transfer the information you gave us from one organization to another, or otherwise process your Personal Data in line with the relevant articles providing for such rights set out in the DP Law or other applicable laws. Any access request generally comes at no cost to you, and we must respond within one month unless a reasonable need to extend the response period for two months is provided. We may, where permissible, impose a reasonable fee to meet any extraordinary administrative costs in providing you with details of the information we hold about you. When you contact us about a potential Personal Data error or query, we will endeavor to confirm or verify the information in question, then correct verified inaccuracies and respond to the original inquiry. We will endeavor to send a correction notice to businesses or others whom we know to have received inaccurate data, where required and / or appropriate. However, some third parties and third- party sites may continue to process inaccurate data about you until their databases and display of data are refreshed in accordance with their update schedules, or until you contact them personally to ensure the correction is made in their own files. As set out in Article 39 on the DP Law, we may not discriminate against you for exercising your rights by denying services or changing prices or quality of service, unless reasonable to do so in general, as objectively determined, and applicable to all individuals offered or receiving such benefits.

13. Contacting Us

Please contact us at compliance@fin.com and let us know if you have any questions or comments about our policies or practices.