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Privacy Policy

Privacy Policy 

Last Updated On 11-Aug-2022 

Effective Date 11-Aug-2022 

 

This Privacy Policy describes the policies of Refracto SRL, Str. Maresal Al. Averescu nr. 37, sc. A, ap. 14, bl. 98, Timișoara, Timis 300766, Romania, email: dpo@refracto.io, phone: +40720119319 on the collection, use and disclosure of your information that we collect when you use our website ( https://www.refracto.io ), which will henceforth be known as the “Service”. By accessing or using the Service, you are consenting to the collection, use and disclosure of your information in accordance with this Privacy Policy. If you do not consent to the same, please do not access or use the Service. 

 

We may modify this Privacy Policy at any time without any prior notice to you and will post the revised Privacy Policy on the Service and notify you directly (e.g via email) in the event of significant changes. 

 

Information We Collect: 

We will collect and process the following personal information about you: 

 

  • Identification data – first and last name, personal code and/or date of birth, age, language and profession; 

  • Contact data – phone number, e-mail address, discord tag;

  • Financial account data – for natural persons account holder, account number, IBAN, Swift, name of the bank, Elrond wallet address;

  • Authentication data – personal ID number and type, date of issue and validity of an identification document with a photo, gender and citizenship;

  • Compliance data – to apply know your customer, anti-money laundering and prevention of terrorism financing principles we conduct background checks when you join us and monitor on our platform your transactions once you are our client. The data we check, includes but is not limited to your residency data, profession, origin of funds used in transactions, qualifications or connections to politically exposed persons, and whether or not you are subject to international financial sanctions;

  • Transactions data – financial transactions made via the portal, user’s preferences of transaction profile types and user’s automatic lending placement settings;

  • Usage data – time and number of log-ins, including log-ins via other third-party service providers and log-in token.

  • Internet data – data on website visitors’ sessions, cookies, log data and IP addresses.

 

How We Collect Your Information: 

We collect/receive information about you in the following manner: 

 

  •  When a user fills up the registration form or otherwise submits personal information

  •  Interacts with the website

  •  From public sources

 

How We Use Your Information: 

We will use the information that we collect about you for the following purposes: 

 

  • Marketing/ Promotional

  • Creating user account

  • Customer feedback collection

  • Enforce T&C

  • Support

  • Measure interest in and improve our Services

  • To apply know your customer, anti-money laundering and prevention of terrorism financing principles

 

If we want to use your information for any other purpose, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which grant consent unless we are required to do otherwise by law. 

 

How We Share Your Information: 

We will not transfer your personal information to any third party without seeking your consent, except in limited circumstances as described below: 

 

  •  Analytics

We require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose. 

 

We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Privacy Policy; or (3) to respond to claims that your use of the Service violates any third-party rights.

 

Retention Of Your Information: 

We will retain your personal information with us for 90 days to 2 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Privacy Policy. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely. 

 

Your Rights: 

Depending on the law that applies, you have the right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at dpo@refracto.io. We will respond to your request in accordance with applicable law. 

 

You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by writing to us at dpo@refracto.io

 

Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes, you may not be able to access or use the services for which your information was sought. 

 

Cookies Etc. 

A cookie is a small piece of data that is stored on your computer or mobile device and allows the website to "remember" your actions or preferences over time. We use cookies to ensure the proper function of our website and to facilitate your access to it by collecting information on your device and preferences (e.g. your device and your browser). In principle you can also use our websites without cookies. If you want to use our website fully and conveniently you should accept those cookies. 

 

There are several types of cookies:

  • Session Cookie (or “temporary cookie”)

 

A session cookie allows us to store your action during your browser session (e.g. your log-in data). Session cookies are erased when you close your browser or exit our website.

 

  • Persistent Cookie (or “tracking cookies”)

 

A persistent cookie is stored on your device in between browser sessions. These cookies help us to remember your preferences or actions every time you visit our website until the expiry date of the cookie. These cookies are also used to keep you logged on to our website. As soon as the cookie is deleted, you need to enter your login credentials again.

 

Security: 

The security of your information is important to us and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. 

 

Grievance / Data Protection Officer: 

If you have any queries or concerns about the processing of your information that is available with us, you may email our Grievance Officer at Refracto SRL, Str. Maresal Al. Averescu nr. 37, sc. A, ap. 14, bl. 98, Timișoara, email: dpo@refracto.io. We will address your concerns in accordance with the applicable law. 

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