The Privacy Policy ("the Policy") of Fineyra Global, UAB ("We," "Our," "Us," or "Fineyra"), registration number: 306725873, informs and explains how We process any information that directly, indirectly, or in connection with other information—including a personal identification number—allows for your identification or identifiability ("Personal Data") that We receive from you when you use Our service ("Service"). We use your Personal Data for operating and improving Our Website ("Website") and Service, and for transferring it to Third Parties when We outsource services for various purposes ("Third Party Services"). By using the Website and Service, you agree to the processing of your Personal Data in accordance with the Policy.
This Policy outlines the basic rules and principles by which We process your Personal Data and details Our responsibilities in processing your Personal Data according to transparency obligations. By using the Service, you agree to the processing of your Personal Data in accordance with the Policy. If you do not agree with the Policy, either partially or fully, you must stop using the Service. All data collected before such refusal will be processed in accordance with the Policy until We receive your explicit prohibition. We do not intend to collect Personal Data from children or individuals under the age of 13.
"Personal Data" refers to any information related to an identified or identifiable natural person; an identifiable natural person is someone who can be identified, directly or indirectly, particularly by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.
"Processing" means any operation or set of operations performed on Personal Data, whether by automated means or not. This includes, but is not limited to, 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.
"Third Party Services" refers to third-party software used by Fineyra to meet regulatory requirements for verifying and confirming the identity of the Service's customers. Fineyra utilizes Third Party Services through APIs to perform the following activities:
1. Identity verification;
2. Document verification;
3. Sanctions check;
4. Political affiliation check;
5. Financial background check;
as well as other checks not limited to those listed above, depending on the requirements imposed by regulators in the Service's geographic area or other relevant authorities.
"Website" – refers to the Fineyra website located at https://www.fineyra.com/.
- IP Address;
- Cookies;
- Personal Information: This includes details you provide to us, such as your name, surname, email address, virtual currency addresses, mobile phone number, alias, password, and any personal documents like ID cards, passports, proof of address, source of wealth or funds, your photos or videos, and any other information you choose to share.
- Device Information: When you visit our website, download the mobile version of our Service, or use our Service through any of our partners’ distribution channels (e.g., widgets), you may provide information that could identify you, such as device type (including identifiers), platform type, mobile phone number, internet service provider, operating system, geolocation data, browser type, browser language, and the pages you visit.
- Behavioral Information: We may collect data on how you interact with our Website, such as the ads you click on or other similar actions. This information might include related metadata, such as the time, date, and location of such activities.
We collect Personal Data for the following purposes and legal bases:
- To provide services;
- To perform transactions;
- To deliver information related to our services;
- To grant you access to our services;
- To maintain the Service (e.g., managing your requests, remembering your settings, hosting, and backend infrastructure);
- To send newsletters, offers, updates, and advertisements that may interest you;
- To prevent fraud, illegal activities, or any violations of our Terms of Use or Policy. This may include disabling access to the Service, erasing, or correcting personal data in certain cases;
- To improve the Service (e.g., testing features, gathering feedback, managing landing pages, heat mapping the Service, traffic optimization, and conducting data analysis and research, including profiling and the use of machine learning and other techniques on your Personal Data, sometimes involving third parties);
- To provide customer support;
- To collect statistical or technical non-personalized data about the use of Fineyra’s website and Service;
- For our legitimate interests, including fulfilling a contract, identifying contract or legal violations, and confirming such violations;
- To comply with legal obligations.
If Personal Data processing is conducted based on our legitimate interests, the User has the right to object to such processing.
Please note that Fineyra does not store your private keys, backup phrases, or passwords.
We retain Your Personal Data for as long as it is necessary to process the data, to protect our interests, or as required by applicable legal provisions.
The retention periods for different types of Personal Data are as follows:
- For accounting documents: 7 years from the end of the fiscal year, in compliance with the law.
- If specified by law: within the period set by that law.
- In other cases: 10 years after the termination of the agreement (including user agreements) between You and the Company.
We have implemented a range of technical and organizational measures to ensure compliance with applicable personal data, privacy, and data security laws in the countries where We operate or where the relevant laws apply to Us.
Fineyra is not liable for any breaches of personal data protection if such breaches result from actions taken by You or third parties.
The Service may include links to other websites that are beyond Our control and are not governed by this Policy. If You access these external sites through the provided links, including when using Third Party Services, the operators of these sites may collect information about You in accordance with their own privacy policies, which may differ from Ours.
In accordance with applicable legal regulations (primarily GDPR), the User can exercise the following rights by contacting Fineyra:
- Request access to their Personal Data;
- Request changes to their Personal Data;
- Request the removal of their Personal Data;
- Object to the processing of their Personal Data on any grounds.
Fineyra will respond to such requests within 1 month and inform the User of the actions taken to address their requests. If a request is particularly complex or voluminous, Fineyra may extend the response period by up to 2 months.
If the User's requests are clearly unjustified or excessive, particularly if repetitive, Fineyra reserves the right to refuse to fulfill those requests.
The User generally does not need to pay a fee to access information or exercise other rights. However, Fineyra may charge a reasonable fee if a request is clearly unfounded, repetitive, or excessive, or refuse to comply under these circumstances.
If Personal Data is processed based on the User's consent, they have the right to revoke that consent at any time. Revoking consent does not affect the lawfulness of processing carried out prior to the revocation.
The User must inform Fineyra of any changes to their contact details to ensure they remain up to date.
In the event of a violation of their rights, the User has the right to seek protection from the Personal Data Protection Authority or the courts.
Your blockchain transactions may be transmitted through servers or nodes and will be publicly visible because of the transparent nature of distributed ledger systems.
Exchange rates, balances, transactions, and other blockchain-related information may be accessed from or associated with third-party servers. We cannot guarantee the privacy of your internet connection.
Notwithstanding any provisions in the Policy to the contrary, Fineyra may retain or disclose Your information if we believe it is reasonably necessary to comply with legal requirements, regulations, legal processes, or governmental requests; to protect the safety of any individual; to address fraud, security, or technical issues; or to safeguard our or our Users’ rights or property.
You acknowledge that the Website is not responsible for any illegal or abusive use of Your information. Additionally, if You share Your information from the Website on social networks, other third-party sites, or platforms, Your information will be governed by the privacy policies of those third-party resources.
Fineyra may disclose Your Personal Data to law enforcement, data protection authorities, government officials, and other relevant authorities only when legally required to do so or when necessary to ensure the safety of its users and the Website.
The Policy may be updated to reflect changes in laws, personal data processing practices, or directives from supervisory authorities. In such cases, Fineyra will revise the Policy available on the website and notify You of the changes when feasible.
Any questions about this Policy, the processing of Personal Data, or data subject’s requests shall be directed to:
Fineyra Global, UAB registration number: 306725873)
Address: Vilnius, Žalgirio g. 88-101
Email: info@fineyra.com
