Privacy and Cookies Policy

This cookie and privacy policy (Policy) describes the types of personal data  Digital Dealing Desk OÜ collects, how Digital Dealing Desk OÜ uses Client’s personal data, with whom Digital Dealing Desk OÜ shares Client’s personal data, how Digital Dealing Desk OÜ stores and protects Client’s personal data and how Clients can contact Digital Dealing Desk OÜ regarding privacy practices.

Clients accept the terms and conditions of this Policy by visiting Digital Dealing Desk OÜ website or using Digital Dealing Desk OÜ Online Platform application.

Herein, “Digital Dealing Desk OÜ” refers to the data controller, Digital Dealing Desk OÜ , registry code 14635720, a limited company incorporated under the laws of the Republic of Estonia, with the address at. Tartu mnt 53-408, 10115, Tallinn, Estonia

“Clients” are the data subject, client of Digital Dealing Desk OÜ.

Personal data collects Digital Dealing Desk OÜ

For the purposes described in Terms&Conditions Digital Dealing Desk OÜ collects and processes primarily (but not only) the following data about Client: name, date of birth, personal identification code, information regarding an identity document (incl. nationality), Client’s residency, information required by law (e.g. information about origin of Client’s assets, purpose of the business relationship etc.), Client’s preferences regards Euro Exchange services and products, e-mail address, physical address, information about Client’s work or study, habits, preferences and satisfaction, Client’s device-ID, IP-address, Client’s geo-location, credit and debit card information, payment details, Client’s IBANs and other bank and payment account related details (incl. balance, logs, transactions), phone number, data and information located in or which is related to the device that is used for Digital Dealing Desk OÜ services (including the device’s identification code, customer contacts, and data related to images) and any other data Client provide to Digital Dealing Desk OÜ, during each visit to the Digital Dealing Desk OÜ Web site, or by accessing and using Digital Dealing Desk OÜ services which includes following:

  • Technical information – Internet Protocol (IP) address used to connect your computer to the Internet, unique device identifier, location, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  • Information about clients visit – including the full Uniform Resource Locators (URL) clickstream to, through and from our website (including date and time); referrer URL; products and services viewed or searched for; page response times; download errors; length of visits to certain pages; page interaction information (such as scrolling, clicks, and mouse-overs); and methods used to browse away from the page; and any phone number used to call our customer service number;
  • Transaction information – including date, time, amount, currencies used, exchange rate, beneficiary details, details and location of the merchant or ATMs associated with the transaction, IP address of sender and receiver, sender’s and receiver’s name and registration information, messages sent or received with the payment, device information used to facilitate the payment and the payment instrument used

The purposes of processing Client’s personal data

Digital Dealing Desk OÜ processes Client’s personal data described in Section 1 for the following purposes:

  • to process Client’s payment and service requests and transactions either on Digital Dealing Desk OÜ own platform or together with partners of Digital Dealing Desk OÜ;
  • to protect against and prevent fraud and unauthorized transactions either on Digital Dealing Desk OÜ own platform or together with partners of Digital Dealing Desk OÜ;
  • to create and manage Client’s account either on Digital Dealing Desk OÜ own platform or together with partners of Digital Dealing Desk OÜ;
  • to offer Client new services either on Digital Dealing Desk OÜ own platform or together with other financial institutions or partners;
  • to analyse the use of Digital Dealing Desk OÜ or its partner services and make improvements thereof;
  • to administer Digital Dealing Desk OÜ website and mobile application(s);
  • to comply with the regulatory requirements and requests of the supervisory and law enforcement authorities;
  • to respond to Client’s or Digital Dealing Desk OÜ partner inquiries;
  • to comply with industry standards and policies;
  • to provide information about Client and Client’s transactions and use of services to partners of Digital Dealing Desk OÜ (e.g. for loyalty programmes).

Sharing and storing personal data

Digital Dealing Desk OÜ may share Client’s personal data with its affiliate entities. Also, Digital Dealing Desk OÜ may share Client’s personal data with selected financial institutions and business partners for the purposes set out in Section 2. The client hereby agrees that Digital Dealing Desk OÜ shares information on and related to the Client’s with third parties so the customer can use Digital Dealing Desk OÜ products and services (including service providers and partners related to technical infrastructure and product’s safely, service providers and partners related to payments and cards, analytics and statistics, and other partners related to Digital Dealing Desk’s services and products). If required under applicable law, Digital Dealing Desk OÜ will share Client’s personal data with law enforcement agencies.

Digital Dealing Desk OÜ will not store Client’s personal data outside the European Economic Area and in countries which have not received the European Commission’s “adequacy decision” on the basis of Article 25 ( 6 ) of Directive 95/46/EC.

Digital Dealing Desk OÜ has taken appropriate technical, physical and organisational security measures against the loss and unlawful processing of Clients personal data.

Digital Dealing Desk OÜ based in the Estonia, our service providers may store, transfer, and otherwise process client’s personal information in countries outside of the country of your residence, and possibly other countries which are within the EEA or granted recognition of adequacy by the European Commission. We use approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland.

Digital Dealing Desk OÜ will not sell, purchase, provide, exchange or in any other manner disclose Account or Transaction data, or personal information of or about a Cardholder to anyone, except, it’s Acquirer, Visa/Mastercard Corporations or in response to valid government demands.

Cookies

Digital Dealing Desk OÜ uses cookies on Digital Dealing Desk OÜ website. Cookie is a small text file, which is placed automatically on Client’s device by the Internet browser. Cookies are used to assist in collecting information associated with Client’s use of the website in order to personalise Client’s use of Digital Dealing Desk OÜ website. Digital Dealing Desk OÜ es the following cookies:

  • session cookies for the purpose of enabling the use of Digital Dealing Desk OÜ service;
  • permanent cookies for the purpose of remembering Client’s choices on Digital Dealing Desk OÜ website;
  • first and/or third party (advertising) cookies for the purpose of showing Client relevant advertising and offers;
  • third party analytic cookies for the purpose of optimising marketing communication.

Client may disable cookies being stored on Client’s device by changing Client’s browser settings. However, as a result, Digital Dealing Desk OÜ website may not function properly and/or some features may not be available to Client in that case.

In addition to using analytic cookies, Digital Dealing Desk OÜ uses pixel tags and web beacons for the purpose of monitoring the use of Digital Dealing Desk OÜ website. Digital Dealing Desk OÜ does not process any personally identifiable information in that regard.

Client’s rights to information control

Client have the right to access Client’s personal data processed by Digital Dealing Desk OÜ and the right to demand the correction of inaccurate personal data.

Whenever clients are asked to fill in a form on the website, look for the box that you can click to indicate that you want the information to be used by anybody for direct marketing purposes. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to or emailing us at [email protected] or in a same manner as you subscribed by clicking on a box on our webpage.

We will not sell, distribute or lease your personal information to third parties unless we have your permission or are required by law to do so. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen. We do not disclose information about identifiable individuals to our advertisers.

You may request details of personal information which we hold about you. A small fee will be payable if request will be excessive or manifestly unfounded (for example, where you make repetitive requests to supply you with the information). If you would like a copy of the information held on you, please send us secure message via our client portal, or if you are no longer a client, please write to Tartu mnt 53-408, 10115, Tallinn, Estonia or email us at [email protected] Note that while requesting us to supply you with information we will need to identify your personality.

You may request us to correct or delete any information which you believe is incorrect or incomplete. In such case please send us secure message via our client portal, or if you are no longer a client, please write to Tartu mnt 53-408, 10115, Tallinn, Estonia or email us at [email protected] Note that while requesting us to correct or delete any information we will need to identify your personality. We will promptly correct any information found to be wrong. However, if you will request us to delete the information which we must maintain in order to follow our legal obligations such as fraud prevention, anti-money laundering or counter terrorism financing we will need to decline your request and keep that information for five (5) years after last settled transaction or from the end date of our relationship, whichever occurs last.

At all time during our collaboration you have a right to withdraw your consent and hence not supply us with your information, stop using our services and stop our collection from the third parties. In such case, we will stop processing of your information when all outstanding orders will be settled. If you wish to withdraw your consent you may change it in your settings, send us secure message via our client portal, or if you are no longer a client, please write to Tartu mnt 53-408, 10115, Tallinn, Estonia or email us at [email protected] Note that while requesting us to supply you with information we will need to identify your personality However, if you withdraw your consent, we will still retain information, which we must maintain in order to follow our legal obligations such as fraud prevention, anti-money laundering or counter terrorism financing and we will keep that information for five (5) years after last settled transaction or from the end date of our relationship, whichever occurs last.

You can object any of our action or inaction in relation to handling of your personal information by writing to Tartu mnt 53-408, 10115, Tallinn, Estonia or email us at [email protected] You may choose to file a complaint with the Komisja Nadzoru Finansowego, data protection inspectorate filing a report over internet [email protected]. If you are residing in another country you may contact your competent national authority responsible for the protection of information.

Other

Digital Dealing Desk OÜ may unilaterally change this Policy from time to time. The latest version of this Policy is always posted on this page.

Digital Dealing Desk OÜ website may contain links to other websites owned and operated by third parties or Digital Dealing Desk OÜ partners. These websites are out of Digital Dealing Desk’s control and Digital Dealing Desk OÜ is not responsible for the content of those websites or any hyperlink contained in those websites. Also, Digital Dealing Desk OÜ website may contain third party advertisements which may contain embedded hyperlinks to the websites of third parties or Digital Dealing Desk OÜ partners.  Digital Dealing Desk OÜ excludes any liability regarding the interaction between Client and these advertisement providers.

This Policy is governed by the laws of Republic of Poland. Any dispute or claim arising out of this Policy will be subjected to the Republic of Poland, EU as the court of first instance.