All terms not otherwise defined herein, shall have the meaning ascribed to them in the Terms and Conditions. The Services are developed, owned and operated by Bruc Bond UAB and any of its group of companies (together “Company”, "we""). This Policy specifies what information we collect and how we collect the information, how we use the collected information, and how we share the information and protect it. Contact Us details are provided at the end of the Policy, for feedback or any privacy enquiries you may have.
“Personal Information” means information that we directly associate with a specific person, which may include without limitations, name, address, telephone number, email address, payment information, IP address etc.
Please note that this Policy is governed by the Lithuanian laws.
Please read the following carefully to understand our practices regarding your Personal Information and how we will treat it.
2. SCOPE AND CONSENT
By accessing, applying, or using our Services or by visiting the Website, you accept and consent to the practices describe in this Policy. This Policy (together with our terms and conditions and any other documents referred to in it) sets out the basis on which we collect and use personal information. It applies, without limitation, to:
- Your use of the Website and Services, whether by using your computer, your mobile device or any other device;
- Email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and the Company.
Learn more to understand how we will treat your Personal Information:
If you are not satisfied with any aspect of this Policy, please do not continue to use the Services.
Contact Us details are provided at the end of the Policy, for feedback or any privacy enquiries you may have.
Please note that we provide certain Services to both individual consumers and businesses and this Policy applies to both and should be read and interpreted accordingly.
3. THE INFORMATION WE COLLECT FROM YOU
We may collect, receive and process any information, including your Personal Information, data and other details submitted, shared or exchanged in connection with the Services. You may provide some of this information to us, for example by filling in forms, or by corresponding with by us phone, e-mail, web chat or otherwise. We may collect some of it through automatic means, for example by using cookies when you visit our Website. We may also obtain data about you from third parties.
Learn more to understand which information we collect:
When underwriting new merchants, the Company routinely collects ‘Know Your Customer’ and
Anti-Money Laundering data from merchants. Merchant's data subjects' details may be
crosschecked against lists and search libraries to verify that such details are correct and not
subject to blacklisting or service prohibitions.
Information you provide us:
- When you register to our Website and Services you will be requested to provide Personal Information such as: your full name, e-mail address, phone number, address, gender, date of birth, contact details, location, nationality and country of residence, and any other contact information you choose to provide on or via the Services or in any other communications with the Company.
- When you use the Services you will be requested to provide additional Personal Information and KYC information such as: your identification number, photograph, a copy of an identification card (e.g. ID card, driving license and/or passport), various business and financial information, including bank account details and any information of your transactions and financial activity with other payment processors, copies of utility bills, etc., and any proof of your identity as we may request. The legal regulation framework that applies on the Services may change from time to time, and accordingly we may require some additional information from you in order to align with such new regulation.
- Any other information you may provide regarding your personal situation. This information may include any Personal Information and/or identification information or other personally sensitive data.
- Information relating to any transaction processed and/or items purchased via the Services, including the location of the recipient or purchase, the value, the time and any feedback that is given in relation to such transaction;
- Information you may provide when you communicate with us by phone, e-mail, SMS, a website or portal, or once you enter information on our Website, submit survey responses or any other electronic means. We may monitor and record phone calls, e-mails, Skype chats, or other communications between you and our Customer Service representatives or other Company's representatives. When visiting our offices, access control systems and other monitoring systems may be in operation.
- Any other information that you or your customers provide us.
Information we get from your use of our Website and Services:
- Information on your requested transactions provided through your use of the Services.
Information we collect from third parties
In order to fulfill our legal obligations to prevent fraud and money laundering and for risk assessment purposes, we will obtain information about you from our trusted service providers when you request to use our Services and at any time when we feel it is necessary to prevent fraud, to minimize financial risks or to prevent other risks, for instance - your financial history information.
4. INFORMATION WE COLLECT AUTOMATICALLY
We automatically collect Personal Information associated with your use of the Website or Services when you access and use the Services, or by using third party services.
- We may use third party services, such as Google Analytics, to collect and process such data in order to analyze the traffic to the Website.
5. LEGAL BASIS FOR PROCESSING
We will only process your Personal Information on the basis of:
- Your consent (including where consent is requested ‘as a condition of business’), or
- Where appropriate and necessary to perform our obligations towards you;
- Where we have a legitimate interest to process data, subject to such processing not overriding your own rights and freedoms in objecting to such processing;
- Where required by law or similar rule (for example, money laundering or other anti-financial crime checks).
6. HOW WE USE THE INFORMATION
We use your Personal Information to provide and improve our Services, contact you about your account and our Services, for customer service purposes, and to detect, prevent, mitigate and investigate fraudulent or illegal activities. We also use this information for sending promotional communications with respect to Services that may be of interest to you based on Information in our possession.
Learn more about the use of your Personal Information by us:
We may use information collected about you, including Personal Information, in any one or more of the following ways: (i) to provide you with the requested Services and transactions, including fulfilling Company's obligations to you or to financial or other institutions in connection with the Services we provide to you (and/or your business), (ii) for financial and identity checks, fraud prevention checks, anti-money laundering and credit checks, including examination of your request for Services according to legal regulatory requirements, risk management examination and fraud detection; (iii) to provide reports that include user's Personal Information to Anti Money Laundering Authorities, and to any other competent authority, with accordance to legal requirements; (iv) to record and track details of transactions you carry out in relation to the Services; (v) to improve the quality of the Services and customize your user experience; (vi) for the Company purposes, including among others, use of aggregated transactional information and anonymised information for commercial purposes - service and surveys, statistical research and analysis, and using external companies which gather and analyze statistical information about use of Website and Services and keeping track of your login name, passwords, and pages you have visited on the Services; (vii) for customer service, including answering questions and responding to feedback and complaints; (viii) for sending communications, administrative e-mails, promotional e-mails messages and/or reaching you via social media platforms, with respect to Services that may be of interest to you based on Information in our possession. You may tell us at any time if you do not wish to receive marketing messages from us by contacting us at [email protected] or by choosing to opt out of receiving additional promotional e-mails from Company by clicking on the 'unsubscribe' link in any such e-mail, or by following any instructions Company may include in the message sent to you (the “Opt-out request” or “Request”). Please note that, once we receive your request, it may take an additional period of time for the Opt-Out Request to become effective. Note that, if you opt-out of our promotional communications, Company may still e-mail or communicate with you from time-to-time, if Company needs to provide you with information or for other commercially, non-marketing reasons related to the Services.
Please be informed that no automated decisions or profiling are made in the course of the processing of your Personal Information.
7. DISCLOSING OF INFORMATION TO THIRD PARTIES
We may share your Personal Information with third parties to provide you with access to our Services, with suppliers working on our behalf, where we have your permission, or where we are required or permitted to do so by law. We may also share your Personal Information with third parties to comply with our legal obligations, to prevent any fraudulent or illegal activities related to our Services, to respond to legal process or to protect the rights or property of the Company, our customers or others. We attempt to minimize the amount of personal information we disclose to what is directly relevant and necessary to accomplish the specified purposes.
Learn more about the cases of disclosure of information to third parties:
We will not disclose to third parties the Personal Information gathered about you via the Website and Services, inasmuch as this Information identifies you personally, except in the cases set forth hereinafter:
(a) To collect, hold and manage your Personal Information through Company's trusted vendors (including their sub-contractors) who apply suitable safeguards to protect the privacy and security of your personal data, for example, cloud computing platform and hosting services provider, as reasonable for business purposes, which may be located in a country that does not have the same data protection laws as your jurisdiction;
(b) To bill and collect money owed to us by our clients;
(c) To Credit and Financial Institutions that take part in the processing of the services: including the credit institution where you maintain bank account and any other financial institutions who may process payments;
(d) Risk management. We use trusted third parties to secure transaction processing and to conduct identity verification and prevention checks of fraud or any other illegal activities or otherwise address security or technical issues (for example, World Check by Thomson Reuters for money laundering detection) and of bank transfer transaction, and we send Personal Information to those third parties to process payments;
(e) To communicate with our customers about their account and provide customer support, including by our third party trusted vendors;
(f) To provide information to our authorized representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, security and other requirements;
(g) To share your personal information with any company in the Bruc Bond group of companies or other third party , to provide the company with the services including suppliers working on B+B’s behalf, where it is required or permitted to do so by law;
(h) To prevent crime and reduce risk, if required to do so by law, where appropriate to do so;
(i) To respond to legal process or to protect the rights or property of Bruc Bond UAB, its customers or others;
(j) To perform client identification process through remote identification services;
(k) To provide, support, and improve the Services we offer. This includes, for example, aggregating information of your use of the Services or Website and sharing this information with third parties to improve and support our Services and to make certain features of the Services available to you;
(l) To promote use of our Services. Sharing your contact information with our trusted vendors that assist us in sending e-mails, marketing, advertisements and customer service, including via social media platforms. You can stop receiving our promotional messages by following the unsubscribe instructions included in every email or by contacting us at [email protected].
(m) To satisfy applicable laws and regulations, if and as applicable, including reports to Anti Money Laundering Authorities and to any other competent authority, with accordance to legal requirements, to financial institutions that take part in the processing of the services for compliance purposes, and to comply with a judicial proceeding, court order, or legal process;
(n) To enforce the Terms and Conditions, including investigation of potential violations thereof, and to protect against harm to the rights, property or safety of Company, its users or the public as required or permitted by law;
(o) In the event Company goes through a business transition such as a merger, acquisition of all or a portion of Company's assets, your Personal Information may be among the assets transferred and it will be transferred only subject to restrictions similar to those contained herein or as otherwise be required by applicable laws and regulations
Please note that these third parties may be in other countries where the laws on processing Personal Information may be less stringent than in your country.
Except where permitted as stated, Company does not sell, rent, share or otherwise disclose Personal Information to third parties.
Company may transfer and disclose to third parties or otherwise use non-personal information at its own discretion.
8. STORING YOUR DATA
The Personal Information that we may collect may be transferred to, stored at and processed in a destination outside your territory and/or outside the European Economic Area ("EEA"), where your Personal Information may not be protected by the same standards. We endeavor to take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy. By using the Website and Services, you agree to this transfer, storing or processing.
Learn more to understand the reasons for storing Personal Information outside EEA and/or your territory:
Any Personal Information which we may collect may be transferred to, processed and stored at destinations outside your territory and/or outside of the European Economic Area ("EEA"), where your Personal Information may not be protected by the same standards, for the reasons set out below:
- Where our hosting provider or cloud computing platform is outside your territory or outside the EEA.
- Transfer to our affiliated companies that is needed for providing the Services.
- If necessary for providing the Services.
- Where our anti-fraud agencies, credit reference agencies and other service provider that are based outside your territory or outside the EEA, require access to your data to perform their obligations to us and provide the requested Services to you.
- Where Personal Information is processed by staff operating outside your territory or outside the EEA who work for Israel-based companies named Fintech NV and Bruc Bond UAB R&D branch and Singapore-based Bruc Bond Pte Ltd within the Bruc Bond group (or one of B+B’s suppliers). Such staff may be engaged in, among other things, the fulfilment of orders, the processing of payment details and support services in provision of the Services. Where such staff is acting on behalf of Company, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with applicable law and with this Policy.
In these and similar cases where recipients of your Personal Information are located outside the EEA, we will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Policy, including the use of any adequacy mechanisms required by law to ensure that the transfer is lawful.
9. DATA RETENTION
- We may retain your Personal Information in conformance with applicable laws, usually for 8-10 years, in order to: comply with legal requirements or to protect Company's legal interests, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce the Terms and Conditions and take other actions otherwise permitted by law.
- In addition, Company will retain your Personal Information after your registration to the Services is cancelled, or if your application is declined or abandoned, for as long as permitted under any applicable law, for legal, regulatory, fraud and other financial crime prevention or if applicable law does not provide specific term, for at least 1 (one) year.
10. THIRD PARTY SOFTWARE/SERVICES
11. USE OF "COOKIES"
Learn more on what is a cookie and how you can disable it:
What is a cookie?
Cookies are alphanumeric identifiers that are transferred to and stored in your device through your web browser for record-keeping purposes. Some cookies allow making it easier for you to navigate a website, while others are used to enable a faster log-in process or to allow to track your activities on a website.
When you access the Website, you will be presented with a message bar requesting your consent to set those cookies. By continuing to browse the Website, you are enabling us place cookies on your computer and/or our partners to provide a better experience and service to you.
Cookies generally process your IP-address but they do not save your personal information like e-mail address or phone number.
This Website may place the following type of Cookies:
- Essential cookies: These cookies are necessary to allow you access and move around our Website and use all its features. Without these cookies, you would not be able to access our Website and/or to use certain important features.
- Visitor Cookie: These cookies are part of our security mechanism and are used to identify visitors (visitor representing a specific computer) of the Website,
- Analytics cookies: This Website also uses analytics cookies placed by Google Analytics (including Google Tag Manager) to measure the number of visits and the parts of the website that are the most popular among our Website visitors as well as for benchmarking purposes. This information is used to provide aggregated and statistical information on the use of this Website and is used to improve the contents of this Website to enhance your user experience. To opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout/ (or to other Google link as may be updated from time to time)
- Advertising cookies: These third party cookies, such as Google Adwords, help ensure that our advertisements are as relevant to you as possible. These cookies track and record information (including by Google) regarding your browsing habits and activity, and use this information to enable us to show you relevant/personalised marketing content across the Internet. Using these cookies, our third party vendors may collect personally identifiable information (for instance when information collected by such cookies is associated with your Google Account) and use this to display our targeted advertising to you. For example, some advertising cookies help select advertisements that are based on your interests. You can opt out of Google’s use of the abovementioned cookies by visiting Google’s Ads Settings: https://adssettings.google.com/authenticated (or other Google link as may be updated from time to time).
You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed.
A customer may oppose the registration of cookies in his/her connected terminal by setting his/her Internet browser as follows:
- Select "Edit" then "Preferences" menu
- Click on the "Security" icon
- Select the desired options for cookies
For Mozilla Firefox:
- Select "Tools" then "Options" menu
- Click on the "Privacy" icon
- Select the desired options for cookies
For Microsoft Internet Explorer:
- Select "Tools " then "Internet Options" menu
- Click on the "Privacy" tab
- Select the desired level using the cursor
- Select the "Settings " then "Privacy" menu
- Click on the tab " Content Settings "
- Select the desired options for cookies
For further details, please consult the help menu in your internet browser.
You can choose to delete cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings. You are therefore informed that the opposition to the registration of cookies can make inaccessible all or part of the Website features.
12. THIRD PARTY SERVICES
Certain Services on the Website, such as services related to Facebook, are in fact managed by bodies other than the Company. In these cases, the Services are provided or operated not via the Company computers alone, but rather via the other bodies as stated.
Company is entitled to be assisted by third parties, including advertising companies, for the purpose of presenting advertisements on the Website or on other websites or providing other services. It is possible that these parties use information about your online activity (which does not include identifying personal information), among others in order to provide advertisements for products and services which may interest you.
13. THIRD PARTY LINKS
14. SECURITY PRECAUTIONS TO PROTECT YOUR INFORMATION
We take a great care in implementing and maintaining reasonable and appropriate security procedures consistent with prevailing industry standards to protect the security of the Website, the Services, and our users’ Personal Information from accidental loss and from unauthorised, alteration and disclosure.
While we take reasonable precautions against possible security breaches of the Services, no website or internet transmission is completely secure, and we cannot guarantee (i) that unauthorized access, hacking, data loss, or other breaches shall never occur; and (ii) the security of your data while it is being transmitted to and from the Services; any transmission is at your own risk. Company urges you to take steps to keep your Personal Information safe, including your Account password, and to log out of your Account after use.
You are responsible for keeping this password confidential and complying with our instructions. You must not share credentials with anyone else, and you authorise the Company to act upon instructions and information from any person that enters your credentials. You also agree to promptly notify us of any information you have provided to us which has changed.
15. TERMS AND CONDITIONS
Please also review the Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of the Services, at: https://www.brucbond.com/legal/conditions.
16. YOUR PRIVACY RIGHTS
Where applicable, you may have certain rights under data protection legislation, including the right to object to direct marketing and the right to see the personal information held about you and you may ask us to make any necessary changes to ensure it is accurate and up to date.
Learn more on other rights available:
You may have certain rights under data protection legislation including the right to see the Personal Information held about you and you may ask us to make necessary changes to ensure that it is accurate and up to date. Where applicable, data protection legislation may also provide the following rights in relation to Personal Information which can also be discussed with us by using the Contact Us section below:
- request us to give you access to it;
- request us to rectify inaccurate or incomplete information, or erase it, where applicable;
- request us to restrict or to stop our using it, in certain circumstances;
- withdraw your consent to our using it;
- data portability, in certain circumstances;
- opt out from our direct marketing, if applicable; and
- lodge a complaint with the relevant Data Protection Authority.
18. CONTACT US
If you have any additional questions or concerns about this Policy, please feel free to contact us any time through the Services or by writing to us at [email protected].