Last Update 25/08/2021
Your privacy is important to us. DIGITAL VENTURES TRADING SRL ("we" or "us") is committed to protecting the privacy, confidentiality, and security of your information by complying with the requirements under applicable laws and regulations. We are committed to ensuring that all our employees, service providers, and agents uphold these obligations.
We want to make sure that you are fully aware of your rights regarding the processing of your data.
You have the right to request to access, update or correct your personal information. You also have the right to object to direct marketing and to our use of your information where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party.
If the processing of your personal information is subject to the EU General Data Protection Regulation ("GDPR"), and your personal information is processed based on legitimate interests, you have the right to object to the processing on grounds relating to your specific situation.
Under GDPR you also have the right to request to have your personal information deleted, erased or restricted and ask for portability of your personal information.
Please be aware that the rights granted to you may be limited or superseded by applicable law and DIGITAL VENTURES TRADING SRL legal and regulatory obligations. Some personal information is also required to provide you with our services.
If you would like to exercise your rights, please send us an email at email@example.com explaining your request. We may ask you to justify your identity before we can proceed with your request.
In the event of a request, we will reply to you within one (1) month.
Personal Data is collected when you use our Services when you are using our website without making a purchase.
In some cases, we will ask you to provide us with personal data to process the Services we provide to you (name, email address, phone number, etc.)
In other cases, we will automatically collect technical data on how you use our Services (IP address, online identifiers, type of device used, etc.)
We collect the following data:
|Identification information||Full name | date of birth|
|Contact information||Customer phone number | Beneficiary phone number | Customer e-mail address | physical address | Identification Document such as passport, driver license (in specific circumstances)|
|Payment and billing information||Payment method information | Billing Address | Bank detail | Payment card information|
|Transaction information||Amount and currency used for toping-up | country of the Beneficiary | Mobile operator of the Beneficiary | Transaction history|
|Correspondences and complaints||Correspondences made through our contact channels | Information provided by you to our customer service|
|Technical information||IP address | SMS content | cookies | pixels; activity logs (such as user session recordings) | online identifiers | device identifiers (such as internet browser used, operating system and mobile device used) | geolocation data|
We use your data to provide you with the service you requested for us. In particular, to:
We process your Personal Data on the following legal basis:
|Processing Purpose||Legal Basis|
|To communicate with you; to optimize our platform; for compliance, fraud prevention, and safety; to provide our service||These processing activities constitute our legitimate interests. We make sure we consider and balance any potential impacts on you (both positive and negative) and your rights before we process your personal information for our legitimate interests. We do not use your personal information for activities where our interests are overridden by any adverse impact on you (unless we have your consent or are otherwise required or permitted to by law).|
|To comply with law||We use your personal information to comply with applicable laws and our legal obligations.|
|With your consent||Where our use of your personal information is based upon your consent, you have the right to withdraw it anytime in the manner indicated in the Service or by contacting us.|
We may also use your personal information in relation to marketing, improvement or development of our products or services, for reasons of safety and security, or regulatory requirements other than in connection with your agreement or request, we do this on the basis of our or a third party’s legitimate interests, or with your consent.
We intend to protect your personal data and to maintain its accuracy. We implement reasonable physical, administrative and technical safeguards to help protect your information from unauthorized access, use and disclosure. For example, we encrypt certain sensitive personal information such as payment information when we transmit such information over the Internet. We also require that our suppliers protect such information from unauthorized access, use and disclosure.
Please be aware that communication over the Internet is not always secure even when encrypted. We are not responsible for any unauthorized access or loss of personal data that is beyond our control.
You are responsible for security of your personal information, such as your login details or personal information shared with us over Internet.
We will also 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.
We will also retain Personal Data such as 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 Services, or we are legally obligated to retain this data for longer time periods.
Your information, including Personal Data, is processed by us at our operating offices and in any other places where the parties involved in the processing are located. Indeed, the international footprint of our activities involves some transfers of personal information between different subsidiaries, as well as to third-parties located in the countries where the data protection laws may differ than those from Your jurisdiction.
In the event, providing you with our Services requires transfer of the personal information to non-European Economic Area, we will only perform it with Appropriate Technical and Organisational Measures to insure an adequate level of protection of your Personal Data.
We may disclose your Personal Data in different way in the course of our activities and in relation to you use of our Services. However, in most of these cases, your Personal Data are not disclosed to the recipients of the data as it is technically not feasible. Please see the following section on disclosure to understand to whom we may disclose your Personal Data.
With Service Providers
We may share your Personal Data with service providers to monitor and analyse the use of our Service, to contact you.
We may share, with your consent, your Personal Data with our business partners to offer you certain products, services or promotions.
For internal Purposes
We may disclose your Personal Data to any of our officers, directors, representatives, agents, servants, counsel, employees, consultants, lawyers, and other personnel authorized to access your Data in the duties. However, we will proceed to such disclosure on a strictly necessary basis.
We may disclose your Personal Data to third-party technical service providers for the purpose of the good functioning of our Services.
For Law Enforcement Purposes
Under certain circumstances, we 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).
For Business Transactions
For Other Legal Requirements
We may disclose your Personal Data in the good faith belief that such action is necessary to: