1. WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy applies to the personal
data that We collect and process acknowledging and understanding that
Your privacy is important to You and that You care about how Your
personal data is collected and processed. We at Fintora LTD
(herein after referred to as Company)
are dedicated to safeguarding and preserving Your personal data and
privacy when visiting Our Websites, utilizing Our services, products
or communicating electronically with Us. For the purposes of the data
protection laws that apply to us, including the GDPR which is the
European General Data Protection Regulation and UK Data
Protection Act 2018, We act as the Data
Controller for the personal data that We collect and process to
enable You to make use of Our Services. The purpose of this Privacy
Policy is to transparently provide You with an explanation as to the
legal basis for Us collecting and processing Your personal data, the
categories of personal data that We may collect about you, what
happens to the personal data that We may collect, where We process
Your personal data, how long We are required to retain Your personal
data, who We may share Your personal data with and to also explain
Your rights as a data subject. We do update this Privacy Policy from
time to time and will post all updates to Our Website as and when
issued. Please review this policy regularly on Our Website for any
changes.
2. DEFINITIONS AND INTERPRETATIONS
In this Privacy Policy the following terms
shall have the following meanings:
Cookie
means
a small text file placed on Your computer or device by Our Websites
when You visit certain parts of Websites.
GDPR
means
the General Data Protection Regulation (EU) 2016/679, of the European
Parliament and of the Council of 27 April 2016 on the protection of
natural persons with regard to the processing of Personal Data and on
the free movement of such data, and repealing Directive 95/46/EC, UK
Data Protection Act 2018
as amended, replaced or superseded and in force from time to time and
as transposed into member-state legislation.
Privacy
Policy
means this Privacy Policy updated from time to
time and made public on Our Website
https://digistorenow.com/.
Personal
Data
means any information which relates to an
identified or identifiable natural person. An identifiable 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.
Website
means
the website https:/digistorenow.com/,
which is owned by the Company as defined.
Services
mean
all Our Services as selling Coupons to our Users.
You, Your
You, as User or Guest, depending on your status
at the Website.
We, Us, Our
refers to Fintora LTD, Company
registered under the number 13010969 in accordance with the
legislation of England and Wales, with the Legal address: 124
City Road, London, England, EC1V 2NX .
3. YOUR
DATA PROTECTION RIGHTS
Under the GDPR you, as a data subject, have
certain rights over the personal data that We hold and process.
At
Fintora LTD, We are committed to make it easy for You to exercise
these rights in the most transparent manner possible. You can
exercise any of Your rights in relation to the data that Fintora LTD holds about you, by contacting Our data protection officer
through the email address provided at the end of this section or
through Your personal user cabinet.
The following are the
specific rights You have over Your personal data We hold and process,
namely:
a. The right to be
informed about Our collection
and processing of Your personal data including without limitation the
legal basis for the collection and processing, the categories of
data, the methods of data use, the envisaged period for which the
personal data will be retained. This Privacy Policy should tell You
everything You need to know, but You can always contact Us to find
out more or to ask any questions.
b.
The right to access Your
personal data We collect about you, commonly referred to as "Subject
Access Requests", which provides you, as the data subject, the
right to obtain a copy of Your personal data that We are processing
for You Pursuant to GDPR We are required to respond without undue
delay to all Subject Access Requests in practice this means We have
to respond within 1 month of receipt of the Subject Access Request.
Ordinarily Subject Access Requests are free of charge. We may extend
the time period for responding to a Subject Access Request by a
further two months and may charge a reasonable fee if We deem the
request to be manifestly unfounded or excessive, however, We are
required to advise You of Our intention to do this within 1 month of
Your subject access request. Should You wish to make a Subject Access
Request this can be done by contacting the Company using the email:
[email protected].
c. The
right to have Your personal data rectified if
any of Your personal data that We collect and process is in any way
inaccurate or incomplete.
d. The
right of erasure (otherwise known as “the right to be forgotten”),
i.e. the right to ask Us to delete or otherwise dispose of any of
Your personal data that We process. Please note that this is not an
absolute right and We may not be able to comply with Your request as
We may be legally obliged to continue to retain Your personal data
for a specific period
e. The
right to restrict (i.e.
prevent) the processing of Your personal data by us.
f. The right to object to
Us processing Your personal data for a particular purpose or
purposes. Please note that the right to object only applies in
certain circumstances and will depend on the purposes or legal basis
for the processing.
g. The
right to data portability. This only
applies where You have provided personal data to Us directly, the
legal basis for Us processing Your personal data is i) consent or ii)
for the performance of a contract and We are processing Your data
using automated means. In such instances You have the right to
receive Your personal data (or request that We transfer it to another
Controller) in a structured, commonly used and machine-readable
format.
h. Rights
relating to automated decision-making and profiling.
We do not use Your personal data in this way.
i. The
right to lodge a complaint with
any relevant Data Protection Authority, in particular in the member
State of Your residence, place of work or the place of processing
Your personal data.
Data
Subject Request
The right to be informed
The right of access
The right to rectification
The right to erasure
The right to restrict processing
The right to data portability
The right to object Rights in relation to
automated decision making and profiling.
j. If
You wish to exercise any of the aforementioned rights, please contact
Us. We request that in the first instance You contact Our data
protection officer at any time on [email protected].
k. We
promise to promptly consider Your request and to respond to You in
accordance with the requirements of the UK Data Protection Act and
GDPR.
l.
If
you’re unhappy with their response, you can make
a complaint to the Information Commissioner’s Office (ICO) or
get advice from the ICO at the website:
https://ico.org.uk/make-a-complaint/data-protection-complaints/
4. PERSONAL DATA WE COLLECT ABOUT YOU
4.1. PRINCIPLES OF PROCESSING
During collecting and processing the personal
data, the Company adheres the principles as follows:
j. Lawfulness,
fairness and transparency
Lawfulness – the controller identifies a
lawful basis before processing the personal data (for example
consent). Fairness – in order to process fairly, the controller has
to make certain information available to the data subjects as
practicable. This applies whether the personal data was obtained
directly from the data subjects or from other sources. Transparency –
any information and communication relating to the processing of the
personal data be easily accessible and easy to understand, and that
clear and plain language be used.
k. Purpose
limitation
The personal data must be collected for
specified, explicit and legitimate purposes and not further processed
in a manner that is incompatible with those purposes; further
processing for archiving purposes in the public interest, scientific
or historical research purposes or statistical purposes shall not be
considered to be incompatible with the initial purposes.
l. Data
minimization
The personal data must be adequate, relevant
and limited to what is necessary in relation to the purposes for
which they are processed.
m. Accuracy
The personal data must be accurate and, where
necessary, kept up to date; every reasonable step must be taken to
ensure that personal data that are inaccurate, having regard to the
purposes for which they are processed, are erased or rectified
without delay.
n. Storage
limitation
The personal data are kept in a form which
permits identification of data subjects for no longer than is
necessary for the purposes for which the personal data are processed.
Personal data may be stored for longer periods insofar as the
personal data will be processed solely for archiving purposes in the
public interest, scientific or historical research purposes or
statistical purposes, if only are implemented appropriate technical
and organizational measures required by governing law in order to
safeguard the rights and freedoms of the data subject.
o. Integrity
and confidentiality
The personal data is processed in a manner that
ensures appropriate security of the personal data, including
protection against unauthorized or unlawful processing and against
accidental loss, destruction or damage, using appropriate technical
or organizational measures.
4.2. LEGAL BASIS FOR COLLECTING AND
PROCESSING PERSONAL DATA
Fintora LTD will process Your personal data based on legal bases
such as:
a. the performance of Our contract with You (i.e.
the provision of Our Services to you);
b. our legitimate business interests
(i.e. for fraud prevention, maintaining the security of Our network
and services, seeking to improve the Services that We provide and
Your interaction with us). Whenever We rely upon this lawful basis,
We assess Our business interests to make sure that they do not
override Your rights. Furthermore, in some cases You have the right
to object to this processing;
c. with Your consent for
direct marketing purposes so that We may keep You fully up to date
with other products and services that We supply and think may be of
interest to you. Where We rely upon consent, We will need Your
explicit consent, which may be removed at any time;
d. our
legal obligation.
4.3.
CATEGORIES OF THE PERSONAL DATA WE COLLECT
A summary of the Personal Data that We process,
when We collect it, how We use it and why We use it (i.e. the legal
basis for processing) is listed below:
Personal Data
|
When We Collect
|
How We Use
|
Why We Use
|
|
|
|
|
|
|
|
|
|
Steam ID, nickname, avatar
|
In registration procedure
|
We use Your personal and contact
information to register You as a User and identify You in Our
Services.
|
Necessary for the performance of a contract
with you
|
|
|
|
|
|
|
|
|
|
Email
|
In registration procedure, in event
registration
|
Use email to restore Your account. We use
it to notify You about changes to Our Terms or Privacy Policy; to
communicate with you
|
Necessary for the performance of a contract
with you
|
|
|
|
|
|
|
|
|
|
Information about Your transactions
|
When You do the transaction
|
We use it for make transactions. All
transactions are carried out using third-party services
|
Necessary to comply with a legal obligation
|
|
|
|
|
|
|
|
|
|
Service id
|
When You use Our services
|
We use it to optimise Our service and to
improve Our Website, services, direct marketing, User
relationships, behaviour profiling and experiences
|
Necessary for Our legitimate interests
|
5.
PROTECTING YOUR PERSONAL DATA AND DATA RETENTION
We use, store and process Your personal data on
Fintora LTD servers which are located in the EU. By filling a
“consent application” You agree to these conditions of
collection, processing, transfer and storing Your personal data. When
We process Your personal data for one of the legal bases specified in
this Privacy Policy, We will take all steps reasonably necessary to
ensure that Your Personal Data is treated securely and in accordance
with this Policy. Fintora LTD protects Your Personal Data under
internationally acknowledged standards, using physical, technical,
and administrative security measures to reduce the risks of loss,
misuse, unauthorized access, disclosure, and alteration. Some of the
safeguards Fintora LTD use are firewalls and data encryption,
physical access controls to Our data centers, and information access
authorization controls. Fintora LTD also authorizes access to
Personal Data only for those employees or contractors who require it
to fulfill their job or service responsibilities. The Fintora
LTD’s staff is trained on procedures for the management of personal
information, including limitations on the release of information.
Access to personal information is limited to those members of Our
staff and contractors whose work requires such access. Fintora
LTD conducts periodic reviews to ensure that proper information
management policies and procedures are understood and followed. All
of Our physical, electronic, and procedural safeguards are designed
to comply with applicable laws and regulations.
5.1. HOW WE PROTECT YOUR DATA
When You provide Your personal data through Our
Website, KYC portals, Our applications, this information is
transmitted across the internet securely using industry standard
encryption. Your personal data is held encrypted on secure servers.
Where any third parties process Your personal data on Our behalf, We
require that they have appropriate technical and organizational
measures in place to protect this personal data and We will also
ensure that it is GDPR compliant. Data Processing Agreement is in
place between Fintora LTD and the third party so that both
parties understand their responsibilities and liabilities pursuant to
GDPR.
5.2. HOW YOU CAN PROTECT YOUR PERSONAL DATA
When You create Your account, choose a strong
password that is unique to this account. Do not share Your password
with other people. Using the same password across Your different
accounts will increase the risk of Your data being compromised if
Your password is accidentally or unlawfully accessed by unauthorized
persons. If You suspect that someone else has got access to Your
password, make sure that You change it immediately. When using Our
wallets, ensure You keep Your passphrases and keys in a secure device
isolated from devices You use regularly. Do not share the device
containing Your passphrases and keys with friends, family members or
even people You trust.
5.3. DATA RETENTION
Your personal data will be retained for as long
as necessary to satisfy the purposes We received it for, this
includes regulatory and business purposes.
In determining the necessary personal data
retention period, the following factors are considered:
a. The
amount of personal data as We aim to minimize this amount to the
extent possible for each specific purpose specified in Section 4 of
this Privacy Policy.
b. The nature of the personal data depends on
the exact purpose which this specific personal data serves as
detailed in Section 4 of this Privacy Policy.
c. The sensitivity of the personal data by its
nature and substance.
d. The potential risk of harm from
unauthorized use or disclosure of Your personal data and We continue
to run risk assessments and risk mitigation activities to minimize
this potential risk including engagement of third-party specialized
data management and data protection providers.
e. The purposes
for which We process Your personal data and whether We can achieve
those purposes through other means, and the applicable legal
requirements.
6. THIRD PARTY LINKS
You may find links to third party Websites on
Our Website or chats of users contained on Our Website or mobile
applications. These Websites should have their own privacy policies
which You should check. We do not accept any responsibility or
liability for their policies whatsoever as We have no control over
them.
7. WHO DO WE SHARE YOUR PERSONAL DATA WITH?
We do not share Your Personal Data to third
Parties, except cases that are mentioned in this Privacy Policy.
7.1 WITH YOUR CONSENT
We will share information with companies,
organizations or individuals outside of Fintora LTD when We have
Your explicit consent.
7.2 TO COMPLY WITH THE LAW
We may share information in response to a
request for information if We believe disclosure is in accordance
with, or required by, any applicable law, regulation, legal process
or governmental request, including, but not limited to, meeting
national security or law enforcement requirements. To the extent the
law allows it, We will attempt to provide You with prior notice
before disclosing Your information in response to such a request.
7.3 IN AN EMERGENCY
We may share information if We believe that it
is necessary to protect the vital interests of the data subject (i.e.
to prevent imminent serious physical harm or death to a person.)
7.4 TO ENFORCE OUR POLICIES AND RIGHTS
We may share information if We believe Your
actions are inconsistent with Our user agreements, rules, or other Fintora LTD policies, or to protect the rights, property, and safety
of ourselves and others.
7.5 WITH OUR AFFILIATES
We may share information between and among Fintora LTD and any of Our parents, affiliates, subsidiaries, and
other companies under common control and ownership.
7.6 WITH OUR PARTNERS
We may share information with vendors,
consultants, and other service providers (but not with advertisers
and ad partners) who need access to such information to carry out
processing activities for us. The partner’s use of personal data
will be subject to appropriate confidentiality and security measures.
We may share Your private personal data with such service providers
subject to obligations consistent with this Privacy Policy and any
other appropriate confidentiality and security measures, and on the
condition that the third parties use Your private personal data only
on Our behalf and pursuant to Our instructions. We may share Your
private personal data with our partners to make a transaction. Where
any third parties process Your personal data on Our behalf, We
require that they have appropriate technical and organizational
measures in place to protect this personal data and We will also
ensure that it is GDPR compliant. Data Processing Agreement is in
place between Fintora LTD and the third party so that both
parties understand their responsibilities and liabilities pursuant to
GDPR.
7.7 INTERNATIONAL TRANSFERS OF PERSONAL DATA
Data Subjects risk losing the protection of
GDPR if personal data is transferred outside of i) the EEA or ii) UK
and accordingly GDPR restricts such transfers, unless the rights of
data subjects in respect of their personal data is protected by
appropriate safeguards or one of a limited number of exceptions
applies (such exceptions include Your explicit and informed consent).
Fintora LTD will not make any international transfers of Your
personal data unless it has i) Your explicit and informed consent or
ii) it has put in place the appropriate safeguards or iii) the
international transfer is covered by an exception.
7.8 ADVERTISING, ANALYTICS AND BUSINESS
PARTNERS (LIMITED TO NON-PERSONALLY IDENTIFIABLE INFORMATION)
We may share aggregated or pseudonymous
information (including demographic information) with partners, such
as publishers, advertisers, measurement analytics, apps, or other
companies. For example, We may tell an advertiser how its ads
performed or report how many people installed an app after seeing a
promotion. We do not share information that personally identifies You
(personally identifiable information is information like name or
email address) with these partners, such as publishers, advertisers,
measurement analytics, apps, or other companies.
7.9 OTHER INFORMATION
Other information that does not personally
identify You as an individual is collected by Fintora LTD (such
as, by way of example, patterns of use) and is exclusively owned by
Fintora LTD. We can use this information in such a manner that Fintora LTD, in its sole discretion, deems appropriate. We may share
specific aggregated, non-personal information with third parties,
such as the number of users who have registered with us, the volume
and pattern of traffic to and within the site, etc. That information
will not identify you, the individual, in any way. We shall not use
Your email or other contact information for sending of commercial
proposals, other marketing needs, without Your prior consent. In the
light of the above, when You send Us messages, We can keep them for
administering Your inquiries, for improving Our services. We shall
not transfer information from such messages to third parties.
8. USE OF COOKIES
To enhance the quality of Our services, provide
You with relevant content as well as understanding how You use Our
Website and applications, We use technologies, such as Cookies.
Cookies do not typically contain any information that personally
identifies you, but personal information that We store about You may
be linked to the information stored in and obtained from Cookies. We
use Strictly Necessary Cookies - these are required for the operation
of Our Website. They include User session key, browser language. This
is a temporary key issued to the User after the successful logging
in. These cookies are used to enable You to log into secure areas of
Our Website.
9. CONTACTING US
We welcome any queries, comments or requests
You may have regarding this Privacy Policy. If You wish to make a
subject access request, please do not hesitate to contact Us
at [email protected].
10. CHANGES TO THIS PRIVACY POLICY
Any changes that We make to Our Privacy Policy
in the future will be posted on Our Website. Where appropriate, We
will notify You of the changes when You next visit Our Website.
This Privacy Policy was last updated on October
24, 2024.
