Privacy & Cookies Policy

Updated on 1st December 2018

This Privacy & Cookies policy ("Privacy Policy") together with our Terms of Service (which can be found at https) ("Terms of Service") sets out the basis on which any Personal Information we - Quppy Europe OÜ an Estonian company with the address at Harju maakond, Tallinn, Kesklinna linnaosa, Tornimae tn. 7-169, 10117, Estonia (hereafter “Quppy”) collect from you ("you", "your", or "customer"), or that you provide to us, will be processed by us.

By "Personal Information", we mean any information which, either alone or in combination with other data, enables you to be directly or indirectly identified, for example your name, email address, username, contact details or any unique identifier such as an IP address, device ID or other online identifier.

This privacy policy has been compiled to better serve those who are concerned with how their personal information is being used. Please read the following carefully to understand what data we collect, how that data is used and the ways it can be shared by us. If you do not wish for your Personal Information to be used in the ways described within this Privacy Policy then you should not access or use the Site or use any of the services, functions, or features offered from time to time on our web site and/or application ("Services").

If you have any questions about your personal information or this privacy policy, please direct your questions to support@quppy.io

DATA COLLECTED

Personal data is data that can be used to identify you directly or indirectly. Our privacy policy covers all personal data that you voluntarily submit to us and that we are obtaining from our partners.

We may collect the following types of information:

  1. Personal Identification Information: Full name, date of birth, age, nationality, gender, signature, utility bills, photographs, phone number, home address, and/or email.
  2. Formal Identification Information: Tax/ other ID number, passport number, national identity card details, photograph identification cards.
  3. Financial Information: Bank account information, transaction history, trading data, tax identification.
  4. Employment Information: Office location, job title, and/or description of role.
  5. Transaction Information: Information about the transactions you make on our services, such as the name of the recipient, your name, the amount, and/or timestamp.
  6. Online Identifiers: Ge location/tracking details, OS, browser name and version, and/or personal IP addresses.
  7. Usage Data: Survey responses, information provided to our support team, public social networking posts, authentication data, user ID, information provided by analytical and statistic services, click-stream data and other data collected via cookies and similar technologies.

HOW YOUR PERSONAL INFORMATION IS USED

We may collect personal data to provide you with our services. When we require certain personal information from users it is because it is necessary for the specified purposes. Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customised experience. In general, we use personal data to create, develop, operate, deliver, and improve our services, content and advertising, and for loss prevention and anti-fraud purposes. We may use this information in the following ways:

For research and development purposes

We process your personal data to better understand the way you use and interact with Quppys. In addition, we use such information to customise, measure, and improve Quppys’s services and the content and layout of our website and applications, and to develop new services. Without such processing, we cannot ensure your continued enjoyment of our services. Our basis for such processing is based on legitimate interest.

We process this personal information to pursue our legitimate interests as described above.

We will not use your personal data for any other purposes than those described in this policy, without informing you. From time to time we may request your permission to allow us to share your personal data with third parties. You may opt out of having your personal data shared with third parties. If you choose to, so limit the use of your personal data, certain features or Quppys’s services may not be available to you.

To maintain KYC-principles

Providing you services may infer the necessity for us to collect and use your personal identification information, formal identification information, financial information, transaction information, employment information, online identifiers, and/or usage data in certain ways. In addition, we may use third parties to verify your identity by comparing the personal information you provided against third-party databases and public records.

PERSONAL DATA FROM THIRD PARTY PROVIDERS

Quppy primarily collects personal data about you from you. From time to time, we may, however, also collect data about you from third party sources, such as public databases, credit bureaus, ID verification partners, resellers and channel partners, joint marketing partners, and social media platforms.

We obtain information about you from public databases and ID verification partners for purposes of verifying your identity. ID verification partners use a combination of government records and publicly available information about you to verify your identity. Such information includes your name, address, job role, public employment profile, credit history, status on any sanctions lists maintained by public authorities, and other relevant data.

COLLECTION AND USE OF INFORMATION COLLECTED AUTOMATICALLY

We may receive and store certain types of information automatically, such as whenever you interact with our website. This information does not necessarily reveal your identity directly but may include information about the specific device you are using, such as the hardware model, device ID, operating system version, web-browser software (such as Firefox, Safari, or Internet Explorer) and your Internet Protocol (IP) address/MAC address/device identifier.

For example, we may automatically receive and record information on our server logs from your browser, including your IP address; device type and unique device identification numbers, device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL), broad geographic location (e.g. country or city-level location) and other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser. We may also collect information about how your device has interacted with our website, including pages accessed and links clicked. We may use identifiers to recognise you when you arrive at the Site via an external link, such as a link appearing on a third party site.

Your Personal data may be transferred worldwide to our affiliates, and to service providers who support the operation of our business. We may transfer Personal Data which is shared with service providers will be limited to that which is required for providing the service and will be adequately protected.

Cookies

We may use “cookies”. A cookie is a small text file containing a unique identification number that identifies a customer’s browser each time that customer visits a website. The use of cookies is industry standard practice and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available.

If you choose to disable or block our cookies on your computer or other device you will need to do this through your browser. Click on the 'Help' menu on your particular browser to learn how to manage your cookie preferences. Alternatively, you can visit www.aboutcookies.org or www.youronlinechoices.eu for comprehensive information on how to manage cookies.

We set cookies (first party cookies) on web pages, however, where we require additional information, we may also allow other companies to host cookies on our website (third party cookies). These companies have been carefully selected by us and are required to meet contractual obligations they have with us.

The cookies on our wesite may be from any of the following categories:

Strictly Necessary cookies - these are used for technical reasons and are necessary to enable the our website to operate efficiently so that you can navigate the Site with ease and use specific features. These include, for example, cookies that help us to debug any errors. If these cookies are blocked or disabled, some of the Site may not operate effectively.

Functionality cookies - these are used to improve the functionality of the Site and make it easier to use. They help us to identify you as a repeat customer of the Site and help us remember your preferences (for example, your choice of language or region).

Analytical - these record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make the Site and the advertising displayed on it (if any) more relevant to your interests. We may also share this information with third parties for this purpose.

We may share information that we collect through cookies, in aggregated form, with carefully selected third parties for the purposes set out above, unless you disable or block cookies.

Our websiteSite’s systems and data are periodically reviewed to ensure that you are getting a quality service and that leading security features are in place. We have put in place procedures to deal with any actual or suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

OUR SHARING OF PERSONAL DATA WITH OTHER PARTIES

We take care to allow your personal data to be accessed only by those persons at Quppys who really need to – and only when it is necessary – in order for them to perform their tasks and duties. Furthermore, we only share your data with third parties who have a legitimate purpose for accessing it and with the appropriate legal basis. Quppys will never sell or rent out your personal information. We will only share your information in the following circumstances:

  1. We share your information with financial institutions with which we partner to process payments.
  2. We may share your information with law enforcement, officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of our user agreement or any other applicable policies.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We understand how important your privacy is, which is why Quppys maintains (and requires its service providers to maintain) appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you entrust to us.

We may store and process all or part of your personal and transactional information, including certain payment information, such as your encrypted bank account and/or routing numbers, in the United States and elsewhere in the world where our facilities or our service providers are located. We protect your personal information by maintaining physical, electronic, and procedural safeguards in compliance with the applicable laws and regulations.

YOUR RIGHTS

When we process your personal data, you have a number of rights under the General Data Protection Regulation.

In general, you have a right of access to Quppys’s processing of your data. This means that you can ask us for information about our processing of your data and for a copy of the data. You also have the right to have a copy of your personal data transmitted to another enterprise, where technically feasible.

In addition, you have a right to object to our processing of your data. If the situation should occur, we will decide whether we are able to meet your objection. If that is the case, we will no longer process the data in question.

Finally, you have a right to have erased, blocked or rectified any data that turn out to be inaccurate or misleading or in a similar way have been processed in conflict with legislation.

COMPLAINTS

Complaints about our processing of your personal data, can be filed at The Estonian Data Protection Agency. Complaints about our processing of your personal data, can be filed at The Estonian Data Protection Agency.

CONTACT AND NEWSLETTERS

If you have given your consent, Quppy may contact you via the address, e-mail and / or phone number you provide on your account for marketing, surveys, news and/or similar initiatives.

ENCRYPTION OF DATA TRAFFIC

Quppy is committed to handling your Customer Information with the highest standards of information security. When your information is transferred over the internet, SSL encryption is used to ensure your sensitive data is not accessible to anyone on the internet. The data that is communicated back and forth between Quppys and your computer is encrypted with a 256-bit SSL certificate. This means no one can intercept the data stream between Quppys and your device.

GOVERNING LAWS

Information collected through Quppys will be treated in accordance with current Estonian legislation and the EEA Data Protection Law.