This is the Privacy Statement of SafeNed B.V., a company incorporated in The Netherlands, whose registered number is 58905413, with a registered office located at Tesselschadestraat 12, 1054 ET Amsterdam, The Netherlands and SafeNed Limited, a company incorporated in England and Wales, whose registered number is 09220888, with a registered office located at 36 Old Jewry, 3rd Floor, Becket House, EC2R 8DD, London, United Kingdom (together “SafeNed”). It applies to all subsidiaries and branches of SafeNed to the extent that they process personal data. SafeNed is supervised by the Dutch Central Bank and the Financial Conduct Authority.
SafeNed treats personal data which it receives through its websites, portals and any other means with due care and is dedicated to safeguarding any personal data it receives. SafeNed is bound by the General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”) and the Data Protection Act 2018. This Privacy Statement is designed to inform you about the type of information that SafeNed collects when using our website and our application and the purposes for which this information is being processed, used, maintained and disclosed (together the “Services”).
This Privacy Statement aims to explain in a simple and transparent way what personal data we gather about you and how we process it. It applies to the following persons:
Personal data refers to any information that tells us something about you or that we can link to you. SafeNed processes any information we receive from you, including personal and financial information you provide to us including when you or your business: enquire or make an application for SafeNed’s services, register to use and/or use any of our services and when you communicate with us through e-mail, SMS, WhatsApp, a website or portal, telephone or any other electronic means. Such information may include your: • name including first name and family name, nationality, place of birth, date of birth, street name, street number, street number suffix, postal code, city, country of residence, phone number, e-mail address, gender, photograph, document type, ID document (picture), document number, issue date, expiration date, geolocation and a selfie.
SafeNed processes your personal data in accordance with the GDPR in the event at least one of the following applies:
We do not record sensitive data relating to your health, ethnicity, religious or political beliefs unless it is strictly necessary. When we do it is limited to specific circumstances.
We only use your personal data for legitimate business reasons. This includes:
Whenever we share personal data internally or with third parties in other countries, we ensure the necessary safeguards are in place to protect it. For this, SafeNed relies on: • EU Model clauses, which are standardised contractual clauses used in agreements with service providers to ensure personal data transferred outside of the European Economic Area complies with EU data protection law.
Privacy Shield framework that protects personal data transferred to the United States. To be able to offer you the best possible services and remain competitive in our business, we share certain data both internally as well as outside of the SafeNed Group. This includes:
SafeNed entities We transfer data across SafeNed businesses and branches for operational, regulatory or reporting purposes, for example to comply with certain laws, secure IT systems or provide certain services (see section 4 (What we do with your personal data). We may also transfer data to centralised storage systems or to process it globally for more efficiency.
Government authorities To comply with our regulatory obligations, we may disclose data to the relevant authorities, for example to counter terrorism and prevent money laundering. In some cases, we are obliged by law to share your data with external parties, including:
Third party service providers When we use other service providers we only share personal data that is required for the particular task we involve the service provider for. Service providers support us with activities like:
Business transfers The SafeNed Group may buy or sell business units or affiliates. In such circumstances, we may transfer customer information as a business asset. Without limiting the foregoing, if our business enters into a joint venture with or is sold to or merged with another business entity, your information may be disclosed to our new business partners or owners.
With your permission Your information may also be used for other purposes for which you give your specific permission, or when required by law or where permitted under the terms of the laws of the relevant jurisdiction.
What are cookies? Many of the websites you view place small text files on your computer. This enables the site to recognize your computer each time you visit. We call these text files ‘cookies’. A cookie is sent by a web server to a web browser that enables the server to collect information back from the browser.
Which cookies are used and what do they do? This website uses the following cookies:
1. Functional cookies These cookies may store your browser name, the type of computer and technical information about your means of connection to this website, such as the operating system and the Internet Service Providers utilized and other similar information. This information is used to technically facilitate the navigation and use of this website. In addition, functional cookies may be used to store personal settings, such as language, or to remember your information for next visits if so requested.
2. Third-party/social media cookies This website contains cookies from third-party websites, mainly social media cookies. When placed on your computer, they automatically activate handy extras, for example, a Facebook ‘like’ button or a Twitter messaging option. These cookies inform our website whether you are logged into such social media and they also enable you to share parts of this website on social media. When visiting this website, SafeNed will ask for your consent to use these cookies.
3. Do you object to cookies? Cookies generally process your IP-address, but they do not save your personal information like e-mail address or phone number. If you do not want to have cookies stored on your computer or want to remove cookies that have already been stored, you can arrange this via your browser settings. You can find more information concerning the removal of cookies on the website all about cookies.
We respect your rights as a customer to determine how your personal information is used. These rights include:
Right to access information You have the right to ask us for an overview of your personal data that we process.
Right to rectification If your personal data is incorrect, you have the right ask us to rectify it. If we shared data about you with a third party that is later corrected, we will also notify that party.
Right to object to processing You can object to SafeNed using your personal data for its own legitimate interests. There is a list of contact details at the end of this Privacy Statement. We will consider your objection and whether processing your information has any undue impact on you that requires us to stop doing so.
You can also object to receiving personalised commercial messages from us. You cannot object to us processing your personal data if we are legally required to do so, even if you have opted out of receiving personalised commercial messages.
Right to object to automated decisions We sometimes use systems to make automated decisions based on your personal information if this is necessary to fulfil a contract with you, or if you gave us consent to do so. You have the right to object to such automated decisions (for example requiring a new passport copy if the one we have on file for you as representative of your company is no longer valid) and ask for an actual person to make the decision instead.
Right to restrict processing You have the right to ask us to restrict using your personal data if:
Right to data portability You have the right to ask us to transfer your personal data directly to you or to another company. This applies to personal data we process by automated means and with your consent or on the basis of a contract with you. Where technically feasible, we will transfer your personal data.
Right to erasure You may ask us to erase your personal data if:
Right to complain Should you for any reason be unhappy with the way SafeNed threats your personal data, you can file a complaint with SafeNed’s Compliance Officer via email@example.com You can also contact the data protection authority in your country.
Exercising your rights How you can exercise your rights depends on the type personal data SafeNed processes. It could be through our website, by fulfilling our KYC obligations or by processing a transaction. We aim to respond to your request as quickly as possible. In certain cases, we may deny your request. If it’s legally permitted, we will let you know within a reasonable timeframe why we denied it. If you want to exercise your rights or submit a complaint, please contact us via the e-mail address provided below.
There is certain information that we must know about you so that we can commence and execute our duties as a payment institution and fulfil our associated obligations. There is also information that we are legally obliged to collect. Without this data we may for example not be able to enter into an agreement with you.
We apply an internal framework of policies and minimum standards to keep your data safe. These policies and standards are periodically updated to keep them up to date with regulations and market developments. More specifically and in accordance with the law, we take appropriate technical and organisational measures (policies and procedures, IT security etc.) to ensure the confidentiality and integrity of your personal data and the way it’s processed.
In addition, SafeNed employees are subject to confidentiality and may not disclose your personal data unlawfully or unnecessarily.
Unfortunately, the transmission of information via the internet in general is not always completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. We do our utmost to protect your data, but there are certain things you can do too:
SafeNed will store and process your personal data only as long as it is necessary to perform our obligations under the agreement with you or as long as the law requires to store it. Therefore, we keep your personal data as long as you are using our Services and for seven (7) years after termination of the agreement to comply with the law. There may be circumstances (e.g. fraud or anti-money laundering) whereby we are obliged to store your personal data even longer.
If you want to know more about SafeNed’s data policies and how we use your personal data, you can send us an e-mail at the following dedicated e-mail address: firstname.lastname@example.org