Privacy Policy

This Website Privacy Policy (“Privacy Policy”) covers the web sites (“Web Sites”) and services (“Services”) operated by FinTech Solutions Ltd (“Fintech Solutions” or “we” or “us” or “our”), including but not limited to www.skaleapps.io, www.forexwebdesign.com and the services provided by us through our products, the Skale Fintech CRM Platform.
This Privacy Policy describes the types of information that we collect, what we do with it, how we protect it, and if and when we disclose it to third parties.
This Privacy Policy is a part of and subject to the Fintech Solutions Terms of Service (“TOS”). Accordingly, when you enter into the TOS, you agree that you have read, understand, and agree that we can collect, use, and disclose your information in accordance with this Privacy Policy. If you do not agree or are not comfortable with any part of this Privacy Policy, you should not agree to the TOS (including this Privacy Policy) and you may not use the Web Sites or our Services.
Additional information about Fintech Solutions’ Data Privacy and Data Security practices, including Fintech Solutions’ commitments with regard to the General Data Protection Regulation (GDPR), can be found at the bottom of this page.

Information Gathering, Processing and Usage

In connection with operation of the Web Sites and providing the Services to you, we may collect the following types of user information (“Information”):

  • Personal Information. We collect personal information (“Personal Information”) from you. This Personal Information is used for billing purposes, account management purposes and for you to utilize the features of the Web Sites to which you have purchased access. Examples of Personal Information we might collect include but are not limited to: first name, last name, email address, mailing address, etc. We also collect Personal Information provided to us via any contact forms you have completed (whether on the Web Sites or via social media), and any emails you send to us.
  • Browsing Information. We collect information about your computer hardware and software and browsing activity.
  • Customer Information. Through the use of the Services, you may enter and upload information relating to your customers and leads (“Customer Information”) which might include, but not be limited to, first name, last name, email address, mailing address, KYC information, financial information, etc.

We collect and process this Information to contact you, for billing purposes, to identify you when you use our Services and to enable you to use our Services.
As a general rule, we never disclose Information to third parties. The only circumstance in which we may disclose Information would be to prevent an emergency, to protect or enforce our rights, to protect or enforce the rights of a third party, or as required or permitted by law (including, without limitation, to comply with a subpoena or court order).
The basis for the processing of your Personal Information is consent (when we contact you regarding our services or process Customer Information on your behalf in order to provide the Services) or legitimate interest (where we use your Personal Information in an emergency, to enforce our rights or as required under law).
We will only access Customer Information when we are required to provide support services to you and for limited purpose only.

Cookies

To enhance your experience on our Web Sites, many of our web pages use “cookies”. Cookies are bits of electronic information that a web site can transfer to a visitor’s hard drive to help tailor and keep records of his or her visit. Cookies are required to use many Fintech Solutions’ Services. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access some of Fintech Solutions’ Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Web Sites. If you proceed with using our Web Sites without deactivating cookies through your browser, you are deemed to have accepted our use of cookies.

Analytics

We may use third-party service providers to monitor and analyze the use of our Web Sites.
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Web Sites. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Web Sites available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Web Beacons

Pages of our Web Sites or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). You are always free to block, delete, or disable these technologies if your browser.

Protecting Personal Information

We understand the importance of safeguarding your Information. We employ administrative, physical, and electronic measures designed to protect your Information from unauthorized access. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedom. Despite our efforts, we cannot guarantee the security of your Information. Accordingly, we assume no liability for any disclosure of data due to errors in transmission, unauthorized third-party access or other acts of third parties, or acts or omissions beyond our reasonable control.

Children’s Privacy

We are committed to protecting the privacy of children. Our solutions are not intended for anyone under the age of 18. If you are under 18, do not use or provide any information on or through our solutions. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you are a parent or guardian or otherwise believe we might have any information from or about a child under 18, please contact us so that we can delete the child’s information. Our services will never knowingly accept, collect, maintain or use any information from a child under the age of 18. If a child whom we know to be under the age of 18 sends Information to us online, we will only use that information to respond directly to that child or notify parents.

Fintech Solutions Data Privacy & Data Security Statement

This Data Privacy & Data Security Statement (the “Statement”), is provided by Fintech Solutions Ltd. (“Fintech Solutions”) to its Clients (each, a “Client”) and to users of Fintech Solutions’ Services affiliated with the Clients (“Users”). This Statement describes Fintech Solutions’ commitments with regard to data privacy and data security. Fintech Solutions may update this Statement from time to time. Updated versions will be published on Fintech Solutions’ websites.
1. Definitions

  • “Authorized Persons” means Fintech Solutions’ employees, agents, and contractors that have a need to know or otherwise access User Data to enable Fintech Solutions to provide the Services.
  • “Controller” means a controller as defined under the GDPR.
  • “Data Protection Laws” means all international, federal, national and state privacy and data protection laws and regulations to the extent applicable to Fintech Solutions and the Services.
  • “Data Breach” means any loss or unauthorized access, acquisition, theft, destruction, disclosure or use of User Data that occurs while such User Data is in the possession of or under the control of Fintech Solutions.
  • “GDPR” means the EU General Data Protection Regulation 2016/679.
  • “Personal Data” means information relating to an identified or identifiable natural person. An identifiable natural person is a natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • “Process” or “Processing” means any operation or set of operations that are performed upon User Data, whether or not by automatic means, such as collection, accessing, processing, use, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, transmittal, alignment or combination, blocking, erasure, destruction or otherwise used as set out in the applicable Data Protection Laws.
  • “Processor” means a processor as defined under the GDPR.
  • “Services” means Fintech Solutions’ services, solutions and products.
  • “Sub-Processor” shall mean an entity engaged by Fintech Solutions to assist it in Processing the User Data in fulfillment of its obligations with regard to the Services.
  • “Third Party” is any person or entity other than Fintech Solutions, Client and Client’s Users.
  • “User Data” means all data relating to a User that is provided to Fintech Solutions by Client or User. User Data may include Personal Data.

2. Data Privacy

  • 2.1. Compliance with Laws. Fintech Solutions is committed to complying with its obligations under all Data Protection Laws. For purposes of the GDPR, Client is considered the Controller and Fintech Solutions is its Processor; if Client is considered a Processor for purposes of the GDPR, then Fintech Solutions is considered its Sub-Processor.
  • 2.2. Distribution of User Data. Users should provide Fintech Solutions only with Personal Data that is requested by Fintech Solutions or that is otherwise necessary for Fintech Solutions to provide the Services. Fintech Solutions is not responsible for any other Personal Data. Client will not provide Fintech Solutions with Personal Data unless Client has obtained all required consents from Users. Fintech Solutions shall be entitled to assume that Client has obtain such required consents by Users by virtue the provision of such User Data to Fintech Solutions by Client.
  • 2.3. Limitations on Use of Personal Data. Fintech Solutions shall not Process User Data other than for the purposes specified by Users and the Client. Fintech Solutions shall not Process User Data for the benefit of any Third Party. Fintech Solutions shall access only the User Data that it needs to perform the Services (i.e., no more than necessary). Fintech Solutions will not store User Data longer than necessary to achieve the permitted purposes specified by User.
  • 2.4. Restrictions. Except with a User’s prior, written approval, on a case-by-case basis, Fintech Solutions will not: (a) use User Data other than as necessary for Fintech Solutions to provide the Services, (b) disclose, sell, assign, lease or otherwise provide User Data to Third Parties (other than to its affiliates or Sub-Processors) except to the extent required or permitted by Data Protection Laws, or (c) merge User Data with other data, modify or commercially exploit any User Data.
  • 2.5. Sensitive Personal Data. Clients and Users are advised never to provide Fintech Solutions with Sensitive Personal Data. “Sensitive Personal Data” means (a) information that reveals a natural person’s racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, (b) information or data concerning a natural person’s health or sex life or sexual orientation; or (c) genetic data or biometric data about a natural person.

3. Sub-Processors

  • Fintech Solutions may engage Sub-Processors in connection with the provision of the Services, provided, however, that Fintech Solutions may not provide a Sub-Processor with access to User Data unless the Sub-Processor has: (i) a business need to know / access the relevant User Data, as necessary for the purposes of the Services; (ii) signed a written obligation of confidentiality or are under professional obligations of confidentiality; and (iii) implemented technical, operational, physical, and organization safeguards to protect User Data against accidental or unlawful destruction or alteration and unauthorized disclosure or access.

4. Data Subject Rights; Cooperation

  • Fintech Solutions shall use commercially reasonable efforts to cooperate and assist with a User’s exercise of his/her rights under applicable Data Protection Laws with respect to Personal Data Processed by Fintech Solutions, including, without limitation, the right to be forgotten, the right to data portability, and the right to access data under the GDPR.

5. Return or Destruction of User Data

  • Upon the written request of a User, Fintech Solutions will return User Data to the User in a commonly readable format or securely delete User Data as soon as reasonably practicable. However, if Fintech Solutions is required by law to retain User Data or if User Data is stored in a manner such that it cannot readily be returned or destroyed without affecting other data, then Fintech Solutions will continue to protect such User Data in accordance with this Statement and limit any use to the purposes of such retention.

6. Data Security

  •  6.1. Security Program Requirements. Fintech Solutions will maintain a security program that contains administrative, technical, and physical safeguards appropriate to the complexity, nature, and scope of its activities. Fintech Solutions’ security program shall be designed to protect the security and confidentiality of User Data against unlawful or accidental access to, or unauthorized processing, disclosure, destruction, damage or loss of User Data. At a minimum, Fintech Solutions’ security program shall include: (a) limiting access of User Data to Authorized Persons and only to provide support services to the Client; (b) implementing network, application, database, and platform security; (c) means for securing information transmission, storage, and disposal within Fintech Solutions’ possession or control; (d) means for encrypting User Data stored on media within Fintech Solutions’ possession or control by using modern acceptable cyphers and key lengths, including backup media; (e) means for encrypting User Data transmitted by Fintech Solutions over public or wireless networks by using modern acceptable cyphers and key lengths; and (f) means for keeping firewalls, routers, servers, personal computers, and all other resources current with appropriate security-specific system patches.
  • 6.2. Regular Reviews. Fintech Solutions shall ensure that its security measures are regularly reviewed and revised to address evolving threats and vulnerabilities.

7. Data Breach Procedures

  • 7.1. Notification. Fintech Solutions shall notify Client and any affected User of any Data Breach as soon as practicable and without undue delay after becoming aware of it. Such notification shall at a minimum: (i) describe the nature of the Data Breach, the categories and numbers of Users concerned, and the categories and numbers of Personal Data records concerned; (ii) communicate the name and contact details of Fintech Solutions’ data protection officer or other relevant contact from whom more information may be obtained; and (iii) describe the measures taken or proposed to be taken to address the Data Breach.
  • 7.2. Remedial Actions. In the event of a Data Breach for which Fintech Solutions is responsible, Fintech Solutions will use commercially reasonable efforts to: (a) remedy the Data Breach condition, investigate, document, restore the Services, and undertake required response activities; (b) provide regular status reports to Client on Data Breach response activities; (c) assist Client with the coordination of media, law enforcement, or other Data Breach notifications; and (d) assist and cooperate with Client in its Data Breach response efforts.

8. Cross-Border Transfers

  • 8.1. Location. Fintech Solutions systems and Fintech Solutions’ Processing of User Data will occur within the following jurisdictions: Israel and Ireland (the “Processing Jurisdictions”). Fintech Solutions will not transfer any User Data outside of the Processing Jurisdictions except as directed by or with the consent of Client and/or User.
  • 8.2. Sub-Processors. Before providing User Data of a European citizen to Sub-Processors, Fintech Solutions will use commercially reasonable efforts to ensure that the Sub-Processors will either be certified under the EU-US Privacy Shield or that the Sub-Processors execute EU-prescribed Standard Contractual Clauses.

Privacy Policy Updates

This Privacy Policy may be updated periodically and without prior notice to reflect changes in our online information practices. We will post a prominent notice on this Web Site to notify you of any significant changes to our Privacy Policy and indicate at the bottom of the policy when it was most recently updated.

Questions

Any questions about this Privacy Policy should be addressed to our Help Desk at info@skaleapps.io .