Effective from: 01.01.2025
Privacy Notice
Your privacy is of utmost importance to us. Our policy is to protect the confidentiality of your information and to respect the privacy of individuals.
This Privacy Notice provides information about:
For more information about how we collect, use, and store your personal data, and to exercise your rights as a data subject, you may contact us at: support@finainnovate.com
The following terms are defined as follows:
2.1 “AML” means Anti-Money Laundering.
2.2 “Digital Asset” means any digital representation of value that may be traded through Fina Innovate’s services, excluding non-fungible tokens.
2.4 “Personal Data” means any information relating to an identified or identifiable natural person, including names, identification numbers, location data, online identifiers, or one or more factors specific to the physical, economic, cultural, or social identity of a person.
You are entering into a contract with Fina Innovate. The company with which you are contracting is your Data Controller and is responsible for collecting, using, disclosing, storing, and protecting your personal data in accordance with our global privacy standards, this Privacy Notice, and any applicable national laws.
Fina Innovate takes the security of personal data extremely seriously. We have dedicated team members in cybersecurity, data protection, and cyber risk, with unmatched capabilities in security, data protection, compliance, and access control within our environments. Our environments are secure, confidential, and encrypted by default.
We obtain information about you in several ways during your use of our products and services, including through any of our websites, during the account opening process, when you subscribe to events, news, and updates, and through information provided in ongoing communications with our support team.
To open an account with us, you must first complete and submit an online form and provide the required information. By filling out this form, you will need to disclose personal data so that Fina Innovate can evaluate your application and comply with relevant laws and regulations.
The minimum required information to enter into a contract for using our products and services — and to fulfill our legal obligations regarding anti-money laundering, crime, and fraud prevention — includes Biographical Information, Contact Information, Verification Information, Politically Exposed Persons (PEP) Information, and Financial Information (definitions provided below).
Without this information, we will not be able to initiate or continue providing you with our products and services.
Information we may collect from you includes:
Information we may collect about you automatically:
We may obtain information about you from other sources.
We also receive information about you from third parties, such as your payment providers, our service providers who assist with anti-money laundering, fraud prevention, and security compliance, as well as from publicly available sources. For example:
Why We Process Your Personal Data | Legal Basis | Categories of Personal Data |
To provide our products and services, including, but not limited to, completing the customer registration process, opening an account, exchanging cryptocurrency, processing payments, and transferring funds. | Performance of a Contract | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, and other relevant data. |
To conduct or arrange creditworthiness or identity checks. | Legal obligation to comply with Know Your Customer (KYC), Know Your Business (KYB), and customer due diligence regulatory requirements. This processing is also in our legitimate interests to prevent and detect potential crime and/or fraud and to protect our business. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, and other relevant data. |
For the purposes of identity verification, compliance with court orders, tax laws, or other reporting obligations, as well as anti-money laundering measures. | Legal obligation to comply with anti-money laundering laws, financial services laws, corporate laws, privacy laws, tax laws, and other applicable legislation. Regulations and requirements imposed by supervisory authorities also apply to us. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, and other relevant data. |
To administer our products and services, provide you with information about them, analyze your current needs, troubleshoot issues, improve our products and services, and develop new ones. | To ensure the effective delivery of our products and services and to meet our customers’ needs, it is in our legitimate interests to administer our products and services, provide you with information about them, troubleshoot issues, and assess our customers’ current needs. It is also in our legitimate interests to improve our products and services, including support services, and to develop and bring new products and services to market. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, other relevant data, browser information, and log information. |
To make payments to partners (our affiliates who promote Fina Innovate and generate new business leads). | It is in our legitimate interests to use affiliates to generate new business leads and to pay those affiliates when the leads generate revenue. | Anonymized trading information. |
To promote our products and services. | Consent, where you have agreed to receive direct marketing communications. We rely on our legitimate interest in processing information about how our products, services, and blockchain technology are used to inform our marketing strategies. | Biographical and contact information, trading information, other relevant data, browser information, and log information. |
To conduct surveys. | It is in our legitimate interests to send you surveys and conduct them in order to gather information on how our products and services are performing for our customers and how they can be improved. Your participation in these surveys will be based on your consent. | Biographical and contact information, trading information, browser information, and log information. |
To conduct data analysis. Our web pages and emails may contain web beacons, pixel tags, or other similar types of data analytics tools that allow us to track the receipt of correspondence and count the number of users who have visited our web page or opened our messages. We may combine your personal data with that of other clients on a de-identified basis (i.e., with personal identifiers removed), allowing us to perform more robust statistical analysis of overall trends, which in turn helps us deliver better products and services. | If your personal data is fully anonymized, we do not require a legal basis, as the information no longer constitutes personal data. If your personal data is not in anonymized form, it is in our legitimate interests to continuously assess this data to ensure that the products and services we provide are aligned with the market and our customers’ needs. | Biographical and contact information, financial information, trading information, browser information, and log information. |
To ensure the accuracy of physical address data submitted during account creation, we may use Google address verification services. | It is in our legitimate interests to ensure the accuracy of addresses submitted by customers. For more information, please refer to the Google Privacy Notice. | Address information |
For internal business purposes and record-keeping. | We have legal obligations to retain certain records. This processing is also in our legitimate interests for internal business and research purposes, as well as for record-keeping. It is further in our legitimate interests to retain records to ensure that you are complying with your contractual obligations under the agreement (“Terms of Service”) that governs our relationship with you. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, other relevant data, browser information, and log information. |
To ensure compliance with and protection of our rights, including initiating legal proceedings, preparing our defense in litigation, conducting legal or administrative proceedings in court or before a statutory authority, and investigating or resolving issues, inquiries, and/or disputes. | It is in our legitimate interests to ensure the enforcement and protection of our rights, as well as to guarantee that issues, inquiries, and/or disputes are investigated and resolved in a timely and efficient manner. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, other relevant data, browser information, and log information. |
To comply with applicable laws, subpoenas, court orders, other legal processes, or requirements of any relevant regulatory authorities. | Legal obligation. We will disclose personal data if we receive a legally binding request for disclosure from law enforcement or other authorities, or if we have a legitimate interest in assisting law enforcement or other authorities in the course of an investigation. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, other relevant data, browser information, and log information. |
To determine our overall pricing strategy and to dynamically set prices for certain products and services. | It is in our legitimate interests to use personal data to determine our overall pricing strategy and to dynamically set prices for certain products and services. For more information about our pricing approach, please refer to our Pricing Policy. | Financial information and trading information |
To notify you about changes to our products or services and/or to laws and regulatory rules and requirements. | Legal obligation. In many cases, the law requires us to inform you of certain changes to our products, services, or applicable laws. We may need to notify you of changes to the terms or features of our products or services. We must process your personal data to send you these legal notices. You will continue to receive this information from us even if you opt out of direct marketing communications. Where such notification is not legally required, it may still be in our legitimate interests to inform you of such changes. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), and other relevant data. |
To effectively manage our business, including through tools and processes, we are committed to ensuring the security of our IT systems, preventing potential criminal activity, and safeguarding assets and access control. | It is in our legitimate interests to protect our assets and systems, to prevent and detect potential crime and/or fraud, and to ensure security. | Biographical and contact information, financial information, trading information, politically exposed person (PEP) information (if applicable), verification information, other relevant data, browser information, and log information. |
To update and verify your personal data in accordance with applicable anti-money laundering regulations. | Legal obligation. This processing is also in our legitimate interests to prevent and detect potential crimes and/or fraud and to protect our business. | Biographical and contact information, financial information, trade information, information on politically exposed persons (if applicable), verification information, other information, browser information, and log information. |
To better personalize our services and content for you and to recognize you as a customer. | When we collect personal data for these purposes via cookies, we will rely on your consent. It is also in our legitimate interests to customize our services and content for customers and to recognize customers to ensure they receive services and content that are suitable for them. | Other information, browser information, and log information. |
To contact you. | It’s in our legitimate interest to communicate with our customers or potential customers to ensure the effective delivery of our products and services and to manage our business. | Biographical and contact information, financial information, trade information, and other information. |
To receive services from third parties, including services such as administrative, legal, tax, compliance, insurance, IT, debt collection, analytics, credit history, identity verification, research, or other services. | Receiving such services from third parties is in our legitimate interests to ensure the effective delivery of our products and services and to manage and protect our business. | Biographical and contact information, financial information, trade information, information on politically exposed persons (if applicable), verification information, other information, browser information, and log information. |
For any purposes not listed above, but for which you instruct us to process your personal data. | Consent. | Biographical and contact information, financial information, trade information, information on politically exposed persons (if applicable), verification information, other information, browser information, and log information. |
To the extent that legitimate interest or the performance of a contract is not a recognized legal basis in your jurisdiction, we rely on consent (express or implied, as the case may be) where consent is required.
In the course of processing your personal data for the purposes listed above, Fina Innovate may disclose your personal data to any member of the Fina Innovate group of companies and to third parties. For example, Fina Innovate may disclose your personal data to any of our service providers and business partners for business or other legitimate purposes, such as specialized advisors who have been engaged to provide us with administrative, financial, legal, tax, insurance, IT, debt collection, analytics, research, or other services.
When Fina Innovate discloses your personal data to service providers and business partners to perform services requested by customers or to comply with our legal and regulatory obligations, such providers and partners may store your personal data in their own systems. We require them to protect the confidentiality of this personal data and to comply with all relevant privacy and data protection laws.
Fina Innovate may also disclose personal data when required by law, such as to a government authority as a result of a valid court order.
Our operations are supported by a network of computers, servers, other infrastructure, and information technology, as well as third-party service providers. We and our third-party service providers and business partners store and process your personal data in the European Union, the United States of America, and other countries around the world. The courts, law enforcement, and security services of these jurisdictions may use legal procedures to access your personal data.
We may transfer your personal data outside the EEA and the UK to other Fina Innovate group companies, service providers, and business partners. Transfers outside the EEA or the UK (as the situation requires) are made in accordance with legitimate transfer mechanisms. If personal data is transferred to a country that the European Commission considers has an equivalent standard of data protection to the EEA, then Fina Innovate may rely on an «adequacy decision» for the transfer of that personal data. If personal data is transferred between destinations not listed as having an adequacy decision, we may rely on standard contractual clauses or binding corporate rules for inter-company transfers/processing.
Your use of digital assets may be recorded on a public blockchain. Public blockchains are distributed ledgers designed to immutably record transactions across a wide network of computer systems. Many blockchains are open to forensic analysis, which can lead to the re-identification of transacting individuals and the disclosure of personal data, especially when blockchain data is combined with other data.
Since blockchains are decentralized or third-party networks that are not controlled or managed by Fina Innovate, we cannot delete, modify, or amend personal data on such networks.
When personal data is no longer needed for the purposes for which it may be lawfully processed, we will delete any data that identifies you or securely destroy the relevant records. We may be required to keep records for a significant period after you cease to be a customer for legal or regulatory reasons, such as when we need to retain information to manage a dispute or legal claim, or where claims expire after six years. Additionally, we are subject to certain anti-money laundering laws which may require us to retain the following information for five years after our business relationship with you ends:
If you have opted out of receiving marketing communications, we will retain your data on our exclusion list to ensure we know that you do not want to receive these communications.
We may keep your personal data for more than six years if we are unable to delete it for legal, regulatory, or technical reasons.
Cookies are small text files that provide information about the device used by a visitor. The information from cookies generally does not identify you directly, but it can give you a more personalized web experience. Because we respect your right to privacy, you can choose not to allow some types of cookies, although this may affect the functionality of the website.
The rights available to you regarding the personal data we process are outlined below. You may request to exercise these rights, subject to any limitations provided by applicable data protection laws.
Access You can ask us to confirm whether we are processing your personal data, and if so, what information we are processing, and to provide you with a copy of that information.
Rectification It is important to us that your personal data is up-to-date. We will take all reasonable steps to ensure that your personal data remains accurate, complete, and current. Please inform us if your personal data changes. If the personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. If we have disclosed your personal data to others, we will inform them of the rectification when possible. If you ask us, and if it is possible and lawful, we will also tell you who we have shared your personal data with.
You can inform us at any time about changes to your personal data by sending us an email at support@finainnovate.com. In accordance with applicable law, Fina Innovate will change your personal data according to your instructions. To fulfill such requests, in some cases, we may require supporting documents from you as proof, i.e., personal data that we are required to keep for regulatory or other legal purposes.
Erasure You can ask us to delete or remove your personal data under certain circumstances. Such requests may be subject to any retention limitations we must comply with under applicable laws and regulations. If we have disclosed your personal data to others, we will inform them of the erasure request when possible. If you ask us, and if it is possible and lawful, we will also tell you who we have shared your personal data with.
Restriction of Processing You can ask us to block or stop processing your personal data in certain circumstances, for example, if you contest the accuracy of that personal data or object to our processing of it. This will not prevent us from storing your personal data. If we have disclosed your personal data to others, we will inform them of the processing restriction if possible. If you ask us, and if it is possible and lawful, we will also tell you who we have shared your personal data with.
Data Portability In certain circumstances, you may have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format and to reuse it elsewhere, or to ask us to transfer it to a third party of your choice, if technically feasible.
Objection You can ask us to stop processing your personal data, and we will do so if:
Automated Decision-Making and Profiling If we have made a decision about you based solely on an automated process (e.g., via automated profiling) that affects your ability to access our products and services or has an otherwise significant effect on you, you can ask not to be subject to such a decision unless we can demonstrate to you that such a decision is necessary for entering into or performing a contract between you and us. Even if the decision is necessary for entering into or performing a contract, you can challenge the decision and request human intervention. We will be unable to offer you our products or services if we agree to such a request (i.e., we terminate our relationship with you).
Complaints You have the right to lodge a complaint with a competent data protection authority. Contact details are provided in section 16 below. We ask that you first contact support@finainnovate to give us an opportunity to resolve any concerns.
Withdraw Consent You have the right to withdraw consent for consent-based processing at any time. Please note that this will not affect the lawfulness of processing based on consent before the withdrawal of consent or on grounds where consent is not required.
Our privacy notice is regularly reviewed in light of new regulations, technologies, and any changes in our business operations. Any personal data we process will be governed by our latest privacy notice. We will update the «Last Updated» date accordingly at the beginning of this privacy notice. Please review this privacy notice from time to time. We will communicate any material changes to this privacy notice on our website.
Our products and services are not intended for individuals under 18 years of age (hereinafter referred to as «Children,» «Child»), and we do not knowingly collect personal data from Children. If we become aware that we have unintentionally processed a Child’s personal data, we will take all legally permissible measures to delete that data from our records. Fina Innovate will require the Child user to close their account and will not permit the use of our products and services. If you are a parent or guardian of a Child and you suspect or have discovered that a Child has provided us with personal data, please contact us at support@finainnovate.com.
Any questions, complaints, comments, and requests regarding this privacy notice are welcome and should be sent to support@finainnovate.com. You can also contact our Data Protection Officer at support@finainnovate.com.
