This Privacy Policy governs how Stvble Digital (referred to as "we,"
"us," or "our") collects, uses, processes, stores, and shares
information obtained from users of our website,
https://stvbledigital.com
("Website"), to provide the services available through the Website (referred
to as "Services"). This Privacy Policy complies with the EU General Data
Protection Regulation (GDPR), the ePrivacy Directive, and The Data Protection
Act, aligning with other relevant legal regulations, as we operate within
the European Economic Area (EEA). We highly value the privacy of all Website
users and ensure that any Personal Data we collect is treated confidentially
and in accordance with applicable laws and regulations. This Privacy Policy
covers the Website, Services, and products offered by Stvble Digital, whether
accessed through the Website, mobile application, or through correspondence
with us (such as via email or messaging forms on the Website). By using the
Website, our Services, and products, as well as by contacting us, you provide
your consent to abide by the terms of this Privacy Policy. When creating
an Account on the Platform and clicking the confirm-checkbox, you explicitly
consent to the terms of this Privacy Policy and all data practices described
within, including the processing, storage, and usage of your Personal Data,
as outlined in the User Agreement. If you do not agree with this Privacy
Policy, it is advisable to refrain from using our Website, mobile application,
Services, or opening an Account. Note that this Privacy Policy is an integral
part of our Terms of Service. For any inquiries or requests related to this
Privacy Policy or your Personal Data, please contact our Data Protection
Officer at
[email protected].
The General Data Protection Regulation (GDPR) is a comprehensive EU law
governing privacy and data protection. It introduces more detailed
privacy safeguards within an organization's systems, requires nuanced
data protection agreements, and mandates consumer-friendly and
comprehensive disclosures regarding an organization's privacy and data
protection practices. The GDPR is applicable to the processing of
Personal Data, either fully or partially through automated means, as
well as the processing of Personal Data by non-automated means, provided
that the data either belongs to a filing system or is intended to be
part of one. In general, GDPR requirements are applicable to all
companies, institutions, and organizations involved in the processing of
Personal Data.
The General Data Protection Regulation (GDPR) is a legal framework
governing the processing of Personal Data by organizations. "Personal
Data" is broadly defined as any information related to an identified or
identifiable individual, encompassing not only basic identifiers like
names and email addresses but also sensitive categories such as racial
or ethnic origin, political opinions, and health data. "Processing"
refers to all operations on Personal Data, whether manual or automated,
including collection, storage, use, disclosure, and deletion. The GDPR
establishes strict privacy safeguards and obligations for entities
handling Personal Data, emphasizing the protection of individuals'
privacy and data rights.
The GDPR is a significant privacy and data protection law that applies
to organizations globally, not just those located within the European
Union (EU). This means that Stvble Digital, in accordance with GDPR
requirements, may process personal data from individuals around the
world, including those in the EU, who use our services. We take data
protection seriously and are committed to ensuring that your personal
data is handled with the utmost care and in compliance with all
applicable laws and regulations. Under the GDPR, personal data is
broadly defined as any information related to an identified or
identifiable individual. It includes various types of information, from
basic details like names and email addresses to more sensitive data such
as health information or even IP addresses. Additionally, certain
categories of personal data, such as information about one's race,
religion, health, or criminal record, receive enhanced protection. The
GDPR governs how we process your personal data and imposes strict
obligations to protect your privacy. By using our website and services,
you consent to our compliance with the GDPR and our commitment to
safeguarding your personal information. We value your trust and
encourage you to review our full Privacy Policy for a comprehensive
understanding of how we collect, use, and protect your data. If you have
any questions or requests regarding your personal data, please don't
hesitate to contact our Data Protection Officer at
[email protected]. Your privacy matters to us, and we are here to assist you with any
privacy-related concerns you may have.
We aim to maintain complete transparency regarding the handling of your
Personal Data. As delineated in this Privacy Policy, our collection,
storage, and utilization of your Personal Data are governed by specific
purposes. We have meticulously outlined the categories of Personal Data
we may gather and provided comprehensive explanations for the reasons
and methodologies behind their use. Furthermore, in the course of
providing our services, we may enlist the assistance of third-party
software and tools offered by independent service providers, herein
referred to as "Service Providers." These Service Providers may also
collect Personal Data from our Users. The protocols governing the
acquisition, processing, storage, and utilization of this Personal Data
are stipulated in the respective Privacy Policies of these Service
Providers. In our commitment to ensuring complete transparency, we have
furnished links to the privacy policies of select Service Providers for
your review:
Please note that this compilation of Service Providers is not exhaustive
and remains subject to potential changes and additions. Regardless of
any modifications, we encourage Users to readily access and review the
privacy policies of Service Providers that collaborate with Stvble
Digital on their respective official websites.
Personal Data Provided During Registration: When you register with us, you may provide the following personal information:
your contact details, including your name, address, email address, and telephone
number(s); and your identification details, such as your date of birth, gender,
and residential address.
Know Your Customer (KYC) Data:
We may collect KYC information from you, third parties, or publicly available
sources. This data may include details from your passport or another government-issued
identity document, such as document numbers and expiration dates, as well
as your photograph. Additionally, we may gather documents confirming the
source of your funds and the results of KYC or Politically Exposed Person
(PEP) checks, including information obtained from our suppliers.
Account-Related Personal Data:
As part of your account setup, you may provide us with certain personal information,
including your chosen password and your preferences related to your account
and marketing.
Data Related to Service Usage:
We collect data pertaining to your use of our Services, including details
of your orders, instructions, and transactions conducted through your account(s).
This includes information about transfers to and from third-party banks or
financial institutions, payment card details, transaction amounts, origins
or beneficiaries, and timestamps. We may also collect data about the digital
device you use to access our Services, such as device type, operating system,
screen resolution, unique device identifiers, and mobile network system.
This information may also encompass your IP address, login times, and communication
with us through email, telephone, messaging, online chats, social media,
or other channels. We track whether you have interacted with links in electronic
communications from us and gather data on your responses to our surveys.
Third-Party Data:
To facilitate your registration as a customer or the provision of our Services,
we may collect personal information from third parties. This can include
data related to payments to or from your accounts, which may be provided
by payment processing services, banks, card schemes, and other financial
service providers. We may also obtain data from credit reference agencies
or fraud prevention agencies.
Data Collected Through Website Usage:
When you use our website, whether or not you have registered for our Services,
we automatically collect certain data. This includes information about your
device, such as its operating system, unique identifiers, and mobile network
details. We also capture hardware and browser settings, as well as details
about your visits to our website, including the pages you view, visit duration,
interactions with the page (e.g., clicks and mouse-overs), methods of navigating
away from our website, and search engine terms you employ. Your IP address
is also logged.
Data from Organizational Representatives:
We may collect personal data from individuals representing organizations,
such as our corporate customers and suppliers. This data typically includes
names, roles, and contact information for these individuals, along with any
additional personal data exchanged in correspondence with them.
We collect and process various types of Personal Data to ensure the
provision, functionality, security, and improvement of our Services, as
well as to meet regulatory requirements. Here's how we utilize different
categories of Personal Data:
Personal Data Provided During Registration:
When you register with us, we use this information to process your registration
request, onboard you as a customer, provide our products and Services, manage
and administer your account, and communicate with you regarding your account
and our Services. Additionally, we may use this data to send you personalized
offers related to our Services and products.
Know Your Customer (KYC) Data:
KYC data is crucial for regulatory compliance. We use this data to conduct
regulatory checks, fulfill obligations to our regulators, verify the authenticity
of our customers, and prevent and detect fraud, money laundering, and other
criminal activities.
Account-Related Personal Data:
Personal Data provided as part of your account with us is primarily used
for managing and administering your account and communicating with you regarding
it and our Services.
Data Related to Service Usage:
Information related to your use of our Services helps us manage and improve
our systems. We may use this data to verify your location and device to prevent
fraud, enhance our Services based on user behaviors and technical capabilities,
address issues or concerns, and monitor customer communications for quality
and training purposes.
Data Collected from Third Parties:
Personal Data obtained from third parties is used to manage our Services
and systems, as well as to assist in preventing and detecting fraud.
Data from Website Usage:
Information collected through your use of our website is valuable for various
purposes. It aids in developing new Services, identifying website issues,
monitoring website usage patterns, and conducting statistical analysis and
research to better understand customer demographics and preferences.
Data from Individuals Representing Organizations:
Personal Data gathered from individuals representing organizations is utilized
to provide Services and products, establish business relationships and collaborations,
deliver marketing communications, improve existing Services, and obtain necessary
services for our business operations.
Our use of Personal Data is carried out in accordance with applicable
data protection regulations and is designed to enhance the quality of
our Services, protect against fraud, and improve user experiences.
As a user, you have several rights concerning the management of your
Personal Data, including the following:
Right to be informed:
You have the right to be informed about the collection and use of your Personal
Data. This includes knowing who is collecting and processing your data, the
purposes for processing, how long your data will be retained, and with whom
it may be shared.
Right to Access:
You can request confirmation regarding whether your Personal Data are being
processed, along with details about the purposes of processing, the categories
of data collected, and the recipients with whom your data may be shared.
Right to Rectification:
If your Personal Data are inaccurate or incomplete, you have the right to
request their rectification or completion.
Right to Erasure ("Right to be Forgotten"):
You have the right to request the deletion of your Personal Data when they
are no longer necessary for the purposes for which they were collected, or
if there is no other legal basis for their processing.
Right to Restriction of Processing:
You can ask us to limit the further processing of your Personal Data, allowing
such processing only with your separate consent in each case.
Right to Data Portability:
You have the right to receive your Personal Data in a structured, commonly
used, and machine-readable format and may transmit this data to another controller
where technically feasible.
Right to Object:
You can object to the processing of your Personal Data at any time if there
are no legitimate grounds for processing that outweigh your interests, rights,
and freedoms or if it is for the establishment, exercise, or defense of legal
claims.
Right to Withdraw Consent:
You have the right to withdraw your consent for the processing of your Personal
Data at any time. You can request us to cease accessing, storing, using,
or otherwise processing your data if you believe we lack the proper rights
to do so.
Right to Non-Discrimination:
We will not discriminate against you for exercising your rights under applicable
data protection laws.
To exercise any of these rights or seek further information, please
contact our Data Protection Officer at
[email protected] . We are committed to addressing your requests and inquiries promptly and
in accordance with applicable data protection regulations.
Kindly be advised that in the event you have provided explicit consent
for receiving marketing communications, you retain the right to withdraw
such consent at any juncture. Additionally, the option to unsubscribe
from our marketing communications is at your disposal. It is important
to note that periodic contact may be necessary for matters pertaining to
operational issues or compliance with the terms of our agreement. Please
be aware that these communications will not constitute marketing
endeavors; rather, they will be conducted under the umbrella of
legitimate interests, serving the purpose of addressing operational
requirements or fulfilling our contractual obligations to you.
We are obligated to collect specific categories of Personal Data in
order to fulfill our legal obligations related to anti-fraud, Anti-Money
Laundering/Countering Financing of Terrorism/Know Your Customer
requirements. Failure to provide this necessary Personal Data would
impede our ability to provide you with our Services. Furthermore, your
Personal Data may be processed when reasonably requested by a law
enforcement or regulatory authority, body, or agency, or in defense of a
legal claim. We will retain this Personal Data until such time as it is
no longer relevant to an ongoing investigation or dispute, ensuring its
storage until these matters are conclusively resolved.
We do not collect or store any information about children under 18.
Minors and children should not use our Website and Services. By using
our Website and Services, you represent that you have the legal capacity
to enter into a binding agreement.
We do not process any sensitive personal information, such as racial or
ethnic origin, political opinions, religious or philosophical beliefs,
or trade union membership, genetic data, biometric data, data concerning
health or data concerning a natural person's sex life or sexual
orientation.
We have implemented a comprehensive array of physical, technical, and
administrative security measures to uphold the confidentiality and
safeguard your Personal Data against potential risks such as loss,
theft, unauthorized access, misuse, alteration, destruction, and other
illicit activities by third parties. These security measures encompass
data encryption during transmission and storage, diversification of data
storage, rigorous physical access controls for both premises and files,
anonymization technology, diversification of data and assets, stringent
access restrictions limited to a select few individuals, employment of
multi-sign access tools, and adherence to confidentiality commitments.
Furthermore, we conduct regular reviews of our information security
policies and practices, making necessary enhancements to ensure ongoing
effectiveness and protection.
We do not engage in the sale, trade, or rental of our Users' Personal
Data to any third parties. However, in exceptional cases, we may
transmit specific Personal Data of Users, such as contact and
identification information, to third-party financial institutions. This
transfer is executed in accordance with the regulations and policies of
the respective financial institutions, primarily for User identification
and the provision of our Services. Users explicitly acknowledge and
grant consent for the transfer of their Personal Data to third parties
responsible for conducting KYC checks and fraud database assessments.
These third parties have undergone a thorough evaluation by us to ensure
compliance with personal data processing laws and our privacy policy. It
should be noted that for the purpose of delivering certain Services
related to Fiat money, we may share the "Know Your Customer" (KYC)
Personal Data and other pertinent data of our Users with third-party
financial institutions, as previously defined. By using our Services,
you explicitly provide us with consent for the transfer of such Know
Your Customer (KYC) Personal Data and other required data to these third
parties.
We retain your Personal Data solely for the durations necessary to
fulfil the various purposes outlined in this Privacy Policy, unless
longer retention periods are mandated or permissible by applicable law.
To ensure compliance with our legal and regulatory obligations and in
alignment with industry standards for data retention, you provide us
with consent and authorization to maintain records of such information
for the duration of your Account and an additional 5 (five) years
following the closure of your Account. Please note that we retain your
Personal Data in a depersonalized or aggregated format that does not
allow for personal identification. In cases where it aligns with our
legitimate business interests and is not prohibited by law, we may store
your personal data for durations exceeding legal requirements.
We may share certain Personal Data with our trusted business partners
who provide essential services such as cloud hosting, insurance,
analytics, research, and other functions that contribute to the delivery
of our Services to users. However, we strictly limit the amount of
Personal Data shared with these third parties to the minimum required
for the provision of their respective services. This information is
shared solely for the purpose of delivering Services to users and
enhancing the quality of these Services and related communications. We
do not share such information with third parties for their marketing
activities.
In compliance with the law, court orders, legal proceedings, or upon
receiving requests from government authorities, both within and outside
your country of residence, we may disclose your Personal Data.
Additionally, we may disclose your Personal Data if we believe that such
disclosure is essential or appropriate for reasons related to national
security, law enforcement, or other matters of significant public
concern. Furthermore, we reserve the right to disclose your Personal
Data if we determine that such disclosure is necessary to enforce Stvble
Digital's User Agreement or to safeguard our operations and the
interests of our stakeholders.
We may transfer and store the Personal Data we collect in countries
outside the one in which the data was originally provided, including
countries outside the European Economic Area (EEA), the United Kingdom,
and Switzerland. It's important to note that these countries may not
have the same data protection laws as the one in which you initially
provided your data. However, when we transfer your Personal Data to
other countries, we will ensure the protection of your data as outlined
in this Privacy Policy, and we will adhere to applicable legal
requirements that provide sufficient safeguards for data transfers to
countries outside the EEA, the United Kingdom, and Switzerland. If you
are located in the EEA, the United Kingdom, or Switzerland, we will only
transfer your Personal Data if one of the following conditions is met:
- The country receiving the Personal Data has received an adequacy
decision from the European Commission.
- We have implemented appropriate safeguards for the data transfer,
such as entering into EU standard contractual clauses with the
recipient and imposing additional safeguards, or the recipient has
established binding corporate rules that have been approved by a
supervisory authority in the EU, UK, or Switzerland.
We retain the right to make amendments to this Privacy Policy at our
discretion and without prior notice. These changes will become effective
as soon as the updated Policy is published on our website at
https://stvbledigital.com/privacy-policy. We recommend that you periodically review the Privacy Policy,
especially when revisions are made. By continuing to use our Website and
Services after any modifications have been posted, you signify your
acceptance of the revised Privacy Policy. We always provide the date of
the last update for your reference.