FINAURA OÜ, a legal person incorporated under the laws of Estonia with a
registry code 14696643 with a registered address at Roosikrantsi 2-768K, 10119
Tallinn, Estonia, its subsidiaries and affiliated parties (the "Company") is
committed to protecting the privacy of your personal information. The
Company is the controller and responsible for your personal data. This Privacy
Policy applies to Your use of the website www.finaura.eu (the "Site") and
governs data collection and usage in relation to the services provided on the
Site (the "Services"). This Privacy Policy and Cookie Policy constitute an
integral part of the Terms of Use. Unless otherwise specified, the terms used
in this document shall have the same meaning as in the Terms of Use.
This Privacy Policy, together with Terms of Use, provides an explanation as to
the treatment of the personal data which You provide us or that is collected
from You in the course of Your use of the Site or any third-party websites, and
describes when and how we may change this Privacy Policy, and tells You
how to contact us with any questions or comments. By using the Site, You
consent to the data practices described in this Privacy Policy.
We collect Personal Information about You and the device You use when You
use our Services on the Site or otherwise interact with the Company.
Personal Information
"Personal Information" means information that we directly associate with a
specific person or entity, which may include without limitations, name,
addresses, telephone numbers, email address, payment information, unique
device ID (the "UDID"), device location, IP address, Site usage data, etc.
"You" and "Your" refers to you, the person accessing the Site, and which by
doing so, accepts this Privacy Policy. Any use of the above terminology or
other words in the singular, plural, capitalization is taken as interchangeable
and therefore as referring to the same.
How Personal Information About You is Collected
We collect information about You in three primary ways:
a. Information You Provide. We collect information that You provide to us
when You register for or use the Site, or otherwise communicate with
us. Without limitations, provision of information by You may include the
following: information provided when You contact us or register (e-
mail, password) to participate in our affiliated products, KYC
information (as set forth in the AML/KYC Policy and Verification Levels),
the Company may collect personal contact information, billing
information and any information shared with payment processors, all
as may be necessary for the provision of the Company Services or the
interaction executed by You.
b. Upon the establishment or modification of an account with the
Company, We may collect user identification information, passwords,
security question responses, or other elements related to account
security, or any other means of identification, which You will use for the
future sign-on.
c. Upon interaction with our Customer Service representatives or anyone
acting on behalf of the Company, or once You enter information on the
Site, submit survey responses, we may also collect Personal Information
and other data. We may monitor and record phone calls, e-mails, live
chats, or other communications between You and our Customer
Service representatives or other employees or representative
Information We Collect Automatically
We automatically collect a variety of Personal Information associated with
Your use of the Site or the Services. Each time You visit the Site Personal
Information is automatically gathered, which in general, does not identify.
You personally and may include without limitations: UDID, IP address,
Country, City (if available), Connection Speed, Publisher Name, Collection
Date, Day of Week, Time of Day (hour), Language settings in addition to any
information provided directly by You, all of which allows the Company to
evaluate Your use of the Site for the purpose of improving the Site and the
The Use of Cookies
The Company uses cookies to appropriately run the Website, analysis of the
Website traffic, and marketing purposes. To learn more about the cookies,
please read the Cookie Policy.
The Use of Web Beacons
The Company may use web beacons (or "pixels"), which are small graphic
images on a web page or an HTML, for the purpose of monitoring interaction
with the Site or e-mails.
Site Use Activity
Through Your access to the Site, we automatically collect certain Personal
Information about Your use of the Site, such as Your IP address, browser type,
date and time, the web pages You visited before visiting the Site, Your
activities and downloads on the Site, and additional analytical information
associated with the Site.
Information from Other Sources
The Company may collect information about You from other sources. For
example, the Company may receive certain credit information from third-
party sources before initiating any service to You. The Company may also
purchase or obtain Personal Information (for example, e-mail lists, postal mail
lists, demographic and marketing data) from third parties.
Cryptographic Hashes
Members sending Virtual Currency to the Site through the use of
cryptographic hashes and keys take full responsibility for the risks involved.
By using the Services you will automatically accept liability of any loss,
damages, or implications incurred through the use of this Site and the
Company will not be held liable for any loss of Your Virtual Currencies.
If You do not agree you can request the return of Your Virtual Currencies
through the use of a withdrawal once logged in.
No cryptographic private keys are held on the Site servers. Virtual Currencies
sent to cryptographic public keys displayed on the Site are immediately
forwarded to offline vaults.
The Company’s Use of the Personal Information Collected About You
The Company may use the Personal Information collected about You for a
variety of business purposes, including the following:
For providing customer services to You;
For identifying and suggesting products or services that might interest
For verifying Your identity and maintaining a record of Your
transactions and interactions with us;
For processing any transaction as applicable;
For making internal business decisions about current and future
service offerings;
For creating, modifying, improving, enhancing, removing, or fixing our
Services and their performance;
For providing You customized user experiences, including personalized
services offerings;
For protecting our rights, interests, safety and property and that of our
customers, service providers, and other third parties and affiliates;
The Company may use third-party vendors, subcontractors, network
advertisers, and other businesses to deliver various services to You on
the Company’s behalf. These providers may be supplied with or have
access to Your information, including Your non-personally identifiable
information (such as Your IP address and Your UDID) for the purposes
of performing the functions for which the Company has engaged them.
Provided that such providers have access to your personally identifiable
information, they are bound by a confidentiality obligation; and
The Company may disclose and use personally identifiable information
in the course of resolving disputes, problems troubleshoot,
enforcement of the Terms of Use or other legal rights (for example,
when necessary to protect the Company or a third party's intellectual
property or proprietary rights), or to alert You to changes in our policies
or Terms of Use that may affect Your use of the Site.
Use for Marketing
The Company may use the information the Company collects to contact You
with regards to our and/or third-party services, products, and offers, which
the Company believes might serve Your interests. In doing so, the Company
may contact You by telephone, postal mail, e-mail, or other methods after
receiving your consent to do so.
In addition, the Company uses Your UDID and information about third parties
websites that You have visited through the Services to report on the number
of users who click through the websites or who accessed third parties
websites as a result of certain ads.
Use for Advertising
Upon the use of the Site, You may be exposed to advertisements. The
Company may assist advertisers to better reach our users by providing
certain customer information, including geographic information, language
preferences, or demographic information obtained from other companies.
The information provided as aforementioned may then be used by
advertisers to determine which ads may be more relevant to You. However,
the Company does not share Personal Information outside of our corporate-
related entities for advertising purposes without Your consent.
Links to Other Content and Third Party Websites
The Company may make content or services from other websites available to
You through links located on the Site. These other sources are not subject to
this Privacy Policy, and the Company has no control over how such sources
may use the personal information collected on their websites. Similarly, the
websites You choose to access through the use of the Site are owned by third
parties and we have no control over what information is collected or used by
such third parties as a result of Your use of third parties’ websites. We
recommend that You review the privacy policy and users’ terms associated
with each of these third-party websites to determine their privacy policies. In
any event, the Company will not be held responsible for the privacy-related
practices, use of Your information by third parties, or the content of third
party providers.
Furthermore, the payment processing services on the Site are provided by
third party payment processing providers, which may also provide fraud
management services and are disclosed of Your information once You
execute a Transaction. Such a payment processing service provider may
further collect additional information and documents from You for the
assessment of fraud risks. You should make yourself aware of any third-party
privacy policy which governs the use and collection of Your information by
such third-party provider. The Company will not be held liable or responsible
for such third party practices and use of Your information.
Use for any Fraud Prevention
We may use Personal Information for investigations or for prevention of
fraud, AML, CTF, for Consumer Protection or network abuse and to protect
our users.
When We Share Information Collected About You
Except as detailed herein this Policy, the Company does not sell, license, or
otherwise provide Your Personal Information to unaffiliated third parties,
which are outside our corporate family without Your consent. The Company
may, however, disclose Your information to unaffiliated third-parties with
Your Consent obtained in either writing, online, through "click-through"
agreements and downloads, upon acceptance by You of the terms of
disclosures for certain Services, in writing (including without limitations by
chat or email) or orally, when You interact with our customer service
Access to Third-Parties
Should You be required to choose a username or password while using the
Site or the Company’s products, You should refrain from sharing Your login
information with any third party. If You provide any of Your login information
to third parties, such third parties will gain access to all Your Personal
Information upon accessing Your Account with Your login information.
Furthermore, sharing Your login information with third parties is forbidden
under AML restrictions, CTF, Fraud, and identity theft provisions.
For Legal Process & Protection
The Company may disclose Personal Information, and other information
about You, or Your communications, where disclosure of such information is
reasonably necessary: (i) In order to satisfy any applicable law, regulation,
legal process or enforceable governmental request, including AML, CTF, Anti-
Fraud and Consumer Protection requirements; or (ii) In order to enforce or
apply agreements, or initiate, render, bill, and collect for services and
products (including to collection agencies in order to obtain payment for our
products and services); (iii) In order to protect our rights or interests, property
or safety or that of others; or (iv) In order to assist with claims, disputes, or
litigation in court or elsewhere; or (v) In order to facilitate or verify the
appropriate calculation of taxes, fees, or other obligations or in an emergency
How We Store and Protect Personal Information
The Company uses a variety of physical, electronic, and procedural safeguards
to protect Personal Information from unauthorized access, use, or disclosure
while it is under our control. Unfortunately, no data transmission over the
internet can be guaranteed to be completely secure. As a result, although the
Company utilizes security measures, the Company may not guarantee You
against the loss, misuse, or alteration of Personal Information under our
control, and You provide Personal Information to us at Your own risk. You
should always take care of how You handle and disclose your Personal
Information and should avoid sending Personal Information through insecure
email, social networks, or other internet channels.
Retention and Disposal. The Company retains information for as long as we
have a business or tax need or as required under the applicable laws,
regulations, and/or government orders from time to time. Following
termination of the Account, the Company endeavors to erase and discard
Your data subject to the limitations and requirements under the applicable
laws and regulations.
Transfer to other countries
For the purpose of providing You with the Services, the Company transfers
Your information to different countries outside Your country where the
Company has facilities. By using the Site, You consent to the transfer of Your
information outside of Your country.
Privacy Policy Updates
The Company may amend this Privacy Policy at any time. You should always
refer to this Policy posted on the Site for the latest information and the
effective date of any changes. By continuing to access or use the Services
after those changes become effective, you agree to be bound by the revised
Privacy Policy
Your rights
You have the right to access Your Personal Information and to require the
correction, updating, and blocking of inaccurate and/or incorrect data by
sending an email to the Company at [support email] or where possible, you
can do these actions in Your account profile page Yourself.
Upon your written request, the Company will inform You of the Personal
Information relating to You that the Company holds and the use and general
disclosure of Your Personal Information. The Company will also give You a
copy of the Personal Information the Company has retained. There may be a
minimal charge for providing you additional copies of Your Personal
Information to cover administrative costs.
You may also request the deletion or destruction of both the Account and
Personal Information by sending an email to us at [support email]. The
Company will action your request immediately, except, where this is not
consistent with its legal and regulatory obligations.
You have the right to ask us to transfer your Personal Information to another
controller of your choice by sending an email to us at [support email].
You have the right to withdraw the consent if you previously gave the
consent to the processing of your Personal Information, for example, for
marketing purposes by sending an email to us at [support email].
If we process your Personal Information in our legitimate interests you have
the right to object against it by sending an email to us at [support email]. If
there are no legal grounds to refuse it, we shall stop processing your Personal
Information for such purposes.
You have the right to request to temporarily stop the processing of your
Personal Information (when contenting its accuracy or when you think we
process it unlawfully).
You can learn more and complete your requests to exercise data rights by
contacting the Company at [support email].
If you believe that the Company violates your data rights, you have the right
to file a complaint with your national data protection authority.
To ensure the confidentiality, integrity, and availability of Your information to
Yourself, the Company may request You to confirm Your identity by providing
identification documentation and/or other methods prior to assisting you in
exercising any of Your rights.
If You refuse to prove your identity, the Company may decline to take actions
in respect of Your data, save restricting processing, until the Company can
ensure that such actions are the true wish of the data subject.
In the carrying out of the Services, the Company may use automated
processing and profiling to reduce the risks of fraud, money laundering, and
abuse of our services. Through this automated processing, the Company
carries out an analysis of Your identification, transactional, and behavioral
The Company may not able to provide you with some or all the Services if you
do not wish this automated processing to be carried out. If You feel that this
processing might be detrimental to You, we can provide You with further
information about this automated processing by contacting us at [support
The Company has appointed a data protection manager who is responsible
for overseeing questions in relation to this Privacy Policy. If you have any
questions about this Privacy Policy, including any requests to exercise your
legal rights, please contact the data privacy manager using the details set out
Email address: support@finaura.eu.