This notice covers Streamity Group OÜ registered in the Republic of Estonia.
This notice demonstrates our liabilities related to the protection of your confidentiality rights and defines the principles, whereupon we process the personal data that is collected by us or is transferred by you to us. It is applied to:
Please review the information below to get the idea of our policy and practice in respect of your personal data and our methods of dealing therewith.
Streamity Group OÜ uses a "multilevel approach" to comply with the regulators' recommendations and to explain the manner of use of the personal data. It means that, in the first place, we try to communicate "in brief" the key information referred to the use of personal data in this privacy notice. In the Contract Us section at the end of this notice you will find contact details for feedback or any requests related to safety protection.
We collect information on you in order to provide you with our products, notifications of changes in our product lines and to improve them. We also use these data to inform you on other products that we offer or that are selected by third parties, similar to those that you used or that you requested or those that, in our opinion, may be of interest to you. If you use one of our financial products, we use your personal data to assess your financial standing and to identify and pursuit possible fraud.
We do not disclose your personal data to anyone, except as provided herein.
We may transfer your personal data to third parties, including service providers, credit bureaus and financial institutions, in order to provide services that we offer. We may also transfer your personal data to third parties in order to prevent crimes and reduce risks if so required by law, if we think such action reasonable, within the framework of a court process or to protect the rights or property of Streamity Group OÜ, our clients or other persons.
The personal data we receive from you may be transferred, stored and processed in the countries outside the European Economic Area (EEA). Such countries may have data protection standards in place that are different from similar standards adopted in your home country (they may be less strict in some cases). We will take all necessary steps to ensure that the recipients of your personal data will use it and protect it in the same safe way as we do.
If we give you (or you select) a password, access code or any other safe means of access and authentication enabling access to certain sections of our web-site, you shall bear responsibility for non-disclosure of such password and compliance with our guidelines. You must not exchange your account data with anyone and you authorize Streamity Group OÜ to act in compliance with instructions and information received from any person that enters your account data.
Information transfer via the Internet is not completely safe. Despite our attempts to protect your personal data, we may not guarantee the safety of information transmitted to our web-site, except when you communicate with us via a protected channel provided by us. On receiving your personal data, we comply with strict procedures and use safety provision functions excluding unauthorized access to such data.
When applicable, in compliance with the data protection legislation, you enjoy certain rights, including the right to: access, edit, alter or delete your personal data; object to its processing or restriction; request that some of your personal data be transferred to another service provider (i.e. to transmit data portability); or withdraw any consent given earlier.
However, it should be noted that there are certain exceptions from such rights. More detailed information on the available rights is given in the comprehensive privacy notice.
Automatic devision-making means that a decision in your respect is taken automatically and is based on computer definition (using software algorithms) without human input. For instance, we use automatic decisions to evaluate your credit capacity when you apply for certain Services provided by Streamity Group OÜ or to perform audits aimed to prevent fraud during execution of your transactions. However, if you are located in the territory of the European Union, you have the right to challenge any automatic decision and request its evaluation by humans, including on the basis of the data you provide.
To exercise your rights, please, contact us at the details specified below.
We process your personal data if we have at least one of the following grounds:
Any future changes in our privacy notice will be published on this page and, if necessary, you will be notified of the same by E-mail. Please visit this page regularly for any new supplements or amendments in our privacy notice.
We are open to any comments, requests and queries related to our use of your personal data. If you wish to exercise any of your rights and receive additional information on Streamity Group OÜ covered by this notice, you should send a letter at the address below marked with "For the attention of Data Protection Department".
Responsibility for personal data protection rests with the person below, who may be contacted via a link to the Contact Us section or at the address given below:
Streamity Group OÜ
Effective date - August 15, 2019
This notice covers Streamity Group OÜ. Streamity Group OÜ shall maintain your confidentiality and shall take all the necessary actions to ensure safe processing of your personal data and compliance with the provisions hereof during collection, use, storage and disclosure of such information.
References to "you" herein are references to certain persons using or intending to use the Services of Streamity Group OÜ (as defined below) via their own account or on behalf of an organization. The above includes - in respect of a Streamity Group OÜ client or potential client - any individual entrepreneur and any managers, including managing and financial directors, any other directors and managing employees, shareholders, partners and actual owners of the client, as well as any employee using or intending to use the Services of Streamity Group OÜ on the client's behalf.
For the purpose hereof, all the above shall be referred to as "Streamity Group OÜ Services".
Please read closely this notice to get the idea of our policy and practice in respect of your personal data and our methods of dealing therewith. Streamity Group OÜ uses a "multilevel approach" to comply with the regulators' recommendations and to explain the manner of use of the personal data. It means that, in the first place, we try to communicate "in brief" the key information referred to the use of personal data in this privacy notice. This document represents a comprehensive privacy notice that describes in detail the methods of protection of our data and that is referred to in the short privacy notice. In the Contract Us section at the end of this notice you will find contact details for feedback or any requests related to safety protection.
Personal and non-personal information
We collect and process personal and non-personal information related to you.
Personal data includes information that allows to expressly identify a certain person, directly or indirectly.
Streamity Group OÜ may collect non-personal information or may depersonalize the data to make it non-personal information. Non-personal information is information that does not allow to directly or indirectly identify a certain person. Streamity Group OÜ may collect, create, store, use and disclose such non-personal information for any reasonable work-related purposes.
For instance, Streamity Group OÜ may use summarized information on transactions for business purposes, notably, to analyze the tendencies and analytical data in order to make analytical conclusions on transaction schemes and usage.
So long as, according to any local legislation, Internet protocol addresses (IP-address) (or similar identifiers) are expressly defined as personal data, and if the provisions of such local legislation are applied to Streamity Group OÜ Services, we regard such identifiers as personal data.
It should be noted that Streamity Group OÜ provides services both to single customers and entities, so this privacy notice is applicable to both types of consumers and shall be read and interpreted respectively.
We collect the following data types using the following methods:
Information that you provide to us: we receive and store any personal data (including financial information) that you provide to us, including when you (or your company) make a request in respect of Streamity Group OÜ Services or apply for their receipt; get registered for the use of, and (or) use any Streamity Group OÜ Services; download and (or) store information on our servers when using Streamity Group OÜ Services; and contact us by E-mail, via SMS, web-site or portal, by phone or by other electronic means. Such information may contain references or refer to you or your clients and includes:
Information on you collected automatically: Streamity Group OÜ automatically receives and stores certain information during your interaction with Streamity Group OÜ, for example, using cookies or similar technologies.
Besides, we receive certain information during sessions performed via your browser to access Streamity Group OÜ Services or advertising materials and other content provided by Streamity Group OÜ or on its behalf on other web-sites, or when reading E-mails. Collection of such information allows us to get a better insight into our visitors and clients that use Streamity Group OÜ Services or interact with Streamity Group OÜ, define the resource they have been taken from and to know in which way they use our services. We use this information for analytical purposes, as well as to enhance quality and demand of our services by visitors and clients. Such information inlcudes:
Information collected via our applications: if you download or use Streamity Group OÜ mobile or desktop application, we may receive information on your location and location of your device or on the service you use (including the place of a payment transaction). Some devices allow applications to access information on real-time location (for example, GPS (Global Positioning System)). When the function of real-time position location is activated, our mobile and desktop applications may collect such information from your mobile device or personal computer at any time you download or use our applications. We always try to inform you of our intention to receive information on your real-time location and, if so required by law, obtain your consent. We may use such information for regulatory purposes, to conduct our own full-scope audits, to get a more deep insight into the structure of transactions and ensure the best use of our services.
E-mail and other means of communication: we may receive information on you and on your use of Streamity Group OÜ Services when we communicate with each other and when you open our messages and use electronic identifiers (sometimes known as "digital device prints"), for example, IP-addresses or phone numbers.
Information from other sources: we may receive information on you from other sources and add it to our information on your account. For example, we closely cooperate with and receive information from third parties, such as counter parties, financial institutions, shops, subcontractors providing financial, payment and delivery services, advertising agencies, analytical information suppliers, search information suppliers, credit bureau and fraud preventing agencies. Below you can find more detailed information on the use of services provided by credit bureaus and fraud preventing agencies. To get a deeper insight into our clients and for the purpose of provision and development of Streamity Group OÜ Services, we may study public comments and opinions in social networks (for instance, Facebook and Twitter). Information on third parties: if you provide us information on third parties you must inform them of the same in advance (for example, provide them with this privacy notice) and make sure you have the right to do so.
We may use and transfer the personal data we collect for the following purpose:
We do not disclose information that could help ascertain your identity, except as and for the purposes described and defined herein, including:
Except as required for the provision of services, as well as in accordance with the foregoing, Streamity Group OÜ does not sell, lease, transfer or otherwise disclose information on its clients to any third parties for business purposes.
We may track or record telephone conversations, E-mails, web chats or other means of communication with you for regulatory, safety and quality improvement purposes, or for the organization of training programs. When you visit our offices, we may activate CCTV and access control and (or) other surveillance systems for safety provision, as well as for health and labor protection.
We, our service providers and other parties, to which we provide your personal data (as described above), may process it outside the European Economic Area (EEA) and outside your home country. Personal data may also be processed by the staff employed by us or one of our suppliers located outside EEA or outside those territories where it was received. Such staff may, inter alia, be involved in the execution of guidelines, payment processing and service support during the provision of Streamity Group OÜ Services. Such countries may have data protection standards in place that are different from similar standards adopted in your home country (they may be less strict in some cases).
In such cases, we assume necessary measures to protect your personal data in accordance with this privacy notice and the applicable data protection law, including the use of any respective means of safety provision ensuring legality of the international data transfer under such law. When entering into contractual relations with independent data recipients located outside EEA and receiving data from EEA for its processing outside EEA, Streamity Group OÜ commonly includes "Model Clauses" adopted by European Commission. In certain cases, when data recipient is located in the USA, for those companies that have agreed to the given scheme, we may use EU-US Privacy Shield
We have taken a number of measures aimed to protect your personal data against its accidental loss and unauthorized access, use, alteration and disclosure.
Responsibility for safety and protection of your information also rests with you. If we have given you (or if you created) a password or access code to access certain sections of our web-site or portal or mobile applications, etc., you shall be responsible for the non-disclosure of such password and (or) access code. You must not disclose your password and (or) access code to anyone. You must exclude unauthorized use of your password and access code. Streamity Group OÜ will act in compliance with the guidelines and information received from any person who specified your user ID and password and you realize that you are fully responsible for any use and other actions that may be committed when using your account. You should immediately notify Streamity Group OÜ of the change in any data transferred to us.
Information transfer via the Internet is not completely safe. Despite our attempts to protect your personal data, we may not guarantee the safety of information transmitted to our web-site, except when you communicate with us via a protected channel provided by us.
On receiving your personal data, we comply with strict procedures and use safety provision functions excluding unauthorized access to such data.
YOUR PERSONAL DATA RETENTION PERIOD
The period of retention of your personal data depend on its nature and type, Streamity Group OÜ Services and the country, in which they are provided, as well as on any applicable regulatory requirements and provisions of local legislation. As a rule, if such data is not needed any longer it is to be destroyed or depersonalized or aggregated with other data.
If you use Streamity Group OÜ Services, we store your personal data for as long as the services you selected are provided. Usually it means that we store your personal data for as long as you continue to be our client and within a certain period thereafter.
Upon termination of relationship, we are to store certain personal data within the period provided for by legislative and regulatory requirements of your home country. For instance, we store your personal data within the period prescribed by local legislation for filing a statement of claim (so-called "action limitation period") or within the period prescribed by a court ruling, law-enforcement authorities or our regulators.
We may continue with our marketing emailing if it does not run contrary to the local legislation and in the absence of your refusal to receive such mails.
You may exercise numerous rights you have in respect of your personal data. If required, you may obtain access to, correct or update your personal data. Under certain circumstances, you may demand deletion of your personal data, prohibit or temporarily limit its processing if you exercise your other rights. Besides, you may demand that some of your personal data be transferred to another service supplier (i.e. data portability).
After giving us your consent to use your personal data, you may withdraw it at any time. Withdrawal of such consent shall not affect the legality of any processing we perform prior to such withdrawal, as well as the processing of your personal data on the basis of legal processing, besides your consent. For example, you may stop receiving our marketing materials by clicking "Cancel subscription" or "Refuse" in an E-mail or by following the instructions we send each time but we will continue sending you instant and service messages in respect of Streamity Group OÜ Services.
It should be noted that the above rights you may use depend on the country, in which you use Streamity Group OÜ Services. Besides, observance of rights can be impossible in certain cases: for instance, you may not restrict us from using your personal data if it is required by law or is necessary to handle claims; in a similar way, you may not demand the deletion of your personal data if you intent to continue using Streamity Group OÜ Services.
You have a continuous right to file a complaint on our collection and use of your personal data with a data protection supervisory authority. For more detailed information, please, refer to your local data protection supervisory authority. Besides, you may initiate court proceedings and demand compensation for damage or arrest caused by our inability to comply with the data protection law.
If you wish to get more detailed information on your rights or exercise such rights, please contact us at the details specified in the Contract Us section.
In some cases, our use of your personal data may lead to automatic decision-making (including evaluation), which may have a significant legal or other impact on you.
Automatic devision-making means that a decision in your respect is taken automatically and is based on computer definition (using software algorithms) without human input. For instance, we use automatic decisions to evaluate your credit capacity when you apply for certain Services provided by Streamity Group OÜ, or to perform audits aimed to prevent fraud as described in What Do We Use Your Personal Data For? section. We have taken measures to ensure protection of rights and interests of those persons whose personal data is used for automatic decision-making. Besides, if you use Streamity Group OÜ Services in the territory of the European Union, you are entitled to challenge any decision taken automatically, express your opinion and demand evaluation of such decision by humans. You may exercise this right by contacting us at the details specified below.
Streamity Group OÜ shall process your personal data only when we have legal authority to do so. Such laws differ in various territories, and further specific information is provided on request. Generally speaking, Streamity Group OÜ processes information in the following cases:
If you have questions or you need additional information on the legal grounds, on which we collect and use your personal data for certain data processing, please, contact us at the details specified in the Contact Us section below.
We may, for time to time, introduce changes in our privacy notice. When we make significant changes in respect of processing of your information, we shall notify you of the same on this web-site or portal. The date of last changes made hereto is specified at the bottom of the page. You are responsible for regular visits to our web-site/portal and checking this privacy notice for any changes. However, if according to the law, we are required to specifically inform you of any changes herein and (or) obtain your consent to our use of your personal data, we shall act respectively.
We may, from time to time, publish references to the web-sites of our partners, advertising agents and subsidiary companies. When clicking such references, please note that these web-sites have their own privacy policies and cookie policies in place, and Streamity Group OÜ does not assume any responsibility or obligations in respect of such third-party web-sites.
This is a global notice that is not aimed to violate any legal rights or bans in any territories where such rights or bans are valid. This being the case, rights and responsibilities set forth herein shall be applicable only if a change has priority according to any applicable enactment.
We are open to any comments, requests and queries related to our use of your personal data. If you wish to exercise any of your rights or receive additional information on respective Streamity Group OÜ companies covered by this notice, you should send a letter at the address below marked with "For the attention of Data Protection Department" or at SA_STM_CLUB@streamity.org
Responsibility for personal data protection rests with the person below, who may be contacted via a link to the Contact Us section or at the address given below:
Streamity Group OÜ, Estonia
Registry code: 14617141
Last version of this notice - August 15, 2019.