Privacy Policy

1. Introduction

FIDEA INVESTMENT STATUTORY TRUST (referred to as “FIDEA”, “we”, “us” or “our” in this notice) respects your privacy and is committed to protecting your personal data. This privacy notice explains what personal data we collect, what we do with it, who we share it with, how long we keep it for and what legal rights you have.

2. Use of our online Services

The personal data we hold about you

Your identity and contact data

This includes personal information about you (for example your name, date of birth, residential address, nationality, passport number) and your contact details. In most cases the information is provided by you during the set up and management of the FIDEA service, in the form of identity documents and any other personal data you have shared with us. In some cases, it may be provided by a third party where you have given your consent for them to share it with us. We may be provided with additional identity and contact data by third parties that we use to perform due diligence (for example, google search or fraud prevention agencies). In addition, we may source identity and contact data from publicly available sources such as company registers, or sanction lists.

Account and service data

This is information about your FIDEA products and any other products and services that you have obtained from us. It includes things like bank account numbers, account balances and information about transactions. The information is generated as you use our services and in some cases it is shared with us by the organisations we use to provide our account services.

Information you permit us to access on your phone

This is information stored on your phone that you explicitly permit us to access (for example, FaceID, TouchID).

Technical data

This is information about the phone you use (for example the browser version, time zone settings, phone operating system, IMEI number, IP address and other technical settings). This information is collected automatically when you use the FIDEA services.

Analytics

This includes information about how you interact with our services. We collect this information automatically when you visit our website or use the FIDEA services. Our use of cookies to help us achieve this is explained in our cookie policy in Section 12.

Special category data

This is information that is considered more sensitive by regulators and includes your race, ethnic origin, political views, religion, trade union membership, genetics, biometrics, health and sexual orientation. With the exception of the photo ID that you provide so we can verify your identity, we do not process this category of data. However, it is possible that we may hold special category data when it is included on documentation that you have given us (for example your ID document). When this is the case, we will only process this information in strict accordance with the law.

3. Personal Data

Use of your personal data

If the User fails to provide the personal data when processing of such data is necessary to enter into and fulfil the Agreement or required by statute, FIDEA, cannot provide the Services.

Use of cookies

The Platform uses cookies to maintain and improve the operation of the Platform. Information on the use of cookies is available in Section 12 of this Privacy and Cookies Policy.

Providing Services to the User

Upon submission of the Registration Application and registration with the Platform, personal data of the User is used to enter into the Agreement and create the Virtual Account to be used as a means to receive the Services. For all of the sub-purpose specified below, the User's data is processed by FIDEA and our Collaborating Providers that provide servers, IT, accounting, communication, bank, CRM services and/or other subjects.

Identifying the User and concluding the Agreement

In order to identify the User and conclude the Agreement, the User's data, Contact Information, Account data is used. Additionally, such data as the date of conclusion is processed as well. This data is necessary to verify the User's identity, conclude and fulfil the Agreement, communicate with the User regarding the fulfilment of the Agreement. The personal data processing is based on the conclusion and fulfilment of the Agreement and compliance with such legitimate interests of FIDEA as informing the User about the activity in the Virtual Account and protection of its rights and interests in case of a dispute as well as to comply with the statutory obligation to keep information on business activities conducted.

Creating and maintaining the Virtual Account

In order to create and maintain the Virtual Account, the User's data, Contact Information, and Account data is used.

This data is necessary to provide log in options in the Platform, to communicate with the User in case of any inquiries, to conduct surveys and to ensure a means by which the User can receive the Services. The personal data processing is based on the conclusion and fulfilment of the Agreement and compliance with such legitimate interests of FIDEA as maintenance of the Virtual Account, improvement of the Service quality, informing the User about the activity in the Virtual Account and protection of its rights and interests in case of a dispute.

Providing Services

In order to provide Services, the User's data, Contact Information and Account data is used and other if necessary.

This data is necessary to verify the User's identity, conclude and fulfil the Agreement, ensure money deposits and withdraws, send daily summaries and notices about cash deposits, to provide any related services arising from Agreement and/or any promotional campaigns, not only but also for cost estimation and analyses of marketing campaigns, as well as prevent fraud and abuse of services. The personal data processing is based on the conclusion and fulfilment of the Agreement and compliance with such legitimate interests of FIDEA informing the User about the activity in the Virtual Account and protection of its rights and interests in case of a dispute.

FIDEA provides the User with the opportunity to opt-out from receiving certain notices in connection with the Services, such as notices about deposits. The User can choose which notices to receive in the Virtual Account.

Sending registration reminders

In order to provide Services and conclude the Agreement, FIDEA can send registration reminders to Users, who have not completed the registration process via e-mail.

Enforcement of statutory obligations

In order to fulfil the statutory obligations in the fields of accountancy and anti-money laundering and terrorist financing prevention, FIDEA processes the User's data, Due diligence data, Communication Data, Contact Information and information specified by the User in the User's questionnaire in accordance with the provisions of the laws and regulations of the jurisdiction of the applicable provider and the internal control system of FIDEA.

For the purpose specified above, the User's data is processed by FIDEA and our Collaborating Providers that provide server, IT, User verification and accounting services.

Due diligence

As per the applicable laws and regulations FIDEA performs the due diligence of the User, which includes, but is not limited to, to identifying the User and verification of the User's identity document and processing the Due diligence data.

Identification of the User and verification of the Users identification document is carried out via a verification procedure, which processes the Users data and the Due diligence data. During this process, the User submits a photo of the User's identification document to the verification portal using the specially designed system of the verification portal.

This data processing is based on the necessity to conclude and perform the Agreement and to comply with the legal obligations of FIDEA in the field of anti-money laundering and terrorist financing prevention.

Sending of informational materials

Upon applying for receipt of informational materials the User agrees that User's data, Contact Information, and certain Account data (funds invested and incoming payments) is used to prepare an appropriate commercial communication for the User based on the User's data available to Iban, using profiling, and to segment the User into a certain category.

Informational materials include any and all communication from FIDEA that is not connected to providing Services, the fulfilment of the Agreement or other essential information (such as a notice that the term of the provided personal identity number will expire).

FIDEA uses profiling, i.e., automatic means for processing personal data, which allows FIDEA to assess the Users interests, to determine which Services are most suitable for the User, to analyse the User's activity and to segment the User into a certain category.

For the purpose specified above, the User's data is processed by FIDEA and our Collaborating Providers that provide server, IT, email and message delivery platform services. FIDEA processes User's personal data until the User withdraws the consent to receive informational materials or, in some cases, when the necessity to keep evidence that consent has been received is no longer in force. Withdrawing consent for receiving informational materials does not affect the consent given to process information obtained through cookies.