Effective date: 2021
When you use Platform available at https://fineadviser.com/ (the “Platform”), we can collect and process the information about you that can directly or indirectly identify you (the “Personal Data”).
- When you use Platform as a website (without registration),
- When you sign up as a user or service provider and use Platform under your account,
- When you send us any request or feedback via relevant forms in Platform or by other means of communication.
Contact Details of Data Controller:
Name: SANTICUM INTERNATIONAL LTD
Address: 174A, Floor 2, Flat 22, 3022, Limassol, Cyprus.
WHAT PERSONAL DATA DO WE COLLECT?
We respect your privacy and aim to limit the Personal Data that we collect from you to the amount which is strictly necessary to fulfil the purposes of processing. Categories of Personal Data that we process can be found in the following section.
HOW DO WE PROCESS YOUR PERSONAL DATA?
We use your Personal Data for the purposes and on the legal bases indicated below:
Your payment information is processed by third-party payment service providers.
We neither use automated decision-making nor refer to the automated profiling.
WHEN CAN WE SHARE YOUR PERSONAL DATA?
We can share your Personal Data with third parties only in the cases listed below:
- For the analytical and advertising purposes we can share a strictly limited amount of data which is necessary for the mentioned purposes with third-parties service providers as described in the section “Cookies and similar technologies”;
- We may have partners who support us in maintaining the Platform (such as technical support and so on). As a rule, by default our partners do not have access to your Personal Data, but they may need it for specific purposes (for example, to resolve your question about interacting with the Platform). In such limited cases, our partners can get access to your Personal Data, but only to the extent strictly necessary for this and only for predetermined purposes;
- In response to valid requests by public authorities (e.g. a court or a government agency) or in other cases when we are required to share your Personal Data by law.
COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small text files sent to your computer or mobile device that enable the Platform and its features to function properly.
Some of our cookies are necessary for certain uses of the Platform. These cookies allow us to make Platform usable by enabling basic functions like page navigation and access to secure areas of the Platform. The Platform cannot function properly without these cookies.
We also use cookie for analytical and advertising purposes. Such cookies collect information on how users use the Platform and the effectiveness of our advertising:
HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain your Personal Data for no longer than it is necessary to fulfill the purposes specified in the section “How do we process your Personal Data” or for a longer period to comply with our legal obligations, resolve disputes, establish and defend legal claims.
The retention period of data processed within the Google Analytics is 14 months. After this period the data will be automatically deleted.
NOTICE FOR MODELS IN PHOTOS OF WORK
Platform allows service providers to upload photos of their work that may feature models, including a photo of the model’s face or other identifiable body parts. Please note that if the service provider was required by applicable law to obtain your consent prior to posting such photo but has not done so, you should contact the service provider and request that such photos be removed. It is the responsibility of the service provider to obtain any required consents before publishing the photo. Nevertheless, if your service provider refuses to remove photo that violates your rights, you can contact us and we will do our best to remove your photo from the Platform.
WHAT RIGHTS DO YOU HAVE?
Under the GDPR you have the following rights in relation to your Personal Data:
- The right of access to your Personal Data meaning that you can receive a copy of the Personal Data that we hold about you, as well as other supplementary information.
- The right to rectification of your Personal Data which is incomplete or inaccurate.
- The right to erasure of your Personal Data meaning that you can ask us to delete or remove your Personal Data in certain circumstances. Note, that we can retain your Personal Data as necessary to comply with our legal obligations or resolve disputes. If we have no grounds to continue processing your Personal Data, we will delete or remove it and notify you about such deletion or removal.
- The right to restrict processing of your Personal Data if (a) the accuracy of the Personal Data is contested by you, (b) the processing is unlawful and you oppose the erasure of the Personal Data, (c) we no longer need the Personal Data for the purposes of the processing, but they are required by you for the establishment, exercise or defence of legal claims, and (d) you have objected to processing pending the verification whether the legitimate grounds override this.
- The right to data portability which allows you to obtain and reuse your Personal Data for your own purposes across different services.
- The right to object to the processing of your Personal Data where we are relying on a legitimate interest and there is something about your particular situation that makes you want to object to the processing on this ground. We will no longer process the Personal Data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
- Right to withdraw consent at any time where we are relying on the consent to process your Personal Data. If we have no other grounds for processing your Personal Data, after you send us a request to withdraw consent, we will stop processing your Personal Data that we were processing under your consent.
- Right to lodge a complaint with a supervisory authority if you consider that our processing of your Personal Data infringes the relevant legislation.
You may exercise these rights by sending a relevant request to the e-mail indicated in the contact details. We will address your request as early as possible and no longer that within one month. Please note that this period may be extended by two further months where necessary, taking into account the complexity and number of the requests. In this case, we will inform you of the extension within one month of receipt of your request and will explain you the reasons for the delay.
We do not knowingly collect or solicit your Personal Data to anyone under the age of 16 or knowingly allow such persons to use the Platform. If you are under the age of 16, please do not provide any Personal Data to us. If we learn that we have collected Personal Data about a child under the age of 16, we will delete that Personal Data as soon as possible. If you believe that we might have any Personal Data from or about a child under the age of 16, please contact us at the e-mail indicated in the contact details.