Cookie Policy
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Breinrock Ltd (Breinrock, We) is a company with registration number HE 39080, registered in Cyprus, at the address: Harmony House, Office 11, 1st Floor, 4 Thekla Lysiotis, 3030 Limassol, Cyprus.
This Cookie Policy explains what cookies are and how they are used in using and navigating our website and services or products offered by Breinrock Ltd and its affiliates (Breinrock, We) through the website (collectively, Services). We use cookies for our Services to distinguish each user of the Services (User, You). This helps us to provide you with a good experience when browsing and using the Services and allows us to improve the Services.
Breinrock Ltd's affiliates include: Breinrock Ltd, FINTRAC license number M20573902 a company incorporated under the laws of Canada and having its place of business at 100 King Street West Suite 5700, Toronto, permitted to act as money transfer business; Breinrock UK, License number FRN929896 a company incorporated under the laws of United Kingdom and having its place of business at 73 Mornington Street, London, NW1 7QE; Breinrock S.R.O License number 043 86 329, a company registered in Czech Republic, and having its place of business at Evropská 2758/11, Dejvice, 160 00 Prague 6; Breinrock DIFC Tech limited, trade license number CL5927 a company registered in UAE, and having its place of business at Emirates Financial Tower S21109, DIFC, Dubai.
For more information about this policy, please contact us at [email protected]
A cookie is a small file of information, letters and numbers that we store on your browser or the hard drive of your computer or your mobile device or tablet if you agree. Cookies contain information that is transferred to your computer's hard drive or mobile device or tablet.
Reference to a "cookie" means the software or technology that can collect, transmit, or recognise information about your visits to, and use of, the Services.
The following types of cookies may be used:
Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website. Without these cookies, you will not be able to use basic services of the website, such as creating an account.
Your consent will not be sought to place these Cookies; they are placed automatically. It is still important that you are aware of them. You may still block these Cookies by changing your internet browser's settings as detailed below, but please take notice that our Services may not work properly if you do so.
Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. These cookies collect anonymous information (they don't contain personal information) on how users use the Services. This information is used for statistical purposes.
Functionality cookies. These are used to recognise you when you return to our Services. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
Targeting/Marketing cookies. These cookies record your visit to the Services, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. Without these cookies, online adverts you encounter will be less relevant to you and your interests.
Cookies are saved on your device, after you have been notified and have consented to them, except where strictly necessary or functional cookies are used -in that case no explicit consent is required.
By clicking accept to the use of any cookies at the message that pops up on your screen asking you to accept, customise, or reject cookies, as may be available for the relevant category of cookies, you are agreeing to our placing cookies on your browser or the hard drive of your computer or your mobile device or your tablet or any other device from which you access our website.
You can set your browser to refuse all or some browser cookies at any time, or to alert you when websites set or access cookies, by selecting the appropriate settings on your browser (see more information below).
If you disable or refuse the use of cookies on our website, at any time, please note that some parts of our website may become inaccessible or not function properly. To find out more about cookies, including how to manage and delete them, you may visit www.allaboutcookies.org.
You disable and/or refuse cookies by rejecting to their use when a relevant message pops up or by activating the setting on your browser that allows you to refuse the setting of all or some cookies.
However, if you block all (including essential cookies) you may not be able to access all or parts of our website.
Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. In order to understand how to change your cookie settings, use the 'help' option in your internet browser or visit the relevant pages on cookie settings in Internet Explorer, Firefox, Chrome or Safari.
We may make changes to this Cookie Policy from time to time. We will update this Cookie Policy from time to time to reflect any changes to our website. We may also make changes as required to comply with changes in applicable law or regulatory requirements or where we change the cookies we use or how we use cookies. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this policy periodically to be informed of how our website uses cookies.
Breinrock will be the "data controller" or "controller" in relation to any personal data provided to us directly via email, phone, chatbot, and post or via the Services, including the Website, or any other available communication channel offered by Breinrock to you. This means that we are responsible for deciding how we will hold and use personal data about you.
By using or navigating the Website and the Services, you acknowledge that you have read, understand, and agree to be bound by this Privacy Policy. You should not provide us with any of your information or use the Website or Services if you do not agree with the terms of this Privacy Policy.
Persons under the age of 18 cannot provide any personal data through our Website, Services, social media account. Persons under 18 years old cannot be registered on our platform with or without consent of parents or other legal guardians.
You may contact our Data Protection Officer:
By email at: [email protected]
Personal data is any information about you that enables us to identify you or the beneficiary of your transaction with us, either directly or indirectly. Personal data covers information such as your name and contact details, but also information such as identification numbers, electronic location data, and other online identifiers.
We are committed to complying with applicable data protection laws and will ensure that personal data is:
We only collect the most relevant, proportionate for each purpose and strictly necessary personal data from you in the course of our business when you access, visit or use our Services. We collect data that are:
The personal data that we collect, and process includes:
We collect your data in various ways. These include the following:
We may collect information that you provide directly.
Typically, this will happen when you register or sign-up with us, where you create an account with us, when you fill in any application form, when you subscribe to our newsletter, when you participate in surveys, when you send us an email, when you sign a contract with us.
We may collect information about you automatically.
When you use our Services, including when you interact with our Website without logging in your account, we will automatically collect technical-related data about you, your equipment, browsing actions and patterns.
Every time you use or access the Services, and our Website, data is collected. This data is stored in log files on the server and can include, the temporary storage of data and log files. The IP address is temporarily stored in the system as it is necessary to provide website access to your computer or other device. The IP address is retained while that website is being accessed. These log files are stored to ensure website functionality, optimize the content of our Website, and ensure the security of our IT system.
Typically, automatic collection of data will happen when you browse and use our Services and Website, social media pages (usually with the use of cookies and other similar tracking technologies).
We may acquire information about you from third parties.
We do this where we are permitted by law. This may be the information provided by our partners, marketing agencies, your public profile information such as in social media platforms, like LinkedIn, Facebook, Twitter, Instagram). We may associate the information we receive about you from yourself, public and commercial sources with other information we receive from you or about you.
These are the typical ways in which we collect information about you. We may collect information about you in other cases that are not covered by this Privacy Policy or using other methods not covered by this Policy. If this happens, we will inform you additionally.
We will use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
In general, we may use your personal data to carry out, provide, fix, and improve our Services, develop new Services, and market our Services.
Below, we explain the ways we plan to use your personal data and the grounds we rely on. We may rely on more than one ground to use your data. You can contact us any time to ask for more details on the grounds we are relying on to use your data.
| Purpose | Legal Basis | Personal Data |
|---|---|---|
| To enable you to register and sign-up with us and to administer your account, to contact you and to update our records about you | Performance of our contract with you | Personal and Contact information such as your first name, last name, username, title, date of birth, personal number/code, date and place of birth, nationality, registered address, correspondence address, details of the personal identity documents (such as passport, identity documents), workplace contact information, the company you work for, images and selfie, signature, tax identification number, tax residency, email address, mobile phone number and other contact details, occupation, PEP status, and other relevant details. Data connected to your account with us, such as your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. |
| To provide you, carry out and perform the Services and to carry out our obligations related to the provision of the Services | Legal Obligation Performance of our contract with you |
Personal and Contact information such as your first name, last name, username, title, date of birth, personal number/code, date and place of birth, nationality, registered address, correspondence address, details of the personal identity documents (such as passport, identity documents), workplace contact information, the company you work for, images and selfie, signature, tax identification number, tax residency, email address, mobile phone number and other contact details, occupation, PEP status, and other relevant details. Payment information – such as details of any transactions carried out using any of the Services, bank account number, e-wallet information, details about payments and transfers made using the Services. |
| To confirm Client's identity and verify personal and contact details in order to confirm Client's eligibility to use our products and services and to comply with any applicable legal and/or regulatory requirements. | Legal Obligation Legitimate Interest |
Personal and Contact information such as your first name, last name, username, title, date of birth, personal number/code, date and place of birth, nationality, registered address, correspondence address, details of the personal identity documents (such as passport, identity documents), workplace contact information, the company you work for, images and selfie, signature, tax identification number, tax residency, email address, mobile phone number and other contact details, occupation, PEP status, and other relevant KYC details. |
| To communicate with you regarding the Services, and any updates and developments thereof | Necessary to perform legal obligations Legitimate Interest |
Name, surname, email address, telephone number, social media information. |
| To respond to and process your queries and requests. | Legitimate interest | Name, surname, e-mail address, social media information and any other contact you ask us to respond you to |
| To provide information about the Services | Performance of the contract with you Legitimate interest to offer accurate, up-to-date and complete information about our Services and Website |
name and surname, email address, mobile phone number. |
| To monitor and record your telephone calls | Legal Obligation Performance of the contract with you |
Personal and Contact information such as your first name, last name, username, title, date of birth, personal number/code, date and place of birth, nationality, registered address, correspondence address, details of the personal identity documents (such as passport, identity documents), workplace contact information, the company you work for, images and selfie, signature, tax identification number, tax residency, email address, mobile phone number and other contact details, occupation, PEP status, and other relevant details. Payment information – such as details of any transactions carried out using any of the Services, bank account number, e-wallet information, details about payments and transfers made using the Services. |
| To find out how people use our Services, including our Website, in order to improve them and create new content, products and services. | Legitimate interest to monitor the quality of the services provided, develop and improve the content that we provide, and ensure the security of the Website and Services. | IP address, operating system version and parameters of the device you use to access content / products, the usage time and duration of your session, query terms that you enter on our Website, and any information stored in the cookies that we have detected on your device, GPS signal of the device, or information about the closest Wi-Fi access points and cellular towers that may be passed to us when you are using our Website content. |
| Defend our interests in court or other institution | Legal obligation Legitimate interest in defending against claims |
Any personal data that is relevant to the claim is needed to defend ourselves. |
We reserve the right to offer you supplemental documents to this Privacy Policy that will describe the ways in which we process your personal data, other than as described above in the table.
We will use your personal data for the purposes for which we collect it or where we reasonably consider that we need to use it for another reason only if this reason is compatible with the original purpose.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which 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.
Personal data is used for different purposes, and is subject to different standards and regulations. In general, personal data is retained for as long as necessary to provide you with services you request, to comply with applicable legal, accounting or reporting requirements, and to ensure that you have a reasonable opportunity to access the personal data.
To determine the appropriate retention period for personal data, we consider the applicable legal requirements, the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means. For example,
We may disclose your information to our employees, agents, and Affiliates to perform services for us.
We may also disclose your information to third parties, such as:
Please note the following:
We use a variety of technical and organisational measures to help protect your personal data from unauthorised access, use, disclosure, alteration or destruction consistent with the applicable data protection laws. We have also implemented appropriate information security policies, rules and technical measures to secure your personal data collected by us. Your personal data is saved in an encrypted form.
All of our partners, employees, consultants, workers and data processors (i.e. those who process your personal data on our behalf), who have access to, and are associated with the processing of personal data, are obliged to respect the confidentiality of such personal data, keep it secure and protect it.
In order to provide our Services, we may need to transfer your personal data to locations outside of your jurisdiction of residence. For any such transfers, we will implement appropriate measures to ensure that your personal data remains protected and secure in accordance with applicable data protection laws.
For any transfers of data outside the European Economic Area (EEA), we only transfer personal data outside the EEA where we implement the appropriate measures to ensure a level of protection that is equivalent to that of the EU. To that end, we rely on either of the following measures:
We may sometimes contact you (by email, SMS text, letter or phone) in order to provide targeted marketing about our Services. Such marketing communications will only be sent to you if you gave your consent (when you registered for our Services or at another point) and you have not withdrawn such consent or if there is another basis to send such communications to you (for example, in certain circumstances, we may send marketing communications solely about our Services to existing customers using contact details we have obtained directly from the customer during the course of registration or the provision of our Services to them, provided they have not previously unsubscribed from such communications).
You have the right to object where we are processing your personal data for direct marketing purposes. This means you can opt-out from receiving direct marketing from us at any time.
You can ask us to stop sending you marketing material and messages any time. You can use any of the following methods:
Where you opt out of receiving marketing messages, you will not stop receiving service communications, such as updates regarding the Services you use.
You should note that we are opposed to third-party spam mail activities and do not participate in such mailings, nor do we release or authorise the use of your personal data to third parties for such purposes.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of our Services may be come inaccessible or not function properly.
For more details, see our Cookie Policy.
We do not carry out any automated decision-making about you where this has a legal or similar significant effect, including profiling. In case we carry out any such profiling, we will let you know. Please note that you have the right not to be subject to profiling, and you can exercise this right by contacting us in writing at [email protected].
You have the following rights in relation to the personal data we hold about you. Please note that some of these rights will only apply in certain circumstances and some of them may be limited where we have an overriding interest or legal obligation to continue to process the data or where data may be exempt from disclosure due to reasons of confidentiality obligations.
If you want to exercise any of these rights, please contact us at [email protected]. Please note that you also have a right to lodge a complaint with your local supervisory authority.
Our Services may include links to third-party websites, plug-ins (such as social media plug-ins) and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.
We may make changes to this Privacy Policy from time to time. To ensure that you are always aware of how we use your personal data we will update this Privacy Policy from time to time to reflect any changes to our use of your personal data. We may also make changes as required to comply with changes in applicable law or regulatory requirements. Where it is practicable, we will notify you by email of any significant changes. However, we encourage you to review this Privacy Policy periodically to be informed of how we use your personal data.