Imaginovation Fintech Solutions Group UK Limited along with its parent and affiliate companies(hereinafter “IFSG”), considers the protection of personal privacy to be extremely important. IFSG wishes to inform its customers and users as much as possible about its services, while respecting their data and giving them control over what happens to them. IFSG wants to manage and use its customer data safely, respectfully and with due diligence in order to provide better service to its customers and to offer the best possible experience. IFSG therefore starts from the principle that everyone must have control over their personal data. Below, you will find information about what data IFSG collects, why, how long for and how you can control it.
3. Processing of personal data and responsibilities
“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.
The personal data that IFSG collects and processes, primarily concerns the data that customers enter themselves via the various pages of our website(s) and that IFSG obtains through your use of our website(s) and/or our products and/or services.
This does not detract from the fact that the customer has a number of obligations in connection with the processing of personal data that allows the customer to use IFSG’s products and services. In this capacity, the customer must always obtain, where necessary, the legally required authorisations from the end users for the processing of their personal data by IFSG insofar as necessary within the framework of IFSG’s products and services.
IFSG processes personal data for various purposes, whereby the only data processed is that which is necessary to achieve the intended purpose.
Thus, we use personal data:
- When we have received permission;
- In the context of the preparation or performance of our contract;
- To comply with the legal or regulatory provisions to which we are subject; and
- When IFSG has a justified interest in this, such as, for example, as the case may be, direct marketing, fraud prevention, internal administration management or monitoring of appropriate network and information security, in which case we always strive for a balance between that interest and respecting the privacy of the person concerned.
Insofar as required, and with permission, IFSG collects personal data for the following concrete objectives:
To process an application for our products and services.
If you visit our website to collect and/or request information about our products and services, or if you sign up for IFSG’s newsletter, for example, then IFSG needs your address details. All information that IFSG receives about you during this pre-contractual phase will only be used by IFSG to provide you with the requested information, in the way that you want. In addition, if you ultimately decide to become a customer at IFSG, IFSG will ask you for a number of personal details, such as name, address, telephone number, e-mail address and customer number, and IFSG will also assign certain data to you, such as login details.
To provide the best service and to inform about usage options.
IFSG uses personal data for setting up, maintaining and supporting products and services, and for administrative purposes.
To provide information about (new) products and services from IFSG.
IFSG may use personal data to offer (in writing, by telephone or electronically) new products, services or special promotions that IFSG believes may be of interest to you. Of course, you can opt out of this type of message (see further).
To track performance.
IFSG may use personal data and consumer profiles to evaluate its products and services. This includes, among other things: requesting feedback on services (for example, via market research), data obtained during answers to customer questions, fraud detection and quality assurance.
To comply with legal obligations.
In many cases, IFSG is legally obliged to keep certain personal data and/or communicate them to government agencies, for example, in the context of general tax and accounting obligations. In the context of a police or judicial investigation, IFSG can be obligated to communicate certain data to the requisite authorities in a confidential manner.
To keep track of studies, tests and statistics, including for trend analysis.
IFSG may use anonymous, aggregated data to, for example, report internally and externally on the use of its services. The data used for this cannot be traced back to a specific individual. The information that IFSG derives from these analyses is used to evaluate the current products and services portfolio and IFSG’s processes, and to adapt them to new developments.
IFSG strives at all times to protect personal data and privacy, both in its physical offices and on the IFSG network. IFSG ensures appropriate organisational and technical measures to secure personal data.
IFSG’s employees are trained to deal with confidential data correctly. In the case of privacy-sensitive projects, an assessment is also made with regard to security and the protection of personal data.. For the security of data, IFSG employs specific people who monitor compliance with legislation and ethical aspirations. IFSG also employs specialised personnel who are responsible for the security of the network, infrastructure and information systems. In addition, IFSG uses a variety of technical measures to protect personal data, such as: password protection, hard disk encryption software, firewalls, antivirus software, intrusion and anomaly detection system and access control systems for employees.
If a data breach should occur with adverse consequences for personal data, the customer is personally notified under the conditions provided for by law.
The number of IFSG employees who have access to personal information is limited and they are carefully selected. These employees are granted access to personal information insofar as they need this information to perform their duties properly.
The existence and content of the personal communication that takes place via the IFSG network (for example: email traffic, hosting…) is protected by the provisions for telecommunications secrecy. This means that IFSG and its employees may not have any knowledge of the existence or content of such communication, outside of the exceptions enumerated by the law.
6. Provision of data to third parties
IFSG does not sell personal data to third parties nor is data passed on to third parties unless:
To our legal successors and other companies within the IFSG group.
This is necessary for our service provision.
For some aspects of our products and services, we cooperate with third parties or engage sub-contractors. These third parties are always selected very carefully and there is always an agreement between IFSG and these third parties in accordance with the applicable legislation. For more information about our sub-contractors, you can always contact us via the contact details under point 10.
If you purchase from IFSG the IFSG website(s) a product or service from a manufacturer or supplier based outside the European Union, it is possible that additional measures are necessary to ensure the security of personal data, such as a certification under the EU-US Privacy Shield and/or a processor agreement with model clauses drawn up by the European Commission.
When a person refuses to have his details passed on, it is possible that some services can no longer be offered by IFSG.
There is a legal obligation.
There is a legitimate interest for IFSG or the third party concerned.
This only happens providing the interests or fundamental rights and freedoms of the person concerned do not override that interest.
IFSG has received permission from the person concerned
If IFSG should provide personal data to third parties by other means, this will be done with an explicit communication, in which an explanation about the third party is given, together with the purposes of the transfer and processing. Where required by law, IFSG obtains express and unambiguous consent from the data subject. The data subject also always has an option to object (see below).
In regard to the international transfer of personal data, IFSG protects all personal data in accordance with the level of protection required by European regulations.
In some cases, IFSG uses anonymous, aggregated data for commercial purposes or for external reporting. This data can never be traced back to a specific individual.
7. Rights of the data subjects
You can exercise a number of rights regarding the processing of your personal data with respect to IFSG, insofar as you have those rights under the applicable legislation.
If you consider it necessary, you can also contact, or file a complaint with, the Data Protection Authority [to decide]
Right of objection
You have the right to object at any time to the processing of your personal data based on the legitimate interest of IFSG on grounds relating to your particular situation. If you object, IFSG will no longer process such personal data unless IFSG demonstrates compelling legitimate grounds for the processing that override your interests, rights and freedoms, or for the establishment, exercise or defence of legal claims.
Right of access and transparency
You have the right to access the data (free of charge) that relate to you and to obtain a copy of these personal data. You can also ask us:
- Whether we process personal data about you;
- For what purposes we process them;
- Which categories of personal data we process;
- With which categories of third parties we share your personal data;
- What the origin of the processed data is;
- What your rights are.
Right to rectification and erasure
As a data subject, you are entitled to have incomplete, incorrect, inappropriate or outdated personal data corrected or supplemented. For this purpose, our customer service can be contacted from a registered address. In order to keep your data up to date, we request that you notify us of any changes, such as if you move house.
You also have the right, without undue delay, to have your personal data deleted if and insofar as:
- the personal data are no longer required for the purposes;
- there is no longer a legal ground for the processing;
- you object to the processing, and there are no overriding legitimate grounds for the processing by IFSG;
- the personal data have been unlawfully processed; or
- the personal data must be erased for compliance with a legal obligation that applies to IFSG.
IFSG will send you a confirmation message after complying with a request for erasure. In the case of partial erasure, IFSG will also explain why the request could not be fully met.
Depending on the nature of the request, it is possible that some services can no longer be offered by IFSG. IFSG is also not always able to erase all requested data, for example, to comply with legal obligations (e.g. in order to meet accounting and tax obligations, IFSG is required to retain invoicing data for a maximum of 7 years).
Right to restriction of processing
As a data subject, you also have the right to have IFSG restrict the processing of your personal data, if and insofar as one of the following applies:
- you contest the accuracy of the personal data, in which case the processing is limited during a period enabling IFSG to verify their accuracy;
- the processing is unlawful and you oppose the erasure of the personal data and request the restriction of their use instead;
- IFSG no longer needs the personal data for the purposes of the processing, but you require them for the establishment, exercise or defence of legal claims;
- you have objected to processing, pending the verification whether the legitimate grounds of IFSG override those of the data subject.
In case of restriction of processing, the data may still be stored by IFSG.
Right to data portability
For personal data that are (i) processed in the context of the performance of the agreement, (ii) provided by yourself and (iii) processed through automated processes, you as a data subject have the right to obtain these data from IFSG in a structured, commonly used and machine-readable format, and to request IFSG to transmit those data directly to another party, providing technically possible, if you wish to switch providers.
8. Retention periods
IFSG stores and processes your personal data for as long as is necessary to achieve the objectives described in point 4.
The retention period can therefore differ for each purpose, for example to meet legal obligations (e.g. to meet our accounting and fiscal obligations, IFSG is obliged to keep records for up to 7 years) or for the legal necessity to provide certain data as evidence in case of disputes for up to a maximum of 10 years after termination of your contract. These archived data are, of course, only accessible to a limited extent.
9. Cookies & the website
All information, whether in the form of text, files or images or any other form, is made available by IFSG for information purposes only.
Any interested person may take note of this information, but IFSG reserves the right, at the time it considers appropriate, to change the rules and conditions concerning access to the use of the website without prior warning, or to subject the entire website or parts thereof to a restriction.
The provision of access to the private section of IFSG’s website through the use of usernames and passwords can be changed or refused by IFSG at any time without this leading to any compensation.
10. Contact details
IMAGINOVATION FINTECH SOLUTIONS GROUP LIMITED UK LIMITED
Attn: Data Protection Team
One Glass Wharf, Bristol, United Kingdom, BS2 0ZX.
IFSG INDIA PRIVATE LIMITED
HD-012, WeWork Embassy TechVillage, Block L,
Devarabisanahalli, Outer Ring Road, Bellandur, Bengaluru, Karnataka-560103
IMAGINOVATION FINTECH SOLUTIONS GROUP CAYMAN
Ugland House, P.O. Box 309,
Grand Cayman, KY1-1104, Cayman Islands
Deltec House, Lyford Cay,
P.O. Box N-3229, Nassau, The Bahamas
IMAGINOVATION FINTECH SOLUTIONS, INC.
#429 Lwnox Avenue, Suite 509, Miami Beach, FL 33139