Privacy Notice
This version is from 27 September 2024
Welcome to FinHub's Privacy Policy
FinHub respects your privacy and is committed to protecting your personal information. This privacy statement explains how we handle your personal data when you visit our website (regardless of where you come from) and explains your privacy rights and the law.
1. About Us
Purpose of this Privacy Policy
This privacy statement describes how FinHub operates through your use of this website, including any data you may provide through this website when signing up for newsletters, mailing lists, private dashboards, etc. It is intended to provide information about how personal data is collected and processed.
This privacy notice aims to give you information on how FinHub collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, mailing list, private dashboard, purchase a service, or take part in a conversation.
This website is not intended for children, and we do not knowingly collect data relating to children.
Read this privacy notice together with any other privacy or fair processing notices we may provide on the particular occasion when we collect or process your personal information, so that you are fully aware of how and why we use such data. This privacy notice supplements other notices and is not intended to override them.
If you fill out any form on our website, you must read and agree with this Privacy Policy. If you do not agree with this Privacy Policy, you should stop using our website immediately.
Controller
FinHub is the controller and responsible for your personal data (collectively referred to in this Privacy Notice also as "we", "us" or "our"). FinHub is a brand name under which different companies operate, as set out in the table below.
We have appointed a Data Protection Officer who is responsible for overseeing questions related to this privacy statement. If you have any questions about this Privacy Policy, including requests to exercise your legal rights, please contact our Data Protection Officer using the details provided below.
Contact Details of Data Controller
| Contracting party | Address | Region |
|---|---|---|
| FINHUB EAD (UIC 206306842) | 16 Usta Kolyu Ficheto str., Western industrial zone, 9000 Varna, Bulgaria | Albania, Bosnia and Herzegovina, Bulgaria, Croatia, Cyprus, Czech Republic, Estonia, Greece, Hungary, Latvia, Lithuania, Montenegro, Poland, Republic of Moldova, Romania, Serbia, Slovakia, Slovenia, North Macedonia, Ukraine |
| FINHUB D-A-CH GmbH (Frankfurt HRB 122210; Mannheim HRB 731980) | Zeil 109, 60313 Frankfurt am Main, Germany | Andorra, Austria, Belgium, France, Germany, Italy, Liechtenstein, Luxembourg, Malta, Monaco, Netherlands, Portugal, San Marino, Spain, Switzerland |
| FINHUB USA LLC (UIC 4960956) | 16192 Coastal Highway, Lewes, Delaware 19958, United States | Antigua and Barbuda, Argentina, Bahamas, Barbados, Belize, Bolivia, Brazil, Canada, Chile, Colombia, Costa Rica, Cuba, Dominica, Dominican Republic, Ecuador, El Salvador, Grenada, Guatemala, Guyana, Haiti, Honduras, Jamaica, Mexico, Nicaragua, Panama, Paraguay, Peru, Saint Kitts and Nevis, Saint Lucia, Saint Vincent and the Grenadines, Suriname, Trinidad and Tobago, United States of America, Uruguay, Venezuela |
| FINHUB Tech UK Ltd. (UIC 12968265) | The Innovation Centre, Boundary Road, Colchester, Essex, England, CO4 3ZQ | Denmark, Finland, Iceland, Ireland, Norway, Sweden, United Kingdom |
| FINHUB Middle East and Africa Teknoloji Ticaret Anonim Sirketi (Register No. 283063-) | Güzeletpe Mah. Çanakci Sk. No:2 İç Kapı/Door No:4, Üsküdar, Turkey | Algeria, Angola, Armenia, Azerbaijan, Bahrain, Benin, Botswana, Burkina Faso, Burundi, Cabo Verde, Cameroon, Central African Republic, Chad, Comoros, Congo, Côte d'Ivoire, DR Congo, Djibouti, Egypt, Equatorial Guinea, Eritrea, Eswatini, Ethiopia, Gabon, Gambia, Georgia, Ghana, Guinea, Guinea-Bissau, Iraq, Israel, Jordan, Kenya, Kuwait, Lebanon, Lesotho, Liberia, Libya, Madagascar, Malawi, Mali, Mauritania, Mauritius, Morocco, Mozambique, Namibia, Niger, Nigeria, Oman, Qatar, Rwanda, Sao Tome and Principe, Saudi Arabia, Senegal, Seychelles, Sierra Leone, Somalia, South Africa, South Sudan, Sudan, Syria, Togo, Tunisia, Türkiye, Uganda, Tanzania, Yemen, Zambia, Zimbabwe, UAE |
| FINHUB APAC PTE. Ltd. (UEN 202339230H) | 160 Robinson Road #14-04, Singapore (068914) | Afghanistan, Australia, Bangladesh, Bhutan, Brunei, Cambodia, China, Cook Islands, Fiji, India, Indonesia, Japan, Kazakhstan, Kiribati, Kyrgyzstan, Laos, Malaysia, Maldives, Marshall Islands, Micronesia, Mongolia, Nauru, Nepal, New Zealand, Niue, Pakistan, Palau, Papua New Guinea, Philippines, South Korea, Samoa, Singapore, Solomon Islands, Sri Lanka, Tajikistan, Thailand, Timor-Leste, Tonga, Turkmenistan, Tuvalu, Uzbekistan, Vanuatu, Vietnam |
Email address: dpo@finhub.cloud
You have the right to make a complaint at any time to the Commission for Personal Data Protection in your country of residence. We would, however, appreciate the chance to deal with your concerns before you approach the Commission for Personal Data Protection, so please contact us in the first instance.
Changes to the Privacy Notice and Your Duty to Inform Us of Changes
It is important that the personal data we hold about you is accurate and up to date. Please let us know if your personal information changes during your relationship with us.
Third-Party Links
This website may contain links to websites, plug-ins, and applications of third parties. Clicking on those links or enabling those connections may allow third parties to collect or share information about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the privacy statement of every website you visit.
2. Data We Collect About You
Personal data or personal information is any information relating to an identifiable individual. It does not include data that has been anonymised.
We may collect, use, store, and transfer various types of personal information about you, summarised as follows:
- Identity Data includes first name, last name, or legal entity name.
- Contact Data includes email address and telephone numbers.
- Technical Data includes IP address, language, browser type and version, time zone setting and location.
- Usage Data includes information about how you use our website, blog, and services, and the website from which you visited us.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences, information about your business, website domain, address, position, and social data you set (avatar image, social network connection).
We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law, as it does not directly or indirectly reveal your identity. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine Aggregated Data with your personal data so that it can identify you, we treat the combined data as personal data in accordance with this privacy notice.
We do not collect any Special Categories of Personal Data about you (race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, health, genetic or biometric data). Nor do we collect information about criminal convictions or offences.
If You Fail to Provide Personal Data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a service you have with us, and we will notify you if this is the case.
3. How is Your Personal Data Collected?
We use different methods to collect data from and about you, including through:
Direct interactions
You may give us your Identity and Contact data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes personal data you provide when you:
- Fill in a form to learn more about our blog or services
- Subscribe to our service or blog newsletters
- Request marketing to be sent to you
Automated technologies or interactions
As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns. We collect this personal data using cookies, server logs, and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.
Analytics & marketing technologies
- Remarketing — FinHub and our advertising partners (Google) use cookie information to serve relevant and optimised ads to past visitors.
- Google Analytics Demographics and Interest Reporting — FinHub uses data from Google's interest-based advertising or third-party audience data (age, gender, interests) with Google Analytics to inform our marketing strategy.
- Opt-out for Google Analytics for Display Advertising via Google's Ad Settings page.
- Opt-out via the Google Analytics Browser Add-On.
- We also use advertising partners to collect cookie-based information to assist with better targeting of our advertising.
- For general information on cookies, including how to decline and remove them, visit aboutcookies.org.
4. How We Use Your Personal Data
We will only use your personal data when the law allows us to. Most commonly, we use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you.
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- Where we need to comply with a legal or regulatory obligation.
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us at dpo@finhub.cloud.
If you share with us personal data of a third party, you confirm that such third party gave you consent to the collection and processing of their data by us. We will take the same measures and procedures to ensure the safety of such information as we do with your personal data.
Purposes for which we will use your personal data
| Purpose / activity | Type of data | Lawful basis |
|---|---|---|
| To register you as a new customer. | Identity, Contact, Marketing and communications. | Performance of a contract with you. |
| To manage our relationship with you. | Identity, Contact, Profile, Marketing and communications. | Performance of a contract with you; compliance with a legal obligation; legitimate interests (keeping records updated, studying how customers use our blog/services). |
| To enable you to subscribe to our newsletters. | Identity, Contact, Profile, Usage, Marketing and communications. | Your legitimate interests; our legitimate interests (developing and growing our business). |
| To administer and protect our business and this website (troubleshooting, data analysis, testing, system maintenance, support, reporting, hosting). | Identity, Contact, Technical. | Legitimate interests (running our business, IT services, network security, fraud prevention, group restructuring); compliance with a legal obligation. |
| To deliver relevant website content and advertisements, and measure advertising effectiveness. | Identity, Contact, Profile, Usage, Marketing and communications, Technical. | Legitimate interests (studying how customers use our services, developing our business, informing our marketing strategy). |
| To use data analytics to improve our website, services, marketing, and customer relationships. | Technical, Usage. | Legitimate interests (defining customer types, keeping our website relevant, developing our business, informing our marketing strategy). |
| To make suggestions and recommendations to you about services that may interest you. | Identity, Contact, Technical, Usage, Profile. | Legitimate interests (developing our services and growing our business). |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing services related to establishing companies and developing businesses.
Promotional offers from us
We may use your Identity, Contact, Technical, Usage, and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information, purchased goods or services, entered into a conversation on our blog, or subscribed to our newsletter.
Opting out
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message, or by contacting us. Opting out does not apply to personal data provided as a result of a service purchase, warranty registration, service experience, or other transactions.
Cookies
You can set your browser to refuse all or some cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, some parts of this website may become inaccessible or not function properly. See section 9 below for more information.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason compatible with the original purpose. If you wish to understand how the processing for a new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of Your Personal Data
We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.
Internal Third Parties: companies inside our Group.
External Third Parties: Google, Owox, Facebook, Getresponse, CRM systems, and other third parties to whom we may sell, transfer, or merge parts of our business or assets. If a change happens to our business, the new owners may use your personal data in the same way as set out in this privacy notice.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow third-party service providers to use your personal data for their own purposes, and only permit them to process it for specified purposes in accordance with our instructions.
6. Data Security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Usually, we keep your data for 5 (five) years.
To determine the appropriate retention period, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.
By law, we must keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers, for tax purposes. In some circumstances you can ask us to delete your data — see "Request erasure" below.
In some circumstances we may anonymise your personal data (so it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
8. Your Legal Rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
Request access to your personal data
Commonly known as a "data subject access request" — this enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of your personal data
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase it to comply with local law. We may not always be able to comply for specific legal reasons, which we will notify to you if applicable.
Object to processing of your personal data
Where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation that makes you want to object on this ground, including for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds that override your rights and freedoms.
Request restriction of processing
This enables you to ask us to suspend the processing of your personal data, for example: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it, because you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Withdraw consent
At any time, where we are relying on consent to process your personal data. This will not affect the lawfulness of processing carried out before you withdraw consent. If you withdraw consent, we may not be able to provide our website, blog, or services to you — we will advise you if this is the case.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any other rights). However, we may charge a reasonable fee if your request is clearly repetitive or excessive, or we may refuse to comply with the request in these circumstances.
What we may need from you
We may need to request specific information from you to confirm your identity and ensure your right to access your personal data (or to exercise any other rights). This is a security measure to ensure personal data is not disclosed to a person who has no right to receive it. We may also contact you for further information to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take longer if your request is particularly complex or you have made a number of requests — in which case we will notify you and keep you updated.
9. Cookies
Our website uses cookies to distinguish you from other users. This helps us provide you with a good experience when you browse our website and also allows us to improve it.
A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer's hard drive.
Our website may place and access certain first-party cookies on your device — these are placed directly by us and used only by us, to facilitate and improve your experience and to provide and improve our services. You may also receive third-party cookies, placed by websites, services, and/or parties other than us.
We do not place cookies before you give your consent, with the exception of technical cookies which are "strictly necessary" for the functioning of our website.
10. Glossary
Legitimate Interest
Means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you by contacting us.
Performance of Contract
Means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Comply with a Legal or Regulatory Obligation
Means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.