Privacy Policy

1. Introduction

1.1. We take the handling of personal data seriously to ensure your privacy when processing and safeguarding your personal information. This Privacy Policy outlines how and why we process, use, and share your personal data when you use our website at https://paynamic.io (the "Website"), software, applications, and other online products and services (collectively referred to as the "Services"), or when you interact with us in any other way or receive communication from us.

1.2. By using our Services or visiting our Website, you expressly consent to the processing of your personal data as outlined in this policy.

1.3. Any mention of "We," "Us," "Paynamic," or the "Platform" in this Privacy Notice refers to Paynamic Sp. z o.o., a Polish entity with its registered office at ul. Ujazdowskie 41, 00-540 Warsaw, Poland, Company registration number: RDWW – 1447, unless otherwise stated.

1.4. We may periodically update this Privacy Policy. The current version, available at https://paynamic.io , will govern the processing of your personal data. In case of a material change, we may notify you via email, and if required by law, seek your permission or provide an opt-out opportunity for any new use of your personal information.

1.5. Paynamic collects and processes personal information necessary for legitimate business purposes, disclosing this to the data subject at the time of collection. We retain your personal data for the duration required to fulfill the purpose for which it was collected and used, unless an extended period is mandated by legal obligations or for defense in a legal matter.

2. Collection of Personal Data

2.1. The data we collect encompasses various categories, including:

• 2.1.1. Identity Data:

• Full name or portions thereof.

• Username or a comparable identifier.

• Marital status.

• Title.

• Nationality.

• Date and location of birth.

• Tax number.

• Gender.

• Information from identity documents, including biometric details (e.g., facial images).

• 2.1.2. Contact Data:

• Billing address.

• Residential address.

• Email address.

• Telephone number.

• 2.1.3. Screening Data:

• Close associations.

• Political background.

• Information linked to sanctions and adverse media.

• 2.1.4. Risk Assessment Data:

• Client risk score.

• Client risk categorization.

• 2.1.5. Economic and Appropriateness Data:

• Employment status.

• Annual income.

• Source of income.

• Current wealth value.

• Annual investment plans.

• Investment objectives.

• Trading experience.

• Level of education

• 2.1.6. Financial Data:

• Bank account details.

• Payment card details.

• 2.1.7. Transaction Data:

• Details regarding payments to and from you concerning our Services.

• 2.1.8. Technical Data:

• Internet Protocol (IP) address.

• Login data.

• Browser type and version.

• Time zone setting and location.

• Browser plug-in types and versions.

• Operating system and platform.

• Other technology on the devices used to access the Services.

• Obtaining personal data from various third parties and public sources, including technical data from analytics providers like Google (based outside the EU), advertising networks, and search information providers.

• 2.1.9. Communication Data:

• Details regarding communications with us, including inquiries and responses.

• 2.1.10. Profile Data:

• Username and password.

• Your interests.

• Preferences.

• Feedback.

• Survey responses.

• 2.1.11. Usage Data:

• Information pertaining to how you access and utilize our Services, including user sessions and, in certain instances, screen recordings.

3. Purpose of Your Personal Data Usage

As part of our business operations, we gather, utilize, store, and transfer diverse types of personal data about you only if there is a lawful basis for such use. The most common lawful bases used by us are:

3.1. Consent. In specific instances, we may handle your personal data solely upon obtaining your explicit consent.

3.2. Execution of a Contract. To provide you with our Services in adherence to the contractual terms between you and us, we necessitate the use of your personal data.

3.3. Adherence to Legal Obligations. The nature of the Services we furnish compels us to amass and store specific data about you in conformity with the laws governing our operations.

3.4. Legitimate Interests. On occasion, we leverage our legitimate interests to process your data, such as enhancing our Services. However, we exercise this right only when such interests do not supersede your rights, interests, or fundamental freedoms.

3.5. The following table outlines the potential applications of your personal data and identifies the legal bases Paynamic employs to ensure lawful data processing:

1. Introduction

4.1. Purpose of Cookies:
Our Website utilizes cookies to distinguish you from other users, enhancing your browsing experience and allowing us to refine our site.

4.2. Information Analysis:
Cookies, commonly stored on your computer’s hard drive, help us evaluate site effectiveness, analyze trends, and administer the platform. This information guides improvements to the user experience, identifying popular site sections and addressing access challenges.

4.3. Email Enhancement:
We use cookies, web bugs, or clear gifs in emails to confirm receipt and response, personalizing your experience on our site.

4.4. Third-Party Assistance:
Utilizing third-party service providers, we gain insights into site use. These providers may place cookies on your computer, offering data on navigation, viewed products, and general transaction information. Aggregate reports assist us in understanding visitor interests and improving our services.

4.5. Data Integration:
Information from service providers may be linked and combined with data we collect about you while using the platform. Service providers are contractually restricted from using this information for purposes other than assistance to us.

4.6. Agreement to Cookie Usage:
By visiting the Paynamic Website, you agree to our use of cookies for the specified purposes.

4.7. More Information:
Further details on Paynamic's use of cookies can be found in our Cookie Policy, accessible at https://paynamic.io.

5. Sources of Personal Data and Automated Decision-Making

5.1. We obtain most of your personal data directly from you, such as when you register for our services or engage in communication with us, leading to the receipt of your identity and contact information. Additionally, we may receive personal data from third parties and publicly accessible sources, such as social media, search engines, company registers, banks, payment service providers, KYC service providers, advertising networks, analytics providers, and screening data vendors. Furthermore, while you use our services, technical data is automatically collected through technologies like cookies.

5.2. In the course of providing our services and fulfilling legal obligations, we engage in automated decision-making processes. These instances include:

• 5.2.1. Evaluating Trading Eligibility:

Our system automatically assesses whether you can be permitted to trade based on the economic and appropriateness data provided in relevant questionnaires. Access to the services may be denied if insufficient experience and/or knowledge are identified.

• 5.2.2. Fraud Detection:

Our anti-fraud systems autonomously identify patterns indicative of potentially fraudulent activities related to your account. In such cases, we will notify you to mitigate potential fraud.

• 5.2.3. Risk Profiling:

Our systems autonomously determine the client's risk profile by evaluating various risk factors in line with applicable laws and internal procedures. The resulting risk score enables Paynamic to establish the necessary customer due diligence procedures.

6. Sharing of Your Personal Information

6.1. Paynamic Group Companies:
Sharing with other companies within the Paynamic group.

6.2. Third-Party Providers:
Sharing with providers of apps, communication systems, and trading platforms.

6.3. Service Providers and Advisers:
Sharing with contracted entities for services such as IT, analytics, marketing, financial, regulatory, and compliance.

6.4. Introducing Brokers and Affiliates:
Sharing with partners having mutual relationships.

6.5. Payment Service Providers and Banks:
Sharing while facilitating transaction processing.

6.6. Auditors and Contractors:
Sharing for auditing, assistance, or advice on business purposes.

6.7. Legal and Regulatory Authorities:
Sharing with courts, tribunals, government bodies, and law enforcement agencies as required by law or authorized by agreements.

6.8. Enforcement of Terms and Conditions:
Sharing with any third party when necessary to enforce our terms and conditions of service.

6.9. Authorized Entities:
Sharing with any entity authorized by you.

6.10. Service Providers and Data Sharing
Engaging service providers for various functions, ensuring adherence to privacy measures.

6.11. Third-Party Advertisers:
Partnering with advertisers and ad networks to deliver targeted advertising.

6.12. Personally Identifiable Information:
Using personally identifiable information to operate and enhance our services.

6.13. Aggregated Non-Personal Information:
Sharing aggregated, non-personal information with third parties for analysis.

6.14. Message Administration:
Retaining messages sent to us for inquiry administration and service improvement.

6.15. External Links:
External third-party websites linked from our sites are not covered by this privacy notice. Please check with each third party for details.

7. Data Security and Retention

7.1. Security Measures:
We maintain personal information in secure computer storage facilities and paper-based files, ensuring protection against misuse, loss, unauthorized access, modification, or disclosure.

7.2. Data Removal and Destruction:
When deemed unnecessary, we remove identifying details or securely destroy records.

7.3. Retention Period:
We typically retain your personal data for the duration necessary to fulfill the specific purpose for which it was collected. This includes meeting legal, accounting, reporting requirements, and addressing our legitimate interests. For instance, your personal data is generally stored for a period not less than 5 years after concluding the business relationship with Paynamic for purposes stipulated in applicable Anti-Money Laundering, Terrorist Financing, and Illegal Transfer of Funds regulations. Additionally, certain personal data may be retained for a minimum of 6 years to comply with tax legislation for bookkeeping purposes. In some instances, authorities may mandate longer data retention periods, especially during ongoing investigations. If you have not actively used our financial services for 5 to 6 years (depending on the data), we will eliminate any details that can identify you or securely destroy the records unless we substantiate why we need the data for a longer period.

7.4. Prospective Client Data:
Incomplete or rejected account opening applications are retained for 6 months unless regulatory obligations dictate a longer duration.

7.5. Suppression List:
For individuals opting out of marketing communications, details are retained on a suppression list.

7.6. International Data Transfers:
Your data may be transferred and stored outside the European Economic Area (the EEA). We ensure its secure treatment and compliance with this Privacy Policy.

7.7. Compliance Measures:
When transferring data beyond the EEA, we may rely on standard contractual clauses, binding corporate rules, EU-US Privacy Shield, or equivalent arrangements, ensuring compliance.

7.8. Request for Arrangement Details:
You can request details of these arrangements by contacting us through the provided contact details.

7.9. Internet Transmission Security:
While we strive to protect data transmitted over the internet, we cannot guarantee complete security. Your transmission is at your own risk. Upon receipt, we implement strict procedures and security features to prevent unauthorized access.

8. Commitment to Security

8.1. We are dedicated to safeguarding personal data, implementing and maintaining suitable technical and organizational measures. These measures ensure the appropriate level of security to protect personal data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access during transmission, storage, or processing.

8.2. Safety Measures:
We apply the following safety measures:

• Evaluation of security measures' effectiveness before website launch and updates.

• Establishment of rules for accessing and processing personal data, with comprehensive registration of all related actions in the website's information systems.

• Regular audits and reviews of data security protocols.

9. Your Rights

Please be aware that these rights may not be applicable in all situations. Nevertheless, you are entitled to the following:

9.1. Access Request:
You have the right to request access to the personal data we hold about you.

9.2. Correction Request:
You have the right to request correction of the personal data held about you.

9.3. Erasure Request:
You can request erasure of your personal data, subject to certain legal considerations.

9.4. Objection to Processing:
You have the right to object to the processing of your personal data based on legitimate interests.

9.5. Processing Restriction Request:
You can request restriction of processing in specific scenarios, such as data accuracy verification or legal claim establishment.

9.6. Data Transfer Request:
You have the right to request the transfer of your personal data to you or to a third party in a structured, commonly used, machine-readable format.

9.7. Submission of Requests:
Complete personal data requests via email to [email protected] using your registered email address.

9.8. Response Time:
We aim to respond to requests within 7 business days, with potential delays for complex or multiple requests.

10. Miscellaneous

10.1. Security Systems Breach Notification:
In the event of a security system breach, Paynamic will make efforts to electronically notify affected parties, with a potential notice posted on the website.

10.2. High-Risk Data Breach Notification:
If a personal data breach poses a high risk to users' rights and freedoms, Paynamic will promptly inform affected individuals.

10.3. Business Changes and Data Transfer:
In cases of acquisition, merger, or control change, Paynamic reserves the right to transfer user information. Users will be notified before any transfer during a merger, acquisition, or sale of assets. In bankruptcy or similar circumstances, control over personal information may be limited.

11. Changes to Privacy Policy

This Privacy Policy may be updated periodically without prior notice. The latest version will be effective at https://paynamic.io and govern the processing of personal data.

12. Contact Us

For any inquiries about this Privacy Policy, please contact us at [email protected].