Privacy policy

Introduction

TECH CONSULTANCY MANAGEMENT PARTNERS OU, ((hereinafter "we" or "us"), is a company registered in Harju Maaokond, Tallin (Estonia) whose registered office is Jarvevana tee 9-40, Kesklinna linnaosa, 11314, and whose registered number is 14580113. We are committed to protecting and respecting your privacy and to providing clear information about the use of your data. We are the data controller for the purposes of the personal data we collect via our web or mobile site and for the performance of the services listed under the usages of your personal data, below (together, the “Services”).

Use of our online Services

Collection of personal data

‍We have access to personal data that we collect from the Users when they personally register, when it is provided through legal or voluntary representation or when it is provided by third parties that are associated to the use of our Services. The Personal Data we collect may include and may not be limited to:

  • Identifying and contact information including, your email address, telephone number, name, surname, date of birth, gender and postal address.
  • Account and financial data including, account information, account balance, transaction data, loan data, securities data, investment data and insurance data, etc. Such data may be gathered from payment initiation services, from opening and the subsequent use of a segregated account, from account services from any P2P Providers and Loan Originators investment services bound to the platform for the duration of the transmission.
  • Technical data including, your IP address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
  • Profile data including, your username, purchases or orders to buy or sell made by you, your interests, preferences, feedback and survey responses.
  • Usage data including, information on how you use our website and interact with the products and services.
  • Marketing and communication data in the case you have given express consent that could include your communication preferences and your preferences in receiving marketing from us.

We also collect, use and share Aggregated Data in addition to Personal data but this will not reveal your identity either directly or indirectly and is not considered personal data. For example, we may aggregate your Usage Data to calculate the number of Users accessing a particular feature. If we connect or combine Aggregated Data with personal data in such a way that can directly or indirectly identity you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

The way we collect, use, process and store your Personal Data in order to provide the Services, is detailed in this Policy

Personal Data

‍Use of your personal data

In order to use the Services, you will need to be registered and be using the services of some of the companies we collaborate with, including in the following circumstances:

  • When it is necessary to perform our contract with you for the service, account or product required. For example:
    • To register as a new client or user of TCMP
    • To manage the payments and transfers of funds
    • To register with platforms linked with the Services such as:
      • Payment initiation services.
      • Services to open and subsequent use of a segregated account.
      • Attached P2P or Loan Origination investment services.

We will only proceed to use your personal data in the way described above once you have expressed your agreement with our Terms and Conditions.

  • To inform you of changes to our Privacy Policy and our Terms and Conditions and send you information related to the Services.
  • When it is necessary to satisfy our legitimate interests (or those of a third party) and your fundamental rights do not override this interests, for example:
    • To carry out market research and statistical analysis.
    • To administer and protect our business and website, including troubleshooting, problem solving, system maintenance, data analysis, testing, support, reporting and hosting data.
    • To use data analytics to improve our website, services, products, user experience and marketing.
    • To inform you of updates, changes or developments of our products and services.
    • To carry out user identity checks.
    • When necessary to comply with our legal obligations.
    • To prevent, investigate and discover fraudulent activities.
    • For third parties that take part in the User debt collection process (such as debt collectors, lawyers, bailiffs, insolvency administrators etc.).
    • To correctly develop the Services in as much as the information is necessary to provide our contractual services.
    • For third parties that provide legal, accounting, or audit services to TCMP.
  • When it is necessary for us to effectively comply with legal and regulatory obligations.

In addition, during data collection, it is possible to express your consent to allow the use of your data for other uses which are not related to the principal list such as:

  • When you give your express consent for us to send commercial communications to the postal address, email address or telephone you have indicated, allowing you to receive calls and text messages (SMS) about products or promotions from TCMP or Collaborating Companies and their affiliates.

How we collect your personal data

We use different methods to collect your personal data which include:

  • Direct interactions: You may provide us personal data when your complete forms on our site, including when you:
    • Contract with our products or services
    • Create an account on our website
    • Subscribe to one of our services or publications
    • Request marketing to be sent to you
    • Participate in a competition, promotion or survey
    • Send us your feedback
  • Automated technologies or interactions: Whilst interacting with our website, we can automatically collect technical data about your equipment, browsing actions and habits. We collect this data through cookies, server logs or similar technologies. Please consult our cookies policy to find more information.
  • Third Parties or publicly available sources: We can receive personal data about you through various third parties and publicly available sources including:
    • Identifying Data for registration in such that they are also required to provide the Service.
    • Contact, transactional, bank, and finance data from technical service providers, payment initiation services providers and aggregators of associated accounts.
    • Identity and contact data from P2P Providers and Loan Originators investment services bound to this platform.
    • Identity and contact data from the use of segregated accounts on the platform.

How do I remove my consent?

If you change your mind, you are able to remove you consent by contacting us at our email or postal address which is found in the contact information.

Change in purpose

We will only use your personal data for the purposes for which it was collected unless we reasonably consider that we need to use it for another purpose which is compatible with the original purpose.

If we need to use your personal data for a purpose that is not related to purpose for which we collected your data, we will notify you explaining the legal basis which allows us to do so.

Limits on keeping personal data

Personal data provided will be kept whilst there is a business relationship or it is necessary to carry out our Services, including to comply with our legal requirements.

Once it is no longer necessary to keep your personal data it will be deleted.

In certain circumstances, we may anonymize your personal data (so that it can no longer be associated to you) for research purposes or statistical analysis. In this case, we can use this information indefinitely without prior notice.

Limits on keeping personal data

We may share your Personal Data with selected third parties included below and those which we collaborate with, including business suppliers, associated aggregators, distributors and sub contractors, when it is necessary for the development, maintenance and control of a legally established relationship, or when there is a legal basis to do it.

Our collaborating companies only collect, use and disclose your information in the ways indicated by us in order to provide adequate services.

  • To IBAN WALLET CORPORATION, in such as it is necessary to provide the Services.
  • To P2P Providers added to the Service.
  • To payment initiation service companies.
  • To payment or electronic money entities which facilitate the opening and subsequent use of segregated accounts, including services relating to payments for maintaining accounts.
  • To service providers who deliver solutions for administration systems and IT which allow us to offer our Service.
  • To relevant government bodies, authorities and regulatory bodies in order to comply with our regulatory and reporting obligations.
  • To our professional advisors including lawyers, accountants and advisors who deliver consulting, finance, legal, security and accountancy advice.
  • To any other parties connected with your investments.
  • To market research companies to assist us in improving our Services.
  • To third parties that take part in the User debt collection process (such as debt collectors, lawyers, bailiffs, insolvency administrators etc.).
  • To third party subcontracted suppliers which have established agreements.
  • To third parties who deliver legal, accounting or audit services
  • To any other party where we have your consent or it is required by law

Additionally they can share your data with other third parties for other purposes when they have legally acquired your prior consent.

We require that all those third parties we transfer your data to respect the security of your personal data and they treat it in accordance with the law. We only permit such third parties process your personal data for specific purposes and under our instructions.

‍Keeping Your Personal Information Secure

‍We take the security of your personal information very seriously and have appropriate physical, technical and administrative procedures in place to help protect your personal information from unauthorised access, use or disclosure as required by law in Estonia. Once we have received your user information, we will use strict procedures and security features to try to prevent unauthorised access including: by encrypting any Personal Data which we transfer to our banking partner; and having in place an agreement with our banking partner which requires it to have in place appropriate measures to safeguard the security of the Personal Data we send to them.

‍Your Rights

Requests to exercise your rights

You can, at any moment, revoke the given agreement or request to exercise the following rights to TCMP:

  • The right to be provided with certain information regarding how we collect, use and share you personal information and our legal basis for doing so. This information can be found in this Privacy Policy.
  • The right to access the personal information we are using.
  • The right to ask about the collection and use of your personal data.
  • The right to rectify when there is incomplete or inaccurate information.
  • The right to eliminate your personal data in certain cases such as when removing your consent, when the treatment of your data is illegal or when your data is no longer necessary.
  • The right to request limits to the treatment of your data in certain cases such as when you contest the accuracy of your data or when the treatment of your data is illegal.
  • The right to receive an electronic copy of your personal data or request that a copy of your personal data is sent directly to another person.
  • The right to oppose the treatment of your data in certain circumstance.

To exercise these rights, you can make your request in writing, accompanied with a photocopy of your ID card or other identity document to either of the following address:

  • By post: Jarvevana tee 9-40, Kesklinna linnaosa, Tallinn, Harju maakond, 11314, Estonia.
  • By email: privacy@ibanwallet.com.

Making a complaint to a supervisory authority

Should you be dissatisfied with the service we provide, You have the right to file a formal complaint to the appropriate Control Authority office.

‍International transfer of data

We inform you that some of our suppliers and selected third parties in this Policy are situated outside of the European Economic Area (EEA). As such, the processing of personal data may be associated with a international transfer outside the EEA.

In the case of such transfers, we will provide contractual guarantees in which the receiver of personal data will ensure an adequate level of protection as required in the EEA.

‍Third Party Links

This Privacy Policy, along with the Services we provide can contain links to third party web pages, applications or plugins. 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 policies. When you leave the iBAN WALLET platform, we recommend that you to read the privacy policy of every website you visit.

‍Changes to the Policy

In the case of modifying this policy, we will publish here the changes with a date on which the change was made. If we make a significant change, we will notify you through other means such as by email or by publishing a notice on our webpage.

‍Cookies Policy

‍We collect data about how you interact with our website through the use of cookies. Our website uses cookies to distinguish you from other users of our website. 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. You can find out more information about cookies at www.allaboutcookies.org. We use cookies to enhance the online experience of our visitors and to better understand how our Site is used. Cookies may tell us, for example, whether you have visited our site before or whether you are a new visitor. They can also help to ensure that adverts you see online are more relevant to you and your interests. When you browse the Site, we automatically receive your computer’s internet protocol (IP) address. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.