Privacy Policy

Privacy Policy

1. General information

1. This Privacy Policy is constructed in compliance with the requirements of the EU General Data Protection Regulation 2016/679 (GDPR), and sets out the order of the processing and collecting of the personal data, and the security measures taken to protect such personal data by SIA Fincorum (hereinafter – Fincorum).
2. Fincorums sets compliance with human rights protection regulations and data protection laws as their priority in collecting and processing personal data of the citizens of EU or any other person, including their rights to privacy and personal life.
3. This Privacy Policy of Fincorum is applicable to all and any information, which Fincorum may receive from and/or about the users of the website www.fincorum.com, or by means of physical handing over personal data or filling in of the client questionnaire while using the services of Fincorum.

2. Definitions

1. Automated processing of personal data – processing of personal data by means of computer facilities;
2. Blocking of personal data – temporarily suspension of the processing of personal data (except for the cases where the processing is necessary for the clarification of such personal data)
3. Web-site – totality of graphic and informational materials, as well as any computer program, ensuring their accessibility in the internet network at the address www.fincorum.com ;
4. Clients – natural or legal persons, as well as the beneficiary owners thereof, who have concluded a Service Agreement with Fincorum for the use of services of the latter;
5. Depersonalization of the personal data – activities, in a result of which it becomes impossible to personalize or indetify the belonging of the personal data to the specific Client or User;
6. Processing of the personal data – any activity (operation) or the totality thereof, performed via automatic data processing means or without them, including, but not limited to, the collection of personal data, storage, systematization, clarification, updating, modification, retraction, usage, transfer, depersonalization, blocking, erasure thereof;
7. Fincorum – for the purposes of this policy is a legal person, which individually or in cooperation with other persons is conducting the processing of the personal data, and also is determining the objectives and means of the data processing, the content of such personal data, operations performed on the personal data and other relevant activities, which under the GDPR the data controller is entitled to perform;
8. Personal data – any information in electronical or physical form, directly or indirectly related to the specific Client of Fincorum or User of www.fincorum.com, containing any sensitive data regarded as such under the scope of the GDPR, and/or by means of which the said client or user can be identified; such data includes but is not limited to the list specified in Clause 3 of this Privacy Policy;
9. User – any user of the website www.fincorum.com;
10. Provision of personal data – actions aimed at disclosure of the personal data to a specific person or pool of specific persons;
11. Disclosure of personal data – any action aimed at the disclosure of the personal data to an indefinite pool of persons, including disclosure of personal data in any social network, publishing of the personal data in any information/communication network or giving access to the personal data by any other means;
12. Transborder trasmission of personal data – transmission of the personal data to the territory of a foreign country, to the foreign governmental body or foreign legal or natural person;
13. Erasure of personal data – any actions, in a result of which personal data are erased irretrievably without a possibility of recovery of the content of personal data in a data base or by any other means; or the destruction of the physical carriers of personal data.

3. We collect and process the following types of personal data from you:

• Contact details (including names, postal addresses, email addresses, telephone and fax numbers);
• Identification documents and details (including passports and IDs, social security and tax identification number);
• Verification of residential address;
• Professional information;
• Bank/Lawyer/Auditor reference letter;
• Personal financial information (including size and source of wealth, income and other financial information);
• Anti-fraud data (including information about fraud and criminal convictions, allegations of crimes and sanctions details received from various anti-fraud and sanctions databases, or regulators or law enforcement agencies);
• Website and communication usage (including details of your visits to our websites and information collected through cookies and other tracking technologies, including but not limited to, your IP address and domain name); Where necessary and legally permitted, we may also collect more sensitive data.

Where you are providing us with information about a person other than yourself, you agree to notify them of their use of personal data and to obtain such consent for us, if needed.

Moreover, the website www.fincorum.com is conducting the collection and processing of the depersonalized data of Users (including „cookies”), with the assistance of such internet services as Yandex Metrika, Google Analytics, and others. For more details on the collection of cookies please consult or Cookies Policy available on the website.

4. Purposes of collection and processing of the personal data

We collect and process your personal data for the following purposes:

• To provide you with, and to improve our services;
• To deal with your enquiries and requests, and also to send you information via email;
• To contact you in the course of providing services to our clients;
• To provide you with any other information that you request from us;
• To comply with our legal and professional responsibilities; and
• Where we have other legitimate reasons, such as for internal compliance and security purposes.
• We collect depersonalized data on the Users for the purposes of conducting the internet-statistics, which serve for the purpose of understanding the patterns of behavior of Users and their points of interest, which would allow us to improve our services and the quality of the website.
• Fincorum also retains the right to send the Client and/or Users information on the new products or services of Fincorum, special offers or events. The Client or User always has a right to object to receiving such information, sending a related query to info@fincorum.com.

5. Disclosure of personal data

The personal information you provide to our Company may be shared, consistent with applicable law and regulations, as follows:

• With affiliates and subsidiaries of our Company;
• With third parties such as contractors, advisers, agents and third-party service providers that provide services to our company, such as companies that provide record and information management services;
• With law enforcement agencies if our Company reasonably believes unlawful activities have occurred;
• As required by law or court order.

Transborder transmission of personal data:

Under the applicable data protection law, thirds countries - Countries outside the European Economic Area (EEA) often do not offer the same level of protections and guarantees for personal data as the countries within the EEA. Thus, Fincorum does not transfer your personal information outside of the EEA unless the transfer is justified on specific legal ground/s as mentioned in GDPR such as model contractual clauses, data protection agreement, your consent or other legal grounds permitted by GDPR.

In any case, before transferring your personal data to the third country, we will ensure that such third party complies with at least same level of data protection measures as Fincorum does, and that your personal data will be secured from disclosure or unauthorized use.

In the event of a trans-border transfer of personal data outside the EEA, Fincorum will follow the GDPR guidelines to ensure the level of data protection is not undermined.

6. Legal grounds for the processing of personal data

1. Fincorum processes only the personal data collected/obtained from the User/Client by means of the latter filling in the forms/ sending/ forwarding the personal data to Fincorum (or their employees) independently and knowingly. Filling in any client questionnaires / forms of Fincorum or sending any personal data to Fincorum in any other way constitutes a consent of the Client/User to this Privacy Policy.
2. Fincorum processes depersonalized data on the Users of www.fincorum.com in case it is allowed by the User in user`s browser setting (enabling or disabling „cookies” and using the JavaScript technology).

7. Collection, storage, transmission and other ways of processing of personal data

Safety of personal data which is processed by Fincorum is ensured by enforcement of legal, organizational and technical measures necessary for the proper fulfillment of the obligations set out under the applicable data protection legislation, including GDPR.

1. Fincorum is ensuring the safety and confidentiality of personal data and performs the measures which exclude any unauthorized access to such data.
2. User or Client may in any case withdraw his/her consent for the processing of the personal data by means of informing Fincorum about it at info@fincorum.com.

Under EU regulations and directives regarding prevention and suppression of anti-money laundering and terrorist financing activities, we are required to keep your personal data and the pertaining documents for 10 years as of the termination of the business relationship or one-off transaction, or where the business relationship or one-off transaction is not formally terminated, as of the completion of the last transaction made in the course of the business relationship. Safety and confidentiality of such personal data is at all times ensured by Fincorum.

In cases of any suspicion or fact of unauthorized access to Clients or Users data Fincorum will make sure to notify Client or User immediately and to take all necessary steps to eliminate the case of such access and prevent the appearance of such unauthorized access in future.

8. Final provisions

1. Client or User have the right to use any of their Data Subject rights as set out in GDPR, as well as to receive any clarification from Fincorum on our Privacy Policy and data protection by addressing us at info@fincorum.com;
2. This document shall contain all the modifications to the Privacy Policy of Fincorum. This Policy enters into force for an indefinite period, until the amendment/modification/replacement thereof, which will also be placed on www.fincorum.com. Therefore, we suggest you save or print the current version of this Privacy Policy to make sure you are aware of any further modifications thereof.