PRIVACY POLICY

This Privacy Policy, together with our Terms of Use and its other essential parts, governs URNICO's collection, processing and use of your Personal Data. As used in this Privacy Policy, “URNICO“, “we“, “us” or “our” refers to URNICO OU., a company duly incorporated and validly existing under the laws of Estonia under registration number 16001450, having its registered office at J. Vilmsi tn 47, Estonia, Tallinn, Harjumaa 10115, area on the 2-nd floor. URNICO is data controller under this Privacy Policy, which sets out the manner in which company, as data controller, may use your Personal Data.

URNICO has been registered and regulated as data controller with Information Commissioner’s Office (ICO) under the registration number 16001450.

URNICO and its Affiliates undertakes to take maximum efforts in order to protect your privacy. URNICO uses the collected information about you to fulfil its contractual obligations and improve the customer service.

1. WHAT DATA WE COLLECT ABOUT YOU

We may collect and process the following data about you:

Information you give to us

You can provide us with information about yourself by filling in the relevant forms on the Site or by providing us such information by phone, email, during a video conference or in any other manner. This information includes Personal Data which was specified when registering on the Site, when subscribing to our Service, opening an Account and verifying the identity of the Account holder or persons authorized to use it, as well as the payment instruments used by a person, when searching for a product, using any of Services provided by our Site, while placing Orders on our Site, by participating in discussions in Chat or using any other communication functions on our Site, during participation in draws, promotions or surveys, and also when you tell us about problems or issues in the work of the Site.

For example, the data that you provide us, may include your:

    • last name and first name;
      photos and videos that you may send to us for AML/CTF and KYC Policy verification purposes;
      residential address and citizenship;
      gender;
      passport, driver’s license or any other government-issued ID;
      tax residency;
      phone number and email address;
      login information and nickname for accessing URNICO Platform;
      bank details, including account numbers and payment details, and OFAC (Office of Foreign Assets Control) information;
      date and place of birth;
      education;
      work experience and place of work;
      PEP (politically exposed person) status
      sources and amount of income and/or Account Top-Ups;
      information on the status of your accounts opened with banks and/or payment systems;
      inquiries and chat history with URNICO support and other Users of the URNICO Platform via Chat;
      trading balances and activity;
      location and log data information that is generated by your use of URNICO Platform;
      other personal information that may be required by our AML/CTF and KYC Policy compliance obligations.
  • URNICO does not collect nor process sensitive personal Users’ data, such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union memberships, genetic or biometric data, health, sex life or sexual orientation information. However, we caution you that in case you disclose such information in Chat it can be collected by persons or companies URNICO has no control over.

    Information we collect about you

    With regard to each of your visits to our Site and use of our Services we can collect, for example, the following information about you (including automatic collection):

    • technical information, including the internet protocol (IP) address used to connect your computer to the internet, your Account login information, your browser type and its version, time zone setting, browser plug-in types and versions, operating system and platform;
      information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our Site (including date and time); products and Services you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number;
      information about geo-location: we may collect information about real-time location based on information from your device at any time while you download or use our services; we may use this information to optimize your experience
      financial data and information on the use of Services and facilities provided by our Site, including information on implemented transactions and parties thereto, including on transactions, information on the status and Accounts and cash flow on them, accrued commissions, information on Account Top-Ups and Withdrawal of Funds from Accounts opened on our Platform.
  • Information we receive from other sources

    We may receive information about you if you use any of the other sites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Such information may include:

    1. information about financial institutions you employ to perform Account Top-Ups and/or Withdrawal of Funds;
      credit agencies’ confirmation of information that you have provided to us;
      your business partners’ that you collaborate with may provide to us information about your finances or name and address.
  • We may receive information about you if you use any of the other sites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them. Such information may include: information about financial institutions you employ to perform Account Top-Ups and/or Withdrawal of Funds; credit agencies’ confirmation of information that you have provided to us; your business partners’ that you collaborate with may provide to us information about your finances or name and address. Your Personal Data, such as your email and nickname, that you provide to us during registration at the URNICO Platform is stored by us, regardless of whether your registration process is finished or not. The same is applied to your Personal Data during an unfinished AML/CTF and KYC Policy verification process.

    2. USE OF COOKIE FILES

    Please, read our Cookie Policy for information about the use of cookies and in order to manage your consent to such use.

    3. WHY WE USE YOUR PERSONAL DATA

    We are going to use your Personal Data for the following purposes:

    Provision of our Services

    • to fulfil the obligations provided by any contracts concluded with you, as well as to provide you with the information, products and Services that you requested;
      to ensure the security of our Site, our Services, and your Account;
      for administration of our Site and for internal operations, including troubleshooting, data analysis, testing, statistical data collection and for conducting surveys;
      to give you access to the interactive features of the Site in case you wish to use them;
      to support, respond and resolve your complaints and issues related to use of our Services and the capabilities of our Site.
  • Informing you about our products and Services

    • to notify you of other our products and Services, similar to those products or Services that you already purchased or information that you searched for;
      to notify you about changes related to our products and Services.
  • Helping us improve our products and Services

    • to improve our Site and to make sure that our content is most convenient for the operating system of your computer;
      to evaluate and understand the effectiveness of promotional materials that we provide to you and other Users, as well as to provide you with the necessary advertising information;
      to ensure the most effective presentation of the content of our Site to you and use it from your computer.
  • Safeguarding vested interests

    • for risk management;
      for security and control of our IT systems, crime prevention;
      for measuring the use of our Services and products for its further development
      for internal business and research purposes, i.e. communication with you regarding our products and Services;
      for anonymized data analysis via web beacons and pixel tags to ensure our products and Services are relevant for the market we operate in.
  • Assuring legal procedures

    • to respond to law enforcement requests;
      to initiate and respond to legal claims;
      to investigate or settle disputes with
  • Complying with legal regulations

    • to verify and check the identity of Users who open and operate Accounts in order to prevent fraud, deception and other illegal activities;
      to comply with legal requirements of our AML/CTF and KYC Policy as well as other applicable laws and regulations;
      for notification of our Users, e.g. of changes to policies and rules of our Platform.
  • Marketing and third parties

    • to provide you by us, or by third parties appointed by us, with information about products or services that you, in our opinion, might be interested in; if you are already a User, we will contact you via electronic means of communication (via email or SMS) to inform you about products or services similar to those that were in a previous sale or negotiations to sell it to you; if you are a new User and since we allow certain third parties to use your Personal Data, we (or they) will contact you only by electronic means and only upon your consent; if you do not want us to use your Personal Data in this way or transfer it to third parties for marketing purposes, please tick the appropriate box on the form in which we collect your Personal Data.
  • 4. DISCLOSURE OF YOUR PERSONAL DATA

    We may share your personal information with any URNICO Group Member, which means our subsidiaries, affiliates, our ultimate holding company and its subsidiaries.

    We may share your information with selected third parties including:

    • business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
      advertisers and advertising networks that require certain data to select and serve relevant adverts to you and others; we do not disclose information about identifiable individuals to our advertisers, but we may provide them with aggregate information about our Users (for example, we may inform them that 500 females aged under 30 have clicked on their advertisement on any given day); we may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women, living in a particular region); we may make use of the Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to a specific target audience;
      analytics and search engine providers that assist us in the improvement and optimization of our Site.
  • We may also disclose your Personal Data to third parties in the following cases:

    • if we sell or buy any business or assets; Personal Data of Users may be disclosed to a potential buyer or seller;
      if URNICO or all of its assets are purchased by a third party, Personal Data of Users will be transferred as one of the assets’ form;
      if we are required to disclose or transfer Personal Data of the User in accordance with any applicable laws or within the implementation of decisions of the relevant courts, requests of judicial and law-enforcement authorities or we are compelled to force Users to comply with the terms and conditions of the agreements concluded with us;
      in case it is necessary to protect own rights, own property, to guarantee the safety of URNICO, our Users or others. This includes the exchange of information with companies and organizations to prevent fraud and reduce the likelihood of default.
  • 5. SECURITY AND STORAGE OF PERSONAL DATA

    We have implemented security measures to ensure the confidentiality of your Personal Data and to protect your them from loss, misuse, alteration or destruction. Only authorized personnel of URNICO have access to your Personal Data, and these personnel are required to treat the information as confidential. Security measures in place will, from time to time, be reviewed in line with legal and technical developments.

    The information we receive from you can be transferred and stored outside the European Economic Area (“EEA“) for the purposes of providing you with our Services. The information about you can be processed by our employees or employees of service providers outside the EEA. When storing or otherwise processing your Personal Data by such third parties outside the EEA, we guarantee that we will notify such third parties of our obligations under this Privacy Policy and will enter with them into relations that will impose obligations for them regarding your Personal Data, provided that they at least have level of protection as specified in this Privacy Policy. Such employees, among other things, can process your requests, payment details and provide technical support. By giving us your Personal Data, you consent to the transfer, storage and processing of your Personal Data. In its turn, we will take all necessary measures to ensure that your Personal Data is processed in compliance with the security rules and in accordance with the provisions of this Privacy Policy.

    Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Site. In this regard, you are solely responsible for possible failures in the transfer of your Personal Data to the Site. Once we have received your Personal Data, we will use strict procedures and all necessary technical and security measures to prevent unauthorized access to your Personal Data.

    6. BASIS FOR PERSONAL DATA PROCESSING

    We collect and process your Personal Data only when we have a legitimate reason for such processing. Legal grounds include consent (in cases where you provide it), a contract (in cases where processing is necessary to fulfill the terms and conditions of contracts between you and URNICO), compliance with a legal obligations (in cases where URNICO is required to request/receive and process as well as to store your Personal Data in order to comply with the requirements of applicable laws, for example the laws related to anti-money laundering and counter-terrorist financing, to use legitimate interest (for example, when processing is necessary to protect you or us from certain threats: fraud, security threats, etc.), to comply with the provisions of applicable laws, for the proper level of conduct of our business (the quality of the services provided, identification of needs, preparation of reports), conclusion and implementation of corporate transactions (sale of participant interests/shares, mergers, acquisitions), etc.).

    In cases where the basis for Personal Data processing is your consent, you have the right to withdraw it at any time.

    7. YOUR RIGHTS

    By contacting us you can use the following rights:

    • the right to delete your Personal Data (all or part thereof, considering, however, our regulatory requirements to retain your personal data as set forth in Clause 9 of this Privacy Policy);
      the right to change or correct your Personal Data, in particular when it is incorrectly stated;
      the right to object or restrict processing of your Personal Data;
      the right to access to your Personal Data and/or copy of your Personal Data, which you have provided to URNICO, in a machine-readable format.
  • In addition, you have the right to prohibit the use of your Personal Data for marketing purposes. Before requesting your Personal Data, we usually inform you that we are going to use your Personal Data or disclose it to third parties for promotional purposes. You can use the right to prohibit the processing of your Personal Data for promotional purposes by putting a tick in the relevant field in the questionnaire. You can also exercise this right by contacting us at any time.

    Please note that the implementation of some of your rights, depending on the situation, may limit, complicate or completely exclude the possibility of further cooperation with us.

    Our Site may contain active links from/to the websites of partner organizations, advertisers and Affiliated companies. If you are following an active link, please note that other websites have their own privacy policies, and we are not responsible for the provisions of these policies. Please review the privacy policies of these websites before sharing your Personal Data with them.

    8. ACCESS TO PERSONAL DATA

    The Data Protection Act 2018 gives you the right to access information we hold about you. Your right of access can be exercised in accordance with the Data Protection Act 2018, and subject to your written request, sent to the email legal@URNICO.com, we will provide you with the data we hold about you. In case your request will be manifestly unfounded or excessive or you will request further copies of your Personal Data following a request, we may charge you a fee of £10 (ten pounds).

    9. RETENTION OF PERSONAL DATA

    Making sure your Personal Data is safe and secured is of a highest priority to us. We use secure storage facilities ensuring safeguard of your Personal Data you share with us at all stages of interaction with our Platform, products and Services. All appropriate measures to secure your Personal Data from potential hacks, loss or misuse are implemented by our security team

    We will hold your Personal Data only for the duration of you using our products and Services via your Account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory that we comply with. In accordance with our record keeping obligations we will retain your Account information and your Personal Data for at least a period of 5 (five) years from the moment you cease to carry on the use of our Services or the moment you end of your client relationship with us, unless otherwise required by legal or regulatory reasons.

    We may access your Personal Data or retain it for a longer period if it will be subject to an official request or legal obligation, an investigation by government bodies or investigation into possible violations of our User Agreement and its essential parts, or in other cases to prevent possible harm based on our reasonable considerations.

    If you will cancel your subscription to our email newsletter, we will hold your email on an inactive email list.

    10. CHANGES TO THIS PRIVACY POLICY

    Any changes we may make to our Privacy Policy in the future will be posted on this page and, where appropriate, notified to you by email. Please check back frequently to see any updates or changes to this Privacy Policy.

    11. CONTACT

    In accordance with the Data Protection Act 2018 and ePrivacy Directive 2009/136/EC, in case you will have any questions, complaints or concerns regarding our Privacy Policy, Cookie Policy or the way or purpose for which we handle your Personal Data — you can contact us. For that purpose, please contact our Data Protection Officer at email legal@URNICO.com or phone +44 7440 961453, and we will try to assist you promptly.

    You can also reach us by post mail at Office 656 6th Floor, 2 Kingdom Street, London, England, W2 6JP.

    If you are resident of the EEA you can reach out to the lead supervisory authority for URNICO, which is Information Commissioner’s Office. Alternatively, you reach out to your National Data Protection Authority if you are resident of the EEA. Residents of other jurisdictions may contact their national data protection authority.