1. Introduction
This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your Personal Data when You use the Service and tells You about Your privacy rights and how the law protects You.
We use Your Personal data to provide and improve the Service. BY USING THE SERVICE, YOU PROMISE US THAT (I) YOU HAVE READ, UNDERSTAND AND AGREE TO THIS PRIVACY POLICY, AND (II) YOU ARE OVER 18 YEARS OF AGE. If you do not agree, or are unable to make this promise, you must not use the Service. In such case, you must contact us to request deletion of your data.
The words of which the initial letter is capitalized have meanings defined under the following conditions.
The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.
2. Definitions
For the purposes of this Privacy Policy:
- You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.
- Company (referred to as either "the Company", "We", "Us" or "Our" in this Agreement) refers to GTWS Tech Limited.
- 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.
- EEA includes all current member states to the European Union and the European Economic Area.
- Process, in respect of personal data, includes to collect, store, use, restrict, erasure, destruct and disclose to others.
- 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.
- Processor means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
- Affiliate means an entity that controls, is controlled by or is under common control with the Company, where "control" means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.
- Account means a unique account created for You to access our Service or parts of our Service.
- Website refers to SolidGate, accessible from http://solidgate.com
- Service refers to the Website.
- Country refers to: Republic of Cyprus.
- Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.
- Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.
- Personal Data is any information that relates to an identified or identifiable individual, such as a name, email, a telephone number, IP address, etc.
- Cookies are small files that are placed on Your computer, mobile device or any other device by a website, containing the details of Your browsing history on that website among its many uses.
- Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
3. What data do we collect
a. Personal Data provided by you through the Website
While using Our Website, We may ask You to provide Us with certain Personal Data that can be used to contact or identify You. Personal Data may include, but is not limited to:
- Name
- Telephone number
- Email
- Other data You give us when using Our Website
b. Usage Data
Usage Data may include information such as Your Device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
c. Cookies
We use Cookies to track the activity on Our Website and store certain information.
4. How do we use Your Personal Data
a. When you request us to contact you
Via our website, You can request Us to contact You regarding questions, queries, comments or complaints. You can also contact us by e-mailing us using for example the contact details listed in this Privacy Policy. When You do so, We will collect the information that You fill out, including Your name, email, telephone number and your message to Us in order to attend and manage Your requests. Therefore, We use this data for our legitimate interest of conducting business with You or to establish our future contract with You.
b. When you contact us to discuss Your business needs
You may also send us your inquiry or question in section “Pricing” of Our Website. In this case We will collect Your first name, last name, company email, company website, the information about region of registration and monthly volume of the company You are representing, and Your payment needs (if you decide to leave this information). This data will be used to provide You with a bespoke pricing model and discuss Your business needs. The information will be processed for Our legitimate interest in enabling Our relationship with You as a prospective merchant.
c. Data we process for our newsletter and marketing purposes
You can sign up for our newsletter using Your e-mail address via subscription form on Our Website. By submitting this form, You indicate your consent to receive our newsletter. We rely upon Your consent to process your Personal Data for the above purpose. You can at any time unsubscribe from receiving these e-mails by following the instructions provided in any of the newsletters or by contacting us using the contact details provided in this Privacy Policy.
If you shared Your contact details with Us at some event, We may use this information (for example, Your business card) to follow-up with You regarding Our services and Your questions. We rely upon Our legitimate interest of conducting business with You to process such Personal Data.
d. When You apply to become Our merchant
When You decide to become Our merchant, We will ask you to provide some Personal Data relating to You, Your representatives, ultimate beneficial owners, employees, and/or other individuals associated with You. We will ask You only for the information that is necessary to on-board You as Our merchant and to meet applicable legal requirements. This information may include full name, email address, date of birth, address, ID card or passport, bank account number, etc. We may also receive some Personal Data relating to You from Our Service Providers, such as identity verification services, and publicly available sources, such as public registers. We process this data to be able to perform our contract with You and to meet Our legal obligations, such as taxation, Anti-Money Laundering (AML) and Know Your Customer (KYC) obligations, etc.
As your service provider, We may also process some Personal Data of Your customers (i.e., cardholders), such as transaction data necessary to process payments. Please note, that as a Personal Data controller, You (merchant) shall bear primary responsibility for the processing of Your customers’ Personal Data, including:
- ensuring the protection of Personal Data in accordance with applicable data protection regulations;
- providing Your customers with necessary information about the processing and the recipients of their Personal Data, such as Our Company;
- supporting the exercise of the rights of Your customers under the applicable legislation, etc.
To the extent that we are acting as your data processor, We will process Your customers’ Personal Data in accordance with the terms of our agreement with You and Your lawful instructions.
e. Data we collect automatically when You use this Website
When You access the Website, We may collect certain information automatically, including, the Usage Data, Cookies, and similar tracking technologies.
This information is collected for our legitimate interest to improve and to administer Our Service, including data analysis, troubleshooting, statistical and survey purposes.
You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. For more information about the cookies we use and your choices regarding cookies, please visit our Cookies Policy.
5. With whom we may share Your Personal Data
- With Service Providers. If necessary, we may share Your Personal Data with Service Providers to monitor and analyze the use of our Service, to store the Personal Data, to show advertisements to You, to help support and maintain Our Service, to contact You, etc. We have concluded agreements with our Service Providers to protect Your Personal Data.
- For Business transfers. If the Company is involved in a merger, acquisition, reorganization, assignment, transfer, change of control, or asset sale, Your Personal Data may be transferred to third parties in connection with such transaction. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.
- With Affiliates. We may share Your Personal Data with Our Affiliates, in which case we will require those Affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.
- With Business partners. We may share Your information with Our business partners to offer You certain products, services or promotions.
- Law enforcement. Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
- Other legal requirements. The Company may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of the Company, to prevent or investigate possible wrongdoing in connection with the Service, to protect the personal safety of Users of the Service or the public, to protect against legal liability.
6. How long do we keep Your Personal Data
The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. For example, We will store Your Personal Data processed for Our newsletter and marketing purposes until You unsubscribe from receiving such e-mails. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.
The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.
7. Transfer of Personal Data to third countries
The Company will take all steps reasonably necessary to ensure that Your Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your Personal Data and other information.
Your Personal Data may be shared with other companies outside of the European Economic Area ("EEA"), when this is necessary for the purposes of providing Our Service. It may include the countries in which some of Our Affiliates and/or Service Providers are located, such as the United States. In case of such transfer we comply with applicable laws to provide an adequate level of data protection for the transfer of your Personal Data to third countries. We rely on Privacy Shield certification (for transfers to the United States), or on Standard Contractual Clauses as approved by the European Commission (for transfers to other non-EU countries) in order to offer sufficient safeguards on data protection for the data to be transferred internationally.
8. Security of Your Personal Data
We put security at the forefront of business operations. The Company has implemented a range of technical and organizational measures appropriate to secure Your Personal Data in a manner that takes account of the potential risks for Your interests and rights. We are certified with Payment Card Industry Data Security Standard (PCI Service Provider Level 1). Even though We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.
9. Your rights
You may have the following rights with regard to Your Personal Data:
- to obtain confirmation as to whether or not We process Your Personal Data, and, where that is the case, the information about such processing;
- to request rectification of inaccurate Personal Data;
- to request erasure of Your Personal Data in certain circumstances provided by law;
- to restrict the processing, for example when the processing is unlawful;
- to object to processing of Your Personal Data which is based on a legitimate interest;
- to receive Your Personal Data We process in a structured, commonly used and machine-readable format and to transmit those data to another controller;
- to withdraw Your consent to receive our newsletter or any other consent that was given at any time.
If you wish to exercise any of the rights set out above, please contact Us by email: info@solidgate.com.
You also have the right to lodge a complaint with a supervisory authority of the country in which You live or work or the country in which We are located (Lithuania).
10. Children's Privacy
Our Service does not address anyone under the age of 13, and we request that they not provide Personal Data through the Service. We do not knowingly collect Personal Data from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.
11. California residents
a. Information on Our privacy practices. You may find in this Privacy Policy and in Our Cookies Policy the information on Our privacy practices and access information as required by the California Consumer Privacy Act (“CCPA”), in particular the information about:
- the categories of Personal Data to be collected;
- the purposes for which the categories of Personal Data shall be used;
- the categories of sources from which the Personal Data are being collected;
- the categories of third parties with whom We may share Personal Data.
b. Access to Your Personal Data. We may also provide You with specific pieces of Personal Data We has collected about You but no more than twice in a year. To obtain this information from Us, please send an email to info@solidgate.com which includes “Request for California Privacy Information” on the subject line and Your state of residence and email address in the body of your message. If You are a California resident, We will provide the requested information to You at your email address in response.
c. We do not sell Your Personal Data.
d. Your right to deletion. You can request that We delete any Personal Data about You which We have collected from You, except for the cases explicitly provided for by the CCPA (e.g., when We need such data to detect security incidents, protect against illegal activity, comply with a legal obligation, etc).
e. Non-discrimination. The Company does not discriminate against You in case You exercise any of the consumer’s rights under this Privacy Policy and/or the CCPA in any way.
If you wish to exercise any of the rights set out above, please contact Us by email: info@solidgate.com.
12. Links to third-party websites
Our Service may contain links to other websites that are not operated by Us. For example, social media buttons. If You click on a third-party link, You will be directed to that third party's site. We strongly advise You to review the Privacy Policy of every site You visit.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
13. Changes to this Privacy Policy
We may update our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.
We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
14. Contact Us
If you have any comments or questions about this Privacy Policy or our data protection practices, You can contact us by email: info@solidgate.com
