Privacy Notice
This Privacy Notice pertains to NanoFrontier s.r.o. and its brand "," which may also operate under various trading names, including (collectively referred to as "," "we," or "our").
Our aim is to outline our commitment to protecting the privacy rights of our users. This notice sets forth the foundation on which any personal information we gather from you, or that you provide to us, will be processed. It applies to: a) The website features, portal functionalities, and services offered when you visit our websites, use our portals, or interact with our payment interfaces integrated into client websites. This includes all gateways, functionalities, services, and payment panels that you may encounter on our website or portal. b) Your use of software, including terminal systems, and mobile and desktop applications provided by . c) Communication via email, other electronic messages such as SMS, telephone, web chat, our website or portal, and other interactions between you and .
Our services are not intended for use by individuals under the age of 18. If you are under 18, you should not proceed with registration or use of services.
We urge you to read this Policy carefully as it contains vital information about what to expect when we collect personal information about you and how we will utilize your personal data.
1.Introduction
This policy aims to demonstrate the purposes for which, and the manner in which, we may collect and use your personal information. By registering as a user for any services provided by us on our website, you consent to this use by us. You may refuse to share any personal information with us, which would mean that you would not be able to use the services provided by us.
Your use of the website is governed by our Terms and Conditions. We advise all users to read our Terms and Conditions and this Privacy Policy thoroughly before signing up. Additionally, we may update our policies from time to time, so it is important that you review them periodically to stay informed of any changes.
Your personal data controller is , as specified in our Terms & Conditions. We have appointed a data protection officer responsible for managing your personal data and ensuring its safety and privacy. You can contact this officer via email at legal@muceniex.com.
We comply with relevant data protection laws, including the Czech Personal Data Protection Act and the General Data Protection Regulation (GDPR). For individuals residing in the European Economic Area (including the United Kingdom) (collectively “EEA Residents”), pursuant to Article 6 of the EU General Data Protection Regulation (GDPR) or any equivalent legislation (collectively “EEA Data Protection Law”), we process this personal information based on our Terms of Use (Agreement) with you to comply with our legal obligations, satisfy our legitimate interests as described above, and obtain your consent where required.
We prioritize security for our customers and their personal privacy. We take all measures to protect the personal data of our users from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction, adhering to the highest industry standards.
If the profile is opened by a legal entity, the Head or other representative of the client must clearly inform data subjects (Beneficial owners, Head, etc.) about the transfer of their data to us and ensure that this Privacy Policy is presented to them.
2. Definitions
"Personal Information" refers to any information relating to an identified or identifiable natural person ('data subject'); 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.
"Processing" means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as 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.
"Data Controller" means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by European Union or Member State law.
"Data Processor" means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
"Consent" of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
"Anonymization" means the irreversible process of transforming or converting personal data into data that cannot be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
"Data Subject" means an identified or identifiable natural person whose personal data is processed by the controller or processor.
"Profiling" means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
"Data Breach" means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
"Supervisory Authority" means an independent public authority which is established by a Member State pursuant to Article 51 of the GDPR.
"Pseudonymization" means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data is not attributed to an identified or identifiable natural person.
“EEA (European Economic Area)” Is the area consisting of EU member states and certain European Free Trade Association (EFTA) states that have agreed to participate in the EU's single market.
“GDPR (General Data Protection Regulation): Regulation” (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
“International Data Transfer” The transmission of personal data outside the jurisdiction where it was originally collected, often necessitating adherence to specific legal frameworks or safeguards.
“Data Security” Measures to protect personal data from unauthorized access, alteration, disclosure, or destruction.
“Encryption: The process of converting information into code to prevent unauthorized access.
“Data Subject Right” Rights granted to individuals under GDPR, including right to information, access, rectification, erasure, restriction of processing, data portability, objection, and rights in relation to automated decision making and profiling.
“AML (Anti-Money Laundering)” refers to a set of regulations, laws, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. It involves measures to detect and mitigate the risks of money laundering and terrorist financing activities.
“Account” An account refers to a user-specific digital or financial entity where transactions, such as deposits, withdrawals, or trades, related to digital assets or fiat currencies are recorded and managed.
“Transaction” involves the exchange or transfer of digital assets (such as cryptocurrencies) or fiat currencies (traditional currencies like USD or EUR) within the platform. This includes buying, selling, depositing, or withdrawing assets.
"You" or "Your" or "the Client": These terms collectively refer to the natural person who is entering into a contractual relationship with the service provider ( in this case), making payments, or whose beneficial ownership is associated with the personal data provided.
“Beneficial Owner” The beneficial owner is the natural person who ultimately owns or controls a customer or the person on whose behalf a transaction or activity is being conducted. In the context of personal data, it refers to the individual whose information is provided or managed within the service.
3. Purposes for Data Processing
3.1. Collection and Utilization of Personal Information. We gather and process your personal data for multiple purposes which are expanded below:
3.2. Provision of the Services To facilitate the provision of payment services; execute digital asset trading; verify identities; detect and prevent fraud, money laundering, terrorist financing, and other criminal activities; and to fulfill obligations under anti-money laundering (AML) regulations.
i. Compliance with Legal Requirements
In accordance with legal obligations, must verify your identity before providing any services, actively monitor your transactions, and take measures to prevent fraud, money laundering, terrorist financing, and other financial crimes. These requirements are in place to ensure compliance with AML regulations and directives provided by payment service providers.
ii. Data Collection for Compliance
To meet these legal obligations, we may collect the following data from natural persons who are clients or representatives of legal entities:
- Identity Information: Includes first and last names, personal identification numbers or other unique identifiers, date of birth, identification document numbers, copies of identification documents, nationality or the issuing country of the identification document, country of residence, user ID in the system, account number in the system, photograph, and other related details.
- Contact Information: Encompasses address, phone number, email address, and similar contact details.
- KYC (Know Your Customer) Information: Covers account numbers with other payment service providers, checks against public and private registries, fraud prevention agencies, details of your employer and job title, occupation, services used, payment and other transactions, turnover, source of funds, countries involved in fund transfers, political exposure, and other data related to client activity monitoring.
- Device Information: Pertains to the operating system of the device, browser type and version used to access the profile, IP address, location, time zone settings, and similar technical details.
- Financial Information: Includes bank account numbers, bank statements, trading details, and related financial data.
- Online Identifiers: Encompasses geolocation data, tracking details, browser fingerprints, operating system, browser name and version, personal IP addresses, and other similar identifiers.
- Usage Data: Comprises survey responses, information provided to our support team, public social media posts, authentication data, security questions, user ID, click-stream data, and other data collected through cookies and similar technologies. Refer to our Cookie Statement for further information.
- Payment Card Information: Consists of payment card numbers and CVC codes, PIN codes, expiration dates, and other relevant card details.
- Additional Information: Any other data you or your customer provide to us.
iii. Collection and Processing of UBOs and Legal Entities' Data
We may gather and process personal data regarding ultimate beneficial owners (UBOs) or legal entities. We might also request personal data about other key individuals and representatives of the legal entity.
iv. Third-Party Data Collection
We may search for and collect data about you from third-party sources. This includes publicly accessible information to verify your identity, process transactions, and prevent and detect fraud or money laundering or other financial crimes.
v. Contractual and Legal Necessity
We collect the aforementioned data as mandated by law and as necessary to enter into a contractual relationship with the Client. If you or a representative of a legal entity fail to provide the required data, we may refuse to establish a contractual relationship or provide services to the Client.
vi. Disclosure of Data
We may share your data with regulatory authorities, banking and financial partners, other payment service providers, payment card manufacturing, personalization and delivery companies, companies providing identification and sanctions/watch lists screening, transaction monitoring services, government bodies, legal counsel, bailiffs, pre-trial investigation bodies, courts, auditors, debt recovery agencies, companies managing joint debtor data files, fraud prevention agencies, money laundering, terrorist financing and other financial crimes prevention agencies, and other entities with a legitimate interest or your consent.
3.3. Service Updates and Dispute Prevention
We are committed to keeping you informed about changes to our services and preventing disputes. Below are the key points regarding notifications and data processing related to these efforts:
i. Mandatory Notifications
As required by law, we must inform you about any changes in our services and Terms & Conditions for the provision of services. These notifications are regulatory and are not to be construed as marketing materials. Consequently, you do not have the right to opt-out of receiving such mandatory communications. To facilitate this, we may process your contact data, ensuring compliance with legal obligations.
ii. Data Processing for Compliance and Contractual Performance
The processing of your contact data, as mentioned above, is conducted in strict adherence to legal requirements and is essential for the performance of our contractual obligations with you, the client. This ensures that you are adequately informed and that our services remain compliant with applicable regulations.
iii. Customer Inquiries and Communication
You are welcome to reach out to us for various purposes, including seeking information about our services, consulting with us regarding any aspect of our offerings, reporting unauthorized transactions, requesting the blocking of your payment instrument, or seeking other necessary information. You may contact us via phone or email. During such interactions, we may process your identity data, contact data, and device data. Additionally, we may record our phone conversations and store the content and history of our correspondence to maintain an accurate record of communications.
iv. Data Processing Justifications
The data collected through your communications with us is processed for specific purposes:
- Phone Communications: We process your data to pursue our legitimate interests, which include preventing disputes and ensuring the accurate provision and receipt of information.
- Email or Written Communications: Data collected via email or letters is processed to comply with legal requirements and to further our legitimate interests in preventing disputes and ensuring the proper provision and receipt of information.
v. Disclosure of Data to Third Parties
In certain circumstances, your data may be shared with external entities, including supervisory institutions, legal counsel, pre-trial investigation bodies, courts, auditors, debt recovery agencies, companies that manage joint debtor data files, and other parties who have a legitimate interest or have received your consent. Such disclosures are conducted in compliance with applicable laws to ensure that all necessary parties are informed and involved in the resolution of any issues or disputes.
3.1. Collection and Utilization of Personal Information. We gather and process your personal data for multiple purposes which are expanded below:
3.2. Provision of the Services. To facilitate the provision of payment services; execute digital asset trading; verify identities; detect and prevent fraud, money laundering, terrorist financing, and other criminal activities; and to fulfill obligations under anti-money laundering (AML) regulations.
i. Compliance with Legal Requirements. In accordance with legal obligations, must verify your identity before providing any services, actively monitor your transactions, and take measures to prevent fraud, money laundering, terrorist financing, and other financial crimes. These requirements are in place to ensure compliance with AML regulations and directives provided by payment service providers.
ii. Data Collection for Compliance. To meet these legal obligations, we may collect the following data from natural persons who are clients or representatives of legal entities:
- Identity Information: Includes first and last names, personal identification numbers or other unique identifiers, date of birth, identification document numbers, copies of identification documents, nationality or the issuing country of the identification document, country of residence, user ID in the system, account number in the system, photograph, and other related details.
- Contact Information: Encompasses address, phone number, email address, and similar contact details.
- KYC (Know Your Customer) Information: Covers account numbers with other payment service providers, checks against public and private registries, fraud prevention agencies, details of your employer and job title, occupation, services used, payment and other transactions, turnover, source of funds, countries involved in fund transfers, political exposure, and other data related to client activity monitoring.
- Device Information: Pertains to the operating system of the device, browser type and version used to access the profile, IP address, location, time zone settings, and similar technical details.
- Financial Information: Includes bank account numbers, bank statements, trading details, and related financial data.
- Online Identifiers: Encompasses geolocation data, tracking details, browser fingerprints, operating system, browser name and version, personal IP addresses, and other similar identifiers.
- Usage Data: Comprises survey responses, information provided to our support team, public social media posts, authentication data, security questions, user ID, click-stream data, and other data collected through cookies and similar technologies. Refer to our Cookie Statement for further information.
- Payment Card Information: Consists of payment card numbers and CVC codes, PIN codes, expiration dates, and other relevant card details.
- Additional Information: Any other data you or your customer provide to us.
iii. Collection and Processing of UBOs and Legal Entities' Data. We may gather and process personal data regarding ultimate beneficial owners (UBOs) or legal entities. We might also request personal data about other key individuals and representatives of the legal entity.
iv. Third-Party Data Collection. We may search for and collect data about you from third-party sources. This includes publicly accessible information to verify your identity, process transactions, and prevent and detect fraud or money laundering or other financial crimes.
v. Contractual and Legal Necessity. We collect the aforementioned data as mandated by law and as necessary to enter into a contractual relationship with the Client. If you or a representative of a legal entity fail to provide the required data, we may refuse to establish a contractual relationship or provide services to the Client.
vi. Disclosure of Data. We may share your data with regulatory authorities, banking and financial partners, other payment service providers, payment card manufacturing, personalization and delivery companies, companies providing identification and sanctions/watch lists screening, transaction monitoring services, government bodies, legal counsel, bailiffs, pre-trial investigation bodies, courts, auditors, debt recovery agencies, companies managing joint debtor data files, fraud prevention agencies, money laundering, terrorist financing and other financial crimes prevention agencies, and other entities with a legitimate interest or your consent.
3.3. Dispute Resolution Mechanism. In the event of a dispute, we are dedicated to providing a clear and structured process to address and resolve your concerns efficiently and fairly.
i. Initial Resolution Process. Before initiating a formal dispute, you are encouraged to contact us directly to address and resolve your complaint. We are committed to resolving your concerns to your satisfaction. If our resolution is unsatisfactory, you may then refer the matter to the appropriate regulatory or supervisory authorities.
ii. Data Collection and Processing for Dispute Resolution. In the event of a dispute, we may collect and process various types of personal data to facilitate the resolution process. This may include, but is not limited to, identity information such as your full name, personal identification number, date of birth, and any relevant identification document details; contact information including your address, phone number, and email address; KYC (Know Your Customer) information, which may encompass account numbers, details of your transactions, employment information, and other relevant data; and any additional information you provide during the complaint filing and resolution process. The processing of this data is conducted in compliance with legal requirements to ensure the thorough investigation and resolution of your complaint.
iii. Disclosure of Data to Third Parties. Your personal data may be disclosed to various entities in the course of dispute resolution. These entities include supervisory authorities overseeing compliance and conduct within our industry, legal counsel and attorneys for legal advice and representation, pre-trial investigation institutions involved in preliminary investigations of potential legal violations, courts for judicial proceedings related to the dispute, auditors for the purpose of audits and ensuring compliance with regulatory standards, debt recovery agencies in cases involving financial recovery actions, entities managing joint debtor data files, and other authorized parties that may have a legitimate interest or where your consent has been obtained. The collection, processing, and disclosure of your personal data are undertaken strictly in accordance with applicable legal requirements to ensure the fair and lawful handling of your dispute.
3.4. Promotional Communications. We strive to keep you informed about our services and offerings through targeted and relevant communication. Below are the details regarding how we handle marketing and promotional activities:
i. Communication via Email. We may reach out to you via email to apprise you of our current services and offerings, as well as other goods or services about which you have previously inquired. Furthermore, we may permit certain third-party providers to inform you about services we believe may be pertinent to your interests.
ii. Marketing Emails and Newsletters. Emails for marketing purposes, including newsletters, will be dispatched solely upon receiving your explicit consent. These communications are designed to provide valuable insights and updates regarding our latest offerings.
iii. Right to Object and Opt-Out. You possess the unequivocal right to object to and opt out of receiving our marketing emails at any time. We provide a straightforward mechanism for you to exercise this right and cease receiving such communications.
iv. Data Sharing with Email Marketing Service Providers. We may share your data with reputable email marketing service providers who act on our behalf to dispatch marketing emails. These providers are contractually obligated to handle your data in accordance with stringent confidentiality and security standards.
v. Personalized Advertising. To enhance the relevance of our communications, we may utilize personalized advertising techniques. This involves analyzing your preferences, behaviors, and past interactions with our services to tailor advertisements specifically to your interests. Personalized advertising aims to provide a more engaging and pertinent experience by presenting you with content and offers that align closely with your preferences.
vi. Anonymized Information for Advertising. We may furnish anonymized information to our advertising partners to promote our products and services effectively. This anonymized data facilitates the delivery of targeted advertising campaigns, ensuring they resonate with specific segments of our clientele. By leveraging anonymized information, we uphold your privacy while enhancing the efficacy of our promotional efforts.
vii. Right to Object to Data Usage for Marketing. You retain the right to object to the utilization of your data for marketing purposes at any time. We are committed to respecting your preferences and will cease using your data for such activities upon your request.
viii. Engagement of Third-Party Service Providers. In the course of our operations, we may engage third-party service providers, including data processors, to manage your personal data. These providers may deliver services such as data storage, server and communication services, software development and maintenance, marketing services, online activity analysis, website traffic analysis, statistical services, and other related services. Your personal data will be transferred to these data processors strictly to the extent necessary for the provision of their services, ensuring compliance with all applicable data protection regulations.
3.5. Cookies. To enhance your experience on our platform, we utilize cookies and similar technologies that facilitate automatic information collection. These technologies are essential for optimizing our website's functionality, analyzing user trends, and providing personalized content. Below, we outline how cookies are utilized, their benefits in improving user experience, and how you can manage your preferences regarding their use.
i. Automatic Information Collection. When you interact with our platform, we employ automatic information collection techniques to enhance your experience. This includes the use of cookies, small text files placed on your computer when you visit websites, including ours. These cookies are crucial for the functionality of our website and contribute to improving its efficiency.
ii. Purpose of Cookies. Cookies stored on your computer's hard drive enable us to assess the effectiveness of our website, analyze trends, and manage the platform effectively. They provide valuable insights into which parts of our website are most frequently visited and help us address any accessibility issues. This knowledge allows us to optimize your user experience by delivering desired features and personalized content.
iii. Types of Information Collected. The information collected through cookies includes technical details such as your IP address, login information, browser type and version, time zone settings, browser plug-in types and versions, and operating system platform. Additionally, we gather data about your visits, including full URL clickstreams, viewed or searched products or services, page response times, download errors, length of visits to specific pages, and interactions on pages (such as scrolling, clicks, and mouse-overs). This comprehensive data helps us tailor our services to better meet your specific needs and preferences.
iv. Use of Third-Party Service Providers. We collaborate with third-party service providers to gain deeper insights into how visitors navigate our website and engage with our services. These providers may place cookies on your computer and analyze aggregated data to generate reports for us. This analysis assists us in understanding visitor interests more effectively and optimizing our website to better serve those interests. The information collected by these providers may be combined with data we collect about you during your use of the platform. These providers are contractually obligated to utilize this information exclusively to support our operational goals.
v. Managing Cookies. You have the option to manage cookies through your browser settings, allowing you to accept or decline cookies on a case-by-case basis or to block them altogether. However, please note that disabling cookies may restrict your access to certain features of our website or services, such as logging into your account or completing transactions. By continuing to use our website with cookies enabled, you consent to the use of both our own and third-party cookies as described.
vi. Sharing with Third Parties. In addition to using cookies for internal purposes, we may share anonymized or aggregated data with trusted third-party service providers. This collaboration helps us enhance our services, improve user experiences, and support our marketing efforts. These third parties are bound by contractual agreements to handle data responsibly and only for the purposes outlined in our agreements with them.
vii. More Information. For detailed information about the types of cookies we use and their specific purposes, please refer to our comprehensive Cookie Statement. By employing cookies and similar technologies, we aim to enrich your browsing experience while maintaining transparency and compliance with applicable data privacy and protection laws.
3.6. Data Processing. Data processing plays a crucial role in how we manage and utilize information to enhance our services and meet regulatory obligations. This involves automated and manual procedures, including decision-making and profiling, aimed at ensuring security, compliance, and the delivery of personalized experiences. We prioritize the protection of your data through rigorous security measures, reflecting our commitment to safeguarding your privacy and rights throughout our operations.
Methods of Processing. Your data undergoes processing through both automated and manual means, including automated individual decision-making and profiling, to fulfill various processing objectives.
Automated Decision Making and Profiling. Automated decision-making and profiling may be employed to verify your identity, monitor your activities within your profile, and predict other aspects of your behavior. These processes are essential to comply with Anti-Money Laundering (AML) regulations and are necessary for establishing and managing business relationships between and its clients. implements appropriate measures to protect your rights, freedoms, and legitimate interests, including providing mechanisms for human intervention. You also have the right to express your views and contest decisions made through automated means.
Data Security. The information we collect and process about you is securely stored on our servers. We employ comprehensive technical, organizational, and other necessary measures to safeguard your data and ensure its confidentiality and integrity.
4. Sharing and Transmitting Personal Information
We may share your personal information with third parties such as service providers, legal and regulatory authorities, or transmit personal data outside the Czech Republic and the EEA.
4.1 Disclosure to third parties. There are circumstances where we may transmit your data to employees, contractors, or other third parties:
a) We may disclose your personal information to our contractors and service providers. These entities may process your personal data on our behalf, for instance, when utilizing a marketing agency. Potential third-party providers include, but are not limited to: IT service providers, database administrators, IT specialists, email service providers, and payment service processors. Our contractors and service providers are mandated to comply with our stringent standards of personal data processing and security. The information we provide to them, including your personal data, will be shared solely in connection with the execution of their designated functions.
Each third-party provider is required to adhere to robust data protection protocols and ensure the confidentiality and security of your personal information. They are only authorized to use your data to the extent necessary to perform the services they are contracted to provide. This controlled access ensures that your personal data is managed responsibly and in accordance with applicable data protection regulations. Moreover, any transfer of your personal data to third parties will be conducted under strict contractual obligations, ensuring that your rights and privacy are safeguarded to the highest standards.
b) We may disclose your personal data to an extended list of third-party providers. Nonetheless, we will always seek your explicit consent prior to any such disclosure. Sharing your personal data with third-party providers may be necessary to ensure the continuity of certain features and services offered to you. These third parties may include, but are not limited to, credit reference agencies, anti-fraud databases, screening agencies, and other business partners with whom we collaborate.
Additionally, we may share your personal information to enhance the services provided by us or to further develop our business operations. This may encompass improvements to our website or the enhancement of our products and services. To achieve these objectives, we might utilize the information you have provided through form submissions. Furthermore, your data may be employed for the purpose of developing and testing new products and services.
In all instances, the transmission of your personal data will be carried out under strict legal and regulatory frameworks, ensuring that your privacy rights are upheld. Each third-party provider will be bound by robust contractual obligations to maintain the confidentiality and security of your personal data. They will only be authorized to use your data to the extent necessary to perform the services they are contracted to provide, ensuring that your personal data is managed responsibly and in full compliance with applicable data protection laws.
This careful and considered approach guarantees that any sharing of your personal data with third-party providers is conducted transparently, securely, and with your explicit consent, thereby upholding the highest standards of data protection and privacy.
4.2 Transfer to third parties. On certain occasions, we may transfer your personal data to third parties, as detailed below:
i. Business Transactions: If we are considering the sale of our business or a part of it, your information may be shared with the potential purchaser under strict confidentiality and non-disclosure agreements. Similarly, if our company is restructured or sold, your information will be transferred to the new owner to ensure the continued provision of services to you.
ii. Legal and Regulatory Compliance: We may be required by law, regulatory codes, or public authorities such as the police to disclose your information. This includes complying with local and national laws, and responding to requests from regulatory bodies.
iii. Legal Defense: In the event of a legal claim against us, your information may be transferred as necessary to defend such a claim.
iv. We may utilize your personal data to engage in direct communication and disseminate marketing messages. This involves the use of personal information to customize our offerings, ensuring that the information, updates, advertisements, and promotional materials shared with you are pertinent and engaging. Should you prefer not to receive such communications, you have the right to opt out at any time by following the instructions provided in the communication or by contacting us directly. This opt-out will not affect your ability to use our core services, but will ensure that you no longer receive marketing-related correspondence.
v. Credit and Fraud Risk Assessment: To effectively manage and mitigate credit and default risks, we may evaluate your financial status by obtaining and exchanging your personal data with credit assessment agencies. Furthermore, your information may be shared with fraud prevention agencies to identify and address potential anti-money laundering (AML) concerns. These credit checks and fraud prevention measures will be conducted in accordance with the provisions set forth in our Terms & Conditions. This process ensures that we maintain the integrity and security of our financial services while adhering to legal and regulatory requirements.
vii. Information Security: To prevent or mitigate information security risks, we may share your data with third parties involved in protecting information security.
viii. Enforcement of Rights and Agreements: We may disclose your information to manage and enforce our rights, the Terms of Use, or any other contracts with you (and/or your business). This includes managing disputes over transactions, rewards, or points, investigating and resolving complaints, recovering debt, or addressing insolvency issues.
4.3 Anonymous and Aggregated Data Sharing. Your Personal Data may be disclosed in a manner where it has been anonymized and aggregated. In such instances, the data will no longer be identifiable to any individual and will not be considered Personal Data under data protection laws. This anonymized and aggregated data may be used for statistical analysis, research, market analysis, and other purposes that contribute to the enhancement of our services and the development of new products. By anonymizing and aggregating your data, we ensure that any specific personal identifiers are removed, and the information is combined with data from other users to create datasets that do not reveal the identity of any individual. This approach allows us to utilize the insights gained from the data while maintaining the confidentiality and privacy of our users' personal information.
4.4 Third-Party Consent and Legal Compliance. Your personal information will not be sold, exchanged, or disclosed to any third parties without your explicit consent, except in circumstances necessary to deliver Services or where mandated by applicable law. We are committed to ensuring that your data remains confidential and secure, and we will only share it with third parties who are essential for the provision of our services. These parties are contractually bound to protect your data and use it solely for the purposes for which it was shared. Additionally, any data sharing required by law will be conducted in strict compliance with legal obligations and regulatory requirements, ensuring that your privacy rights are safeguarded at all times.
4.5 Third-Party Provider Obligations. The third-party service providers engaged by are contractually obligated to safeguard and utilize your personal information solely for the specific purposes for which it was disclosed. This contractual obligation ensures that your data is handled with the highest standards of security and confidentiality. Except as otherwise required or permitted by applicable law, these service providers are prohibited from using your information for any other purposes. We rigorously enforce these contractual terms to ensure compliance with data protection laws, including the Data Protection Law (DPL). This means that any third-party provider must adhere to strict data protection standards and practices, providing a robust framework for the secure processing of your personal information. By doing so, we ensure that all third-party interactions involving your data uphold the same level of integrity and security as if handled directly by .
4.6 Specific Third-Party Data Transfers. Your personal information may be disclosed to the following third-party entities under particular circumstances:
5. Data Sharing with Regulatory Bodies
5.1 Compliance with Legal Obligations and Law Enforcement Requests.We may be obligated to cooperate with regulatory bodies and law enforcement agencies within the European Economic Area (EEA) or globally. This cooperation may involve the disclosure of your personal information in response to lawful requests from these entities. We may also determine that sharing your information is necessary or appropriate for reasons including, but not limited to, mitigating fraud risk, supporting litigation or legal processes, or addressing matters of national security. Such disclosures may involve sharing your personal data with: a) Regulatory Authorities and Law Enforcement Agencies: We may be legally required to provide information about you to regulatory authorities and law enforcement bodies, whether within the EEA or internationally. These requests can stem from various legal obligations, including compliance with statutory requirements and investigations into criminal activities. b) Governmental and Public Authorities: We may need to disclose your personal data to governmental or public authorities for purposes such as complying with legal obligations, responding to requests that serve national security interests, or fulfilling duties deemed in the public interest. c) Commercial Organizations: In certain situations, we may share your information with commercial entities with which you have had interactions. These organizations may request your data to mitigate fraud risk, ensure compliance with contractual obligations, or for other legitimate purposes.
i. Litigation and Legal Processes: Your personal data may be disclosed in connection with legal proceedings, including litigation, arbitration, or other legal processes. This could be necessary to protect our rights, comply with court orders, or respond to subpoenas.
ii. National Security and Public Interest: In situations where it is deemed necessary for national or public interest, we may disclose your information to relevant authorities. This includes scenarios where disclosure is considered lawful and essential for maintaining public safety and order.
By cooperating with these entities, we ensure compliance with our legal obligations and contribute to the enforcement of laws and regulations designed to protect individuals and society as a whole.
6. International Data Storage and Processing
We store and process your personal data in data centers located worldwide, wherever facilities or our service providers are situated. Consequently, your personal data may be transferred beyond the borders of the Czech Republic and the European Union. Certain countries to which your personal data may be transmitted for these purposes are outside the Czech Republic or the EU and do not benefit from an adequacy decision issued by the Czech Data Protection Authority or by the EU Commission concerning the protection of personal data in that country.
These international data transfers are conducted in compliance with our legal and regulatory obligations. We implement appropriate safeguards under the General Data Protection Regulation (GDPR), such as standard data protection clauses with data recipients or processors approved by competent authorities. These measures ensure that your personal data receives a level of protection equivalent to that provided within the Czech Republic or the EU. For further details on these safeguards, or to request a copy of the data protection clauses, you may contact us using the information provided in the "Contact Us" section of this policy.
Additionally, we continually monitor and evaluate the data protection practices of our international service providers to ensure ongoing compliance with applicable data protection laws and standards. Our commitment to data security and privacy remains steadfast, regardless of where your data is processed or stored.
7. Your Rights
Under applicable Data Protection regulations, you have several rights regarding your personal data. These rights are as follows:
i. Right to Information: You have the right to request information about the personal data we process about you and the reasons for such processing.
ii. Right of Access: You are entitled to access your personal data held by us.
iii. Right to Rectification: You have the right to correct any inaccurate personal data and complete any incomplete personal data. We may need to verify the accuracy of the new data you provide.
iv. Right to Erasure (Right to be Forgotten): You can request the deletion of your personal data if there is no compelling reason for us to continue processing it. We may not always be able to comply with your request for specific legal reasons, which will be communicated to you at the time of your request. Under GDPR Article 17(3)(b), legal requirements take precedence over the right to be forgotten. For AML compliance, customer due diligence and transaction records must be retained for a minimum period after the end of the customer relationship. Consequently, the right to be forgotten is enforceable only after this period. We will then take reasonable steps to securely destroy or permanently de-identify such information.
v. Right to Restriction of Processing (Right to Withdraw Consent): You can request that we restrict the processing of your personal data where there is a legitimate reason. If processing is restricted, we will only store your personal data or process it with your consent, for legal claims, to protect the rights of another person, or for important public interest reasons.
vi. Right to Data Portability: You have the right to receive the personal data you provided to us in a structured, commonly used, and machine-readable format and transmit that data to another data controller. This right applies only to data you provided to us.
vii. Right to Object: You can object to the processing of your personal data at any time if the processing is based on our legitimate interests. We will cease processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims. If your personal data is processed for marketing purposes, you can object to such processing at any time.
viii. Right to Object to Automated Processing: You have the right to object to decisions based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. You can request a manual review of such decisions if you believe automated processing may not consider your unique situation.
ix. Right to Withdraw Consent: You can withdraw your consent to process your personal data at any time. This withdrawal will not affect the lawfulness of processing carried out before the withdrawal. However, withdrawing consent may limit our ability to provide certain se rvices to you.
x. Right to Complain: If you have concerns about privacy or data processing issues, you have the right to lodge a complaint with the supervisory authority. You can do so in the EU member state where you live or work or where the alleged breach occurred. The Czech Data Protection Authority (Úřad pro ochranu osobních údajů) is the competent authority for data protection issues in the Czech Republic. We would appreciate the opportunity to address your concerns before you approach the supervisory authority, so please contact us first. You can reach our Legal Officer via email at legal@muceniex.com.
By exercising these rights, you help us ensure transparency and trust in how we handle your personal data.
8. Data Security and Protection
8.1 Commitment to Data Security. We prioritize the protection of your personal information with the utmost seriousness. To this end, we implement the highest industry standards and practices to safeguard your data. We are dedicated to ensuring that all data handling processes adhere to stringent security protocols designed to prevent any unauthorized access, misuse, loss, or alteration of your personal information.
8.2 Comprehensive Security Measure. To maintain the confidentiality and integrity of your Personal Data, we employ a wide array of security measures designed to protect against loss, theft, unauthorized access, and other potential threats. These measures include, but are not limited to: a) Password-Protected Directories and Databases: Access to sensitive information is restricted to authorized personnel through the use of robust password protection protocols. b) Secure Sockets Layer (SSL) Technology: We utilize SSL encryption technology to ensure that all data transmitted over the Internet is secure and protected from interception. c) PCI Compliance Scanning: Our servers are regularly scanned for vulnerabilities to protect against potential hacking attempts and other security threats.
8.3 Encryption and Confidentiality. All sensitive financial information and credit data are transmitted securely using SSL technology and encrypted within our database. Access to your Personal Data is strictly limited to authorized personnel who are obligated to maintain the highest levels of confidentiality. Our security measures are continually reviewed and updated to align with the latest legal and technological advancements.
8.4 Avoiding Phishing Scams. We will never request sensitive financial information, such as credit card numbers, passcodes, account numbers, or PINs, through email, text, or any other unsolicited communication. Always verify that any website requesting such information in connection with our services is legitimately operated by . If you encounter a suspicious request, do not provide any information and report it to our customer service team immediately as outlined in this Privacy Policy.
8.5 User Responsibility. You are responsible for maintaining the confidentiality and security of your account passcodes, membership numbers, and PINs. Do not share these credentials with anyone. In the event of unauthorized use or any security breach involving your information, notify us immediately using the contact details provided below.
8.6. Internet Transmission Risks. While we strive to protect your personal information, it is important to note that data transmission over the Internet is not entirely secure. Although we take robust measures to protect your data, we cannot guarantee complete security during transmission unless you are communicating through a secure channel that we have provided. Upon receipt of your information, we enforce strict security procedures to prevent unauthorized access. By using our website and services, you acknowledge and accept that any personal data provided to us or third parties is at your own risk. We are committed to safeguarding your personal information and continuously enhancing our security measures to ensure your data is protected at all times.
9.1 Global Scope and Local Compliance. This Privacy Policy is intended to be comprehensive and globally applicable, but it does not supersede any legal rights or prohibitions specific to any jurisdiction where such rights or prohibitions are paramount. In cases where local laws take precedence, the rights and obligations outlined in this notice will be adjusted in accordance with the relevant local legal requirements.
9.2 Policy Amendments. We reserve the right to modify the provisions of this Privacy Policy as necessary. Should any changes be made, we will provide prior notice and publish the updated version of the Privacy Policy on our Website. We encourage you to review the Privacy Policy periodically to stay informed of any updates. The latest amendment to this Privacy Policy was made on June 13th, 2024. By continuing to use our services after the updated Privacy Policy takes effect, you acknowledge and agree to the revised terms.