Privacy policy
Company: PLATFORMA365 LIMITED
Address: Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Registration Nr: 117378
Date of commencement: 16/05/2018
Address: Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Registration Nr: 117378
Date of commencement: 16/05/2018
Version: 1.0
First Introduced: 16/05/2018
Endorsed by the Management Committee on: Applicable
Approved by the Board of Directors: Approved
First Introduced: 16/05/2018
Endorsed by the Management Committee on: Applicable
Approved by the Board of Directors: Approved
SCOPE
This privacy policy explains in detail the types of personal data PLATFORMA365 LIMITED (PLATFORMA) may collect about legal entities and private persons which interact with the company, methods of storage and handling that data and other parties’ rights associated with it.
When you use our website https://platforma365.com/ (the “Website”) and/or our services, PLATFORMA365 LIMITED is the data controller of your personal data and adheres to the EU General Data Protection Regulation 2016/679 (hereafter referred to as “GDPR”).
This Privacy Notice supersedes all previous notices or guidance issued prior to the commencement date as stated above.
How we collect your personal information
PLATFORMA collects “personal data” of users and customers in connection with the Services (as defined in the Terms of Use). Personal data means information that refers to an identified or identifiable person.
PLATFORMA also collects “anonymized information” which does not relate to an identified or identifiable person as it is anonymous and is not personally identifiable information. This information is collected for PLATFORMA’s own purpose as described below.
You may give us your identity, contacts, business details and other personal information by corresponding with us via email, messenger services, phone or by completing our forms.
This includes personal data you provide when you:
– meet our company representatives
– use our Website
– communicate with us by email, phone or messenger apps
– complete our questionnaire or other forms or agreements
– use other electronic means to identify yourself
– are being introduced to us by your agent, tax adviser, attorney or other intermediary
– subscribe to our newsletter or services
– order our services
– pay for our services
We may also collect profile information and insight from publicly available sources or third parties (such as risk management solutions organizations), when we are conducting background checks on you as a part of our due diligence obligations.
What personal information do we collect?
We may collect the following information about you:
Identity data
– your title, first name, last name; your biographical data, such as date of birth, tax identification number, passport/ID numbers, your nationality, domicile and citizenship.
Contact data
– contact information such as your residential and business addresses, phone numbers, email addresses, and your communication app accounts (such as Skype, Whatsapp etc.)
Business data
– your reasons for using our services, including business and development plans
Due diligence data
– information required to understand whether you represent a risk of money laundering, terrorism financing or being a politically-exposed person
Financial data
– bank account or payment account details (if you use payment service providers other than banks).
Technical data
-your internet protocol (IP) address
– information about from where you visited our Website and which site you subsequently visited
– browser type and version
– time zone and location
– operating system and platform of the device you used to visit our Website
Marketing & Communications data
– information about whether you have opened our newsletter email, when and how many times
– your preferences for receiving newsletter emails from us
Cookies
Similar to other websites, we may use cookies and similar technologies. Cookies are used to obtain information about user behavior during the use of the Website and Services. A cookie is a small text file with a unique identification number that identifies a user’s browser. It is generated by a web page server, which is basically the computer that operates a web site. Cookies are not computer programs or codes, they are not used to transfer viruses. Modern versions of browsers allow users to reject or opt out of receiving cookies.
The cookies on the Website may be of the following categories:
– Strictly necessary cookies – these are strictly essential cookies that enable you to browse the Website and use its tools and features. With this type of cookies, you may log into your account on the Website and access other secure areas of the Website. Without them you may not be able to use our
Website partially or in whole.
– Functionality cookies – these cookies are used to enhance the Website and its functionality. These cookies remember your personal choices made when you browse and access the Website (like your language preference, location). The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.
– Analytical cookies – these are not personally identifiable cookies. They allow users to navigate through the pages and while navigating, these cookies collect information about which pages you visit and how you use online services. This allows us to improve our services and your user experience with us. We may share this information with third parties for this purpose.
We use cookies in order to identify user behavior on the Website, to allow users navigate through the Website pages, to remember user’s preferences, to enable security features and to improve the Website and its tools.
Though it is possible to delete or reject cookies, such deletion or rejection of cookies may prevent you to access or use certain features or areas of the Website.
How and why do we use your personal data?
– to respond to your queries, prepare our service contracts, proposals, etc. and to enable our services, which require us knowing your personal information
– we may share some of this information in order to deliver our services to you. For example, we may share information with our legal advisors, accountants and risk management companies. For more about information sharing, please see below.
– to manage our business and monitor our own performance, for example analysing our client database when developing new services.
– to protect our business and your account from fraud and other illegal activities. For example we may ask you to verify your identity.
– to offer you new products and services.
Who do we share your personal information with?
In certain cases your personal information may be disclosed to 3rd parties:
– we have a legal obligation to comply with anti-money laundering and terrorism finance laws
– we are obliged to disclose personal information to competent authorities, law enforcement agencies as well as our regulators if necessary and in accordance with the laws of Gibraltar and European Union.
– we may disclose your information to our auditors
– we disclose certain information to 3rd parties who conduct background checks on you as a part of our due diligence procedure
– our data storage service provider
– our advisors or partners, in case we need to obtain legal or accounting advice in relation to services we render to you, or outsource part of the service
Legal basis
PLATFORMA collects and processes personal data only if PLATFORMA has lawful basis. Lawful basis includes:
– consent (where you have given consent);
– contractual obligations (when the processing is necessary to perform our obligations under a contract);
– legitimate interests;
– compliance with applicable law (when we follow applicable personal data law in order to be complied with).
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
The legitimate interests are:
– analysing and understanding user behaviour on the Website;
– providing with the Services ordered;
– processing billing and collecting fees;
– making improvements to the Website;
– enabling us to enhance, customise or modify the Services and communications;
– improving data security;
– determining whether marketing campaigns are effective.
Minors
PLATFORMA does not knowingly collect personal information from anyone under 18 years of age. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
How can you subscribe or unsubscribe from direct marketing?
Subject to the notification preferences you subscribed to, from time to time we may send you regulatory updates, our proposals, reviews of new products, invitations to business events and other information, which we believe may be of interest to you.
There are several ways you can stop direct marketing communications from
PLATFORMA365 LIMITED:
– click the “unsubscribe” link in any direct marketing communication email you receive from us.
– email us at info@platforma365.io , asking us to unsubscribe you.
– write to:
PLATFORMA365 LIMITED
Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Please note that you may continue to receive direct marketing communication from us for a short period of time after unsubscribing while our systems are being updated with your new preferences.
What are your rights over your personal information?
Under the GDPR you have the following rights:
– To request and obtain a copy of information we hold about you
– To request that we erase data we hold about you
– To ask us to cease to process your personal data
– To request that we stop sending you our marketing materials and promotions
– To request that we correct the data we hold on you
Where can you find out more information on the topic of data protection?
For more information about your rights, please visit the website of the European Commission https://ec.europa.eu/info/privacy-policy_en
How to complain
If you are not happy with how we process your information, you can make a complaint via the website of the European Commission https://ec.europa.eu/info/about-european-commission/contact_en
How to withdraw your consent
If you have previously given us your consent to process your personal information and would like to withdraw it, then please write to:
info@platforma365.io or
PLATFORMA365 LIMITED
Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Data retention
In certain cases we will retain your personal information lawfully in accordance with the demand of the European Commission.
We retain your personal data primarily within the European Union and the European Economic Area.
We adhere to the anti-money laundering regulations and we are obliged to retain your personal details for 5 years from the date of termination of our relationship, unless we are ordered by a court or other competent authority to retain your data for a longer period.
We also store your personal details for 5 years from the termination of our contractual or other relations in case any claims arise out the services we have rendered you.
Retention periods may be changed from time to time based on regulatory requirements.
The data inventory
PLATFORMA stores personal information in accordance with the following principles:
The purposes of keeping this information are clearly identified
PLATFORMA regularly reviews the processing of this information and, where necessary, updates documentations and privacy information for individuals.
PLATFORMA collects only personal data needed for its’ specified purposes.
PLATFORMA periodically reviews the stored data, and delete any redundant information.
PLATFORMA makes sure that access to personal data can be restored in the event of any incidents, such as by establishing an appropriate backup process.
PLATFORMA conducts regular testing and reviews of measures to ensure they remain effective, and acts on the results of those tests where they highlight areas for improvement.
PLATFORMA ensures that any data processor that could be used by the company in the future also implements appropriate technical and organizational measures.
Merge of Company
If PLATFORMA merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal data may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal data will always remain subject to this Privacy Policy.
Changes to the Privacy Policy
We may need to update this Privacy Policy from time to time. As soon as the Privacy Policy is updated, PLATFORMA will post an updated version of the Privacy Policy on the Website. The new Privacy Policy becomes effective from the moment it is posted or updated on the Website, unless otherwise indicated therein. We will send you an email notification to alert you about such changes.
Key responsibilities person(s)
Under data protection law every person that handles personal data has some responsibility to ensure that it is used appropriately. However, the following person(s) within PLATFORMA365 LIMITED have key responsibilities:
Maxim Ivanchenko has overall responsibility as Data Protection Officer for ensuring that the organization meets its obligations under data protection law.
This privacy policy explains in detail the types of personal data PLATFORMA365 LIMITED (PLATFORMA) may collect about legal entities and private persons which interact with the company, methods of storage and handling that data and other parties’ rights associated with it.
When you use our website https://platforma365.com/ (the “Website”) and/or our services, PLATFORMA365 LIMITED is the data controller of your personal data and adheres to the EU General Data Protection Regulation 2016/679 (hereafter referred to as “GDPR”).
This Privacy Notice supersedes all previous notices or guidance issued prior to the commencement date as stated above.
How we collect your personal information
PLATFORMA collects “personal data” of users and customers in connection with the Services (as defined in the Terms of Use). Personal data means information that refers to an identified or identifiable person.
PLATFORMA also collects “anonymized information” which does not relate to an identified or identifiable person as it is anonymous and is not personally identifiable information. This information is collected for PLATFORMA’s own purpose as described below.
You may give us your identity, contacts, business details and other personal information by corresponding with us via email, messenger services, phone or by completing our forms.
This includes personal data you provide when you:
– meet our company representatives
– use our Website
– communicate with us by email, phone or messenger apps
– complete our questionnaire or other forms or agreements
– use other electronic means to identify yourself
– are being introduced to us by your agent, tax adviser, attorney or other intermediary
– subscribe to our newsletter or services
– order our services
– pay for our services
We may also collect profile information and insight from publicly available sources or third parties (such as risk management solutions organizations), when we are conducting background checks on you as a part of our due diligence obligations.
What personal information do we collect?
We may collect the following information about you:
Identity data
– your title, first name, last name; your biographical data, such as date of birth, tax identification number, passport/ID numbers, your nationality, domicile and citizenship.
Contact data
– contact information such as your residential and business addresses, phone numbers, email addresses, and your communication app accounts (such as Skype, Whatsapp etc.)
Business data
– your reasons for using our services, including business and development plans
Due diligence data
– information required to understand whether you represent a risk of money laundering, terrorism financing or being a politically-exposed person
Financial data
– bank account or payment account details (if you use payment service providers other than banks).
Technical data
-your internet protocol (IP) address
– information about from where you visited our Website and which site you subsequently visited
– browser type and version
– time zone and location
– operating system and platform of the device you used to visit our Website
Marketing & Communications data
– information about whether you have opened our newsletter email, when and how many times
– your preferences for receiving newsletter emails from us
Cookies
Similar to other websites, we may use cookies and similar technologies. Cookies are used to obtain information about user behavior during the use of the Website and Services. A cookie is a small text file with a unique identification number that identifies a user’s browser. It is generated by a web page server, which is basically the computer that operates a web site. Cookies are not computer programs or codes, they are not used to transfer viruses. Modern versions of browsers allow users to reject or opt out of receiving cookies.
The cookies on the Website may be of the following categories:
– Strictly necessary cookies – these are strictly essential cookies that enable you to browse the Website and use its tools and features. With this type of cookies, you may log into your account on the Website and access other secure areas of the Website. Without them you may not be able to use our
Website partially or in whole.
– Functionality cookies – these cookies are used to enhance the Website and its functionality. These cookies remember your personal choices made when you browse and access the Website (like your language preference, location). The information these cookies collect may be anonymous and they cannot track your browsing activity on other websites.
– Analytical cookies – these are not personally identifiable cookies. They allow users to navigate through the pages and while navigating, these cookies collect information about which pages you visit and how you use online services. This allows us to improve our services and your user experience with us. We may share this information with third parties for this purpose.
We use cookies in order to identify user behavior on the Website, to allow users navigate through the Website pages, to remember user’s preferences, to enable security features and to improve the Website and its tools.
Though it is possible to delete or reject cookies, such deletion or rejection of cookies may prevent you to access or use certain features or areas of the Website.
How and why do we use your personal data?
– to respond to your queries, prepare our service contracts, proposals, etc. and to enable our services, which require us knowing your personal information
– we may share some of this information in order to deliver our services to you. For example, we may share information with our legal advisors, accountants and risk management companies. For more about information sharing, please see below.
– to manage our business and monitor our own performance, for example analysing our client database when developing new services.
– to protect our business and your account from fraud and other illegal activities. For example we may ask you to verify your identity.
– to offer you new products and services.
Who do we share your personal information with?
In certain cases your personal information may be disclosed to 3rd parties:
– we have a legal obligation to comply with anti-money laundering and terrorism finance laws
– we are obliged to disclose personal information to competent authorities, law enforcement agencies as well as our regulators if necessary and in accordance with the laws of Gibraltar and European Union.
– we may disclose your information to our auditors
– we disclose certain information to 3rd parties who conduct background checks on you as a part of our due diligence procedure
– our data storage service provider
– our advisors or partners, in case we need to obtain legal or accounting advice in relation to services we render to you, or outsource part of the service
Legal basis
PLATFORMA collects and processes personal data only if PLATFORMA has lawful basis. Lawful basis includes:
– consent (where you have given consent);
– contractual obligations (when the processing is necessary to perform our obligations under a contract);
– legitimate interests;
– compliance with applicable law (when we follow applicable personal data law in order to be complied with).
Where we rely on your consent to process personal data, you have the right to withdraw or decline your consent at any time and where we rely on legitimate interests, you have the right to object.
The legitimate interests are:
– analysing and understanding user behaviour on the Website;
– providing with the Services ordered;
– processing billing and collecting fees;
– making improvements to the Website;
– enabling us to enhance, customise or modify the Services and communications;
– improving data security;
– determining whether marketing campaigns are effective.
Minors
PLATFORMA does not knowingly collect personal information from anyone under 18 years of age. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
How can you subscribe or unsubscribe from direct marketing?
Subject to the notification preferences you subscribed to, from time to time we may send you regulatory updates, our proposals, reviews of new products, invitations to business events and other information, which we believe may be of interest to you.
There are several ways you can stop direct marketing communications from
PLATFORMA365 LIMITED:
– click the “unsubscribe” link in any direct marketing communication email you receive from us.
– email us at info@platforma365.io , asking us to unsubscribe you.
– write to:
PLATFORMA365 LIMITED
Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Please note that you may continue to receive direct marketing communication from us for a short period of time after unsubscribing while our systems are being updated with your new preferences.
What are your rights over your personal information?
Under the GDPR you have the following rights:
– To request and obtain a copy of information we hold about you
– To request that we erase data we hold about you
– To ask us to cease to process your personal data
– To request that we stop sending you our marketing materials and promotions
– To request that we correct the data we hold on you
Where can you find out more information on the topic of data protection?
For more information about your rights, please visit the website of the European Commission https://ec.europa.eu/info/privacy-policy_en
How to complain
If you are not happy with how we process your information, you can make a complaint via the website of the European Commission https://ec.europa.eu/info/about-european-commission/contact_en
How to withdraw your consent
If you have previously given us your consent to process your personal information and would like to withdraw it, then please write to:
info@platforma365.io or
PLATFORMA365 LIMITED
Office Suite 24, Block 6, Water Gardens, Waterport Wharf, GX11 1AA, Gibraltar
Data retention
In certain cases we will retain your personal information lawfully in accordance with the demand of the European Commission.
We retain your personal data primarily within the European Union and the European Economic Area.
We adhere to the anti-money laundering regulations and we are obliged to retain your personal details for 5 years from the date of termination of our relationship, unless we are ordered by a court or other competent authority to retain your data for a longer period.
We also store your personal details for 5 years from the termination of our contractual or other relations in case any claims arise out the services we have rendered you.
Retention periods may be changed from time to time based on regulatory requirements.
The data inventory
PLATFORMA stores personal information in accordance with the following principles:
The purposes of keeping this information are clearly identified
PLATFORMA regularly reviews the processing of this information and, where necessary, updates documentations and privacy information for individuals.
PLATFORMA collects only personal data needed for its’ specified purposes.
PLATFORMA periodically reviews the stored data, and delete any redundant information.
PLATFORMA makes sure that access to personal data can be restored in the event of any incidents, such as by establishing an appropriate backup process.
PLATFORMA conducts regular testing and reviews of measures to ensure they remain effective, and acts on the results of those tests where they highlight areas for improvement.
PLATFORMA ensures that any data processor that could be used by the company in the future also implements appropriate technical and organizational measures.
Merge of Company
If PLATFORMA merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal data may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal data will always remain subject to this Privacy Policy.
Changes to the Privacy Policy
We may need to update this Privacy Policy from time to time. As soon as the Privacy Policy is updated, PLATFORMA will post an updated version of the Privacy Policy on the Website. The new Privacy Policy becomes effective from the moment it is posted or updated on the Website, unless otherwise indicated therein. We will send you an email notification to alert you about such changes.
Key responsibilities person(s)
Under data protection law every person that handles personal data has some responsibility to ensure that it is used appropriately. However, the following person(s) within PLATFORMA365 LIMITED have key responsibilities:
Maxim Ivanchenko has overall responsibility as Data Protection Officer for ensuring that the organization meets its obligations under data protection law.