Thank you for entrusting Finstream OU (hereinafter referred to as “us” or “we” or similar) the owner of https://broxus.com (the Website) with your personal information. Holding on to your private information is a serious responsibility, and we want you to know how we’re handling it. Your privacy is important to us. It is Finstream OU’s policy to respect your privacy regarding any information we may collect from you across our Website, https://broxus.com, and other sites we own and operate.
“User Personal Information” is any information about one of our Users which could, alone or together with other information, personally identify them or otherwise be reasonably linked or connected with them. Information such as a username and password, an email address, a real name, an Internet protocol (IP) address and a photo are examples of “User Personal Information”.
User Personal Information does not include aggregated, non-personally identifying information that does not identify a User or cannot otherwise be reasonably linked or connected with them. We may use such aggregated, non-personally identifying information for research purposes and to operate, analyze, improve, and optimize our Website and Service.
The following applies to any information you provide to us, for example during any registration or ordering or confirmation of details process:
You authorize us to use, store or otherwise process any personal information which relates to and identifies you, including but not limited to your name and address, to the extent reasonably necessary to provide the Services which are available through our Website by us or our sub-contractors. Unless you have indicated on the registration form that you do not wish to receive direct marketing material, your personal details will be included on a database compiled for direct marketing purposes. From time to time you may receive direct marketing information, either from us or from the third parties.
You must ensure that the User Personal Information you provide is accurate and complete and that all ordering or contact details contain your correct name, e-mail address and other requested details.
If you like to review or modify any part of your User Personal Information or you have not indicated that you do not wish to receive direct marketing material, but change your mind about this you should notify our Data Protection Officer at [email protected]. As soon as this is reasonably practicable, we will remove your name from the direct marketing database.
We reserve the right to charge a fee to deal with any request to review, update or delete the Personal Information.
If you’re accessing our Service or Website, we automatically collect the same basic information that most services collect, subject, where necessary, to your consent. This includes information about how you use the Service, such as the pages you view, the referring site, your IP address and session information, and the date and time of each request. We collect this information from every visitor to the Website, whether they have an Account or not. This information may include User Personal information.
1. Information we collect
When you visit our Website, our servers may automatically log the standard data provided by your web browser.
- your computer’s Internet Protocol (IP) address,
- your browser type and version,
- the pages you visit,
- the time and date of your visit,
- the time spent on each page,
- and other details.
We may also collect data about the device you’re using to access our website.
- This data includes:
- the device type;
- operating system;
- unique device identifiers;
- device settings;
- and geo-location data.
What we collect can depend on the individual settings of your device and software. We recommend checking the policies of your device manufacturer or software provider to learn what information they make available to us.
We may ask for personal information, such as your:
- first name and last name;
- email address;
- social media profiles;
- date of birth;
- phone/mobile number;
- home/Mailing address including state, province, city\town, postal code;
- website address;
- payment information including bank card number;
- driver’s licence details;
- passport number.
We require some basic information at the time of account creation. When you create your own username and password, we ask you for a valid email address. If you sign on and buy a Product on the Website, we collect your full name, address, and credit card information or PayPal information. Please note, we do not process or store your credit card information or other payment information, but our third-party payment processor does.
Business data refers to data that accumulates over the normal course of operation on our platform. This includes:
- transaction records;
- stored files;
- user profiles;
- analytics data and other metrics;
- as well as other types of information, created or generated, as users interact with our services.
If you have an Account with us and buy any Products from the Website, we automatically collect certain information about your transactions on the Service, such as the date, time, and amount charged. This information is also available to you and may help you in your using the Website.
2. Information we do not collect
We do not intentionally collect Sensitive Personal Information, such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation. If you choose to store any Sensitive Personal Information on our servers, you are responsible for complying with any regulatory controls regarding that data. If you are a child under the age of 16, you may not have an Account on the Website. We do not knowingly collect information from or direct any of our content specifically to children under 16. If we learn or have reason to suspect that you are a User who is under the age of 16, we will have to close your Account. Please see our Terms of Service Agreement for information about Account termination. Different countries may have different minimum age limits, and if you are below the minimum age for providing consent for data collection in your country, you may not have an Account on the Site.
3. Legal bases for processing
To the extent that our processing of your User Personal Information is subject to certain international laws (including, but not limited to, the European Union’s General Data Protection Regulation (GDPR)), we are required to notify you about the legal basis on which we process User Personal Information.
We will process your User Personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so. These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:
- it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
- it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
- you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or we need to process your data to comply with a legal obligation.
Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place). We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.
If you would like to request deletion of data we process on the basis of consent or if you object to our processing of personal information, please use our “Сontact us” form.
4. Collection and use of information
We may collect, hold, use and disclose information for the following purposes and User Personal information will not be further processed in a manner that is incompatible with these purposes:
- to provide you with our platform’s core features;
- to process any transactional or ongoing payments;
- to enable you to access and use our website, associated applications and associated social media platforms;
- to contact and communicate with you;
- for internal record keeping and administrative purposes;
- for analytics, market research and business development, including to operate and improve our website, associated applications and associated social media platforms;
- for advertising and marketing, including to send you promotional information about our products and services and information about third parties that we consider may be of interest to you;
- and to comply with our legal obligations and resolve any disputes that we may have.
In more details:
- We use your Registration Information to create your account, and to provide you the Service.
- We use your payment information to provide you with the possibility to use Products on the Website or any other paid service you request.
- We use your User Personal Information, specifically your username, to identify you on our Website.
- We use your profile Information to fill out your Account profile.
- We use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay.
- We use User Personal Information to respond to support requests.
- We use User Personal Information and other data to make recommendations for you, such as to suggest Products or Services that may be of interest for you. We learn from your public behavior on the Site — such as the Products you view and buy — to determine your interests, and we recommend other Products that you may use. These recommendations are automated decisions, but they have no legal impact on your rights.
- We may use User Personal Information to invite you to take part in surveys, beta programs, or other research projects, subject, where necessary, to your consent.
- We use Usage Information and Device Information to better understand how our Users use the Site and to improve our Website and Service.
- We may use your User Personal Information if it is necessary for security purposes or to investigate possible fraud or attempts to harm the Site or our Users.
- We may use your User Personal Information to comply with our legal obligations, protect our intellectual property, and enforce our Terms of Service.
5. Disclosure of personal information to third parties
We may disclose personal information to:
- third party service providers for the purpose of enabling them to provide their services, including (without limitation) IT service providers, data storage, hosting and server providers, ad networks, analytics, error loggers, debt collectors, maintenance or problem-solving providers, marketing or advertising providers, professional advisors and payment systems operators;
- our employees, contractors and/or related entities;
- sponsors or promoters of any competition we run;
- courts, tribunals, regulatory authorities and law enforcement officers, as required by law, in connection with any actual or prospective legal proceedings, or in order to establish, exercise or defend our legal rights;
- third parties, including agents or sub-contractors, who assist us in providing information, products, services or direct marketing to you;
- and third parties to collect and process data.
We strive for transparency in complying with legal process and legal obligations. Unless prevented from doing so by law or court order, or in rare, exigent circumstances, we make a reasonable effort to notify users of any legally compelled or required disclosure of their information. We may disclose User Personal Information or other information we collect about you to law enforcement if required in response to a valid subpoena, court order, search warrant, a similar government order, or when we believe in good faith that disclosure is necessary to comply with our legal obligations, to protect our property or rights, or those of third parties or the public at large.
We share certain aggregated, non-personally identifying information with others about how our users, collectively, use the Site, buy Products or how our users respond to our other offerings.
We do not sell your User Personal Information for monetary or other consideration.
6. International transfers of personal information
The personal information we collect is stored and processed in Belgium, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties. We will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means. Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.
7. Your rights and controlling your personal information
You have the following right with respect to information we collect and use on the Website:
- the right to be informed;
- the right of access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to data portability;
- the right to object;
- rights related to automated decision making and profiling.
Choice and consent:
You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it. Information from third parties:
You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.
Access and data portability:
You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.
If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.
Notification of data breaches:
We will comply with laws applicable to us in respect of any data breach.
If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.
To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.
Deletion of data:
After an account has been deleted, certain data, such as history of transactions and bought Products, will remain. However, we will delete or de-identify your User Personal Information, including your username and email address, from the author field of issues, pull requests, and comments by associating them with a ghost user.
That said, the email address you have supplied via registration procedure will always be associated with your transactions in the Site. If you choose to make your email address private, you should also update your settings. We are unable to change or delete data in the Site history — the Site software is designed to maintain a record — but we do enable you to control what information you put in that record.
We use “cookies” to collect information about you and your activity across our Website.
9. Business transfers
If we or our assets are acquired, or in the unlikely event that we go out of business or enter bankruptcy, we would include data among the assets transferred to any parties who acquire us. You acknowledge that such transfers may occur, and that any parties who acquire us may continue to use your personal information according to this policy.
We may share User Personal Information if we are involved in a merger, sale, or acquisition of corporate entities or business units. If any such change of ownership happens, we will ensure that it is under terms that preserve the confidentiality of User Personal Information, and we will notify you on our Site or by email before any transfer of your User Personal Information. The organization receiving any User Personal Information will have to honor any promises we made in our Privacy Statement or Terms of Service.
10. Security measures
We take all measures reasonably necessary to protect User Personal Information from unauthorized access, alteration, or destruction; maintain data accuracy; and help ensure the appropriate use of User Personal Information.
We enforce a written security information program. Our program:
- aligns with industry recognized frameworks;
- includes security safeguards reasonably designed to protect the confidentiality, integrity, availability, and resilience of our Users’ data;
- is appropriate to the nature, size, and complexity of our business operations;
- includes incident response and data breach notification processes;
- and complies with applicable information security-related laws and regulations in the geographic regions where we do our business.
In the event of a data breach that affects your User Personal Information, we will act promptly to mitigate the impact of a breach and notify any affected Users without undue delay.
Transmission of data on the Site is encrypted using SSH, HTTPS (TLS). We manage our own cages and racks at special data centers with high level of physical and network security, and when data is stored with a third-party storage provider, it is encrypted.
No method of transmission, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee its absolute security. For more information, see our security disclosures.
11. Communication with the User
We use your email address to communicate with you, if you’ve said that’s okay, and only for the reasons you’ve said that’s okay. For example, if you contact our Support team with a request, we respond to you via email. You have a lot of control over how your email address is used and shared on and through our Site. You may manage your communication preferences in your user profile.
By design, the Site software associates many actions with a User’s email address, such as special messages and history of purchases. We are not able to change many aspects of our Software. We set current Users’ email address private by default, but Users may need to update their settings.
Depending on your email settings, we may occasionally send notification emails about changes in Products, new Services, Products and features, requests for feedback, important policy changes, or to offer customer support. We also send marketing emails, based on your choices and in accordance with applicable laws and regulations. There’s an “unsubscribe” link located at the bottom of each of the marketing emails we send you. Please note that you cannot opt out of receiving important communications from us, such as emails from our Support team or system emails, but you can configure your notifications settings in your profile to opt out of other communications.
Our emails may contain a pixel tag, which is a small, clear image that can tell us whether or not you have opened an email and what your IP address is. We use this pixel tag to make our email more effective for you and to make sure we’re not sending you unwanted email.
12. Limits of our policy
Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.
13. Changes to this policy
14. Dispute resolution procedure
If you have concerns about the way we are handling your User Personal Information, please let us know immediately. We want to help. You may contact us using our Telegram chat at https://t.me/broxus_chat. You may also email us directly at [email protected] with the subject line “Privacy Concerns”. We will respond promptly, within 45 days at the latest.
You may also contact our Data Protection Officer directly.
Sergey Shashev, dpo@admin
Data Protection Officer
Sergey Shashev, dpo@admin
In the unlikely event that a dispute arises between you and us regarding our handling of your User Personal Information, we will do our best to resolve it. Additionally, if you are a resident of the EU member state, you have the right to file a complaint with your local supervisory authority, and you might have more options.