Privacy Policy

Last updated on December 15, 2024

1. Introduction

As part of our normal daily business operations, we collect personal information from our clients and prospective clients in order to provide them with our products and services, and ensure that we can meet their needs when providing these products and services, including providing information as part of the service.

Your privacy is of utmost importance to us and it is our policy to safeguard and respect the confidentiality of information and the privacy of individuals. This Privacy Policy (hereinafter as 'Privacy Policy', 'Privacy Notice', 'Policy', or 'Notice', as used interchangeably) sets out how fiat services provided by GVV Technology Limited, collects, uses and manages the personal information we receive from you, or a third party, in connection with our provision of services to you have requested for or which we collect from your use of our services and/or our website.

The Privacy Notice also informs you of your rights with respect to the processing of your personal information. Use of the words "The Company" "we," "us," or "our" refer to GVV Technology Limited. Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment.

2. How do we protect personal information?

The Company respects the privacy of any user who access its website and it is therefore committed to taking reasonable steps to safeguard any existing or prospective clients, applicants and website visitors. The Company keeps any personal data of its clients and its potential clients in accordance with the applicable privacy and data protection laws and regulations.

We have the necessary and appropriate technical and organisational measures and procedures in place to ensure that your information remains secure at all times in line with the industry standard. We conduct periodic training and raise awareness for all our employees to the importance of maintaining, safeguarding and respecting your personal information and privacy.

We regard breaches of individuals' privacy very seriously and would impose appropriate disciplinary measures, including dismissal from employment. We have also appointed appropriate personnel to ensure that our Company manages and processes your personal information in compliance with the applicable privacy and data protection laws and regulations, and in accordance with this Privacy Notice.

3. Information we may collect about you

In order to open an account with us, you must first complete and submit a "create account" form to us by completing the required information. By completing this form, you are deemed to consent to disclose personal information in order to enable the Company to assess your application and comply with the relevant laws (including their regulations).

The information that we collect from you is as follows (on an 'as-applicable' basis):

  • Full name, current residential address and contact details (e.g. email address, telephone number, etc.)
  • Date of birth, place of birth, gender, citizenship
  • Bank account information, credit card details, including details about your source of funds, assets and liabilities, and Office of Foreign Assets Control (OFAC) information
  • Trading account balances, trading activity, your inquiries and our responses
  • Verification information, which includes information necessary to verify your identity such as a passport, driver's licence or Government-issued identity card
  • Other Personal Information or commercial and/or identification information

4. Disclosure of your personal information

The Company would not disclose any of its clients' confidential information to a third party, except:

  • To the extent that it is required to do so pursuant to any applicable laws, rules or regulations
  • If there is a duty to disclose
  • If our legitimate business interests require disclosure
  • In line with our Terms of Service
  • At your request or with your consent or to those described in this Privacy Notice

The Company would endeavour to make such disclosures on a "need-to-know" basis, unless otherwise instructed by a regulatory authority. Under such circumstances, the Company would notify the third party regarding the confidential nature of any such information.

5. Where we store your personal data

Our operations are supported by a network of computers, servers, and other infrastructure and information technology, including, but not limited to, third-party service providers. We and our third-party service providers and business partners store and process your personal data in, including, but not limited to, the European Union (including Lithuania) and the United Kingdom.

6. Transfers of personal information outside of the European Economic Area (EEA) and the United Kingdom (UK)

We may transfer your personal information outside the EEA and UK to other Company subsidiaries, service providers and business partners (i.e Data Processors) who are engaged on our behalf. To the extent that we transfer your personal information outside of the EEA and UK, we would ensure that the transfer is lawful and that any such Data Processor in these jurisdictions are obliged to comply with the applicable European Union (EU) General Data Protection Regulation and the UK Data Protection Act 2018.

If transfers of personal information are processed in the US, we may in some cases rely on standard contractual clauses.

7. Transfers of Personal Information outside of your country

By using our products and services, you consent to your Personal Data being transferred to other countries, including countries that have differing levels of privacy and data protection laws than your country. In all such transfers, we would protect your personal information as described in this Privacy Notice, and ensure that appropriate information sharing contractual agreements are in place.

8. Privacy when using multi-currency trading

Your multi-currency trading activities may be recorded on secure electronic systems, intended to maintain accurate transaction records across our trading platform.

Our trading systems maintain comprehensive records for regulatory compliance and security purposes. All transaction data is protected by our privacy policies and security measures. As these systems are operated by us and our affiliates, we maintain full control over the security and privacy of your trading information.

9. Data Retention

Safeguarding the privacy of your personal information is of utmost importance to us, whether you interact with us personally, by phone, by email, over the internet or any other electronic medium.

We would hold personal information, for as long as we have a business relationship with you, in secure computer storage facilities, and we take the reasonable and necessary measures to protect the personal information we hold from misuse, loss, unauthorised access, modification or disclosure.

When we consider that personal information is no longer necessary for the purpose for which it was collected, we would remove any details that would identify you or we would securely destroy the records. However, we may need to maintain records for a significant period of time (after you cease being our client).

10. Cookies

When you use our products and services, we may make use of the standard practice of placing tiny data files called cookies, flash cookies, pixel tags, or other tracking tools (herein, "Cookies") on your computer or other devices used when engaging with us. We use Cookies to help us recognize you as a customer, collect information about your use of our products and services, to better customize our services and content for you, and to collect information about your computer or other access devices to ensure our compliance with our BSA and AML obligations.

11. Your rights regarding your personal information

The rights that are available to you in relation to the personal information we hold about you are outlined below:

  • Information Access: If you ask us, we would confirm whether we are processing your personal information and, if so, what information we process and, if requested, provide you with a copy of that information within 30 days from the date of your request.
  • Rectification: It is important to us that your personal information is up to date. We would take all reasonable steps to make sure that your personal information remains accurate, complete and up-to-date.
  • Erasure: You can ask us to delete or remove your personal information in certain circumstances such as if we no longer need it, provided that we have no legal obligation to retain that data.
  • Processing restrictions: You can ask us to block or suppress the processing of your personal information in certain circumstances such as if you contest the accuracy of that personal information or object to us processing it.
  • Data portability: In certain circumstances, you may have the right to request for personal information you have provided us with previously (in a structured, commonly used and machine readable format) and to re-use it elsewhere or request us to transfer this to a third party.
  • Objection: You may request us to stop processing your personal information, and we would do so, if we are relying on our own or someone else's legitimate interests to process your personal information.

12. Changes to this Privacy Notice

Our Privacy Notice is reviewed regularly to ensure that any new obligations and technologies, as well as any changes to our business operations and practices are taken into consideration, as well as that it remains abreast of the changing regulatory environment.

Any personal information we hold would be governed by our most recent Privacy Notice. If we decide to change our Privacy Notice, we would post those changes to this Privacy Notice and other places we deem appropriate.

13. Data Protection Authorities

If you are not satisfied with our response to your complaint, you have the right to submit a complaint with the appropriate governing regulatory body or bodies.

14. Photo Album

App uses the photo album to upload payment receipts and user avatars on our app, and we may need to access your album to select and upload the necessary images. We promise to strictly comply with privacy regulations and only use album access permission during the payment receipt upload. User personal photos and private information will not be stored or shared. We will take all necessary security measures to protect your privacy and data security.