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Privacy Policy

Privacy Policy

IMPERIVM FZC LLC ("the Company") is concerned with the protection of personal data. That is why we make every effort to protect the privacy of all visitors and members (hereinafter the "Users") of the Website https://www.imperivm-systems.com (hereinafter referred to as "the Site"). ").


Users will find below all the provisions relating to the processing of personal data that are applicable during any visits or uses of the Site (hereinafter the "Privacy policy").


The Privacy Policy is intended to inform you of the policy pursued by the Company with regard to the protection of personal data and the rights relating to the protection of personal data that you have.


By using our Services, you agree to the terms of this Privacy Policy. If you disagree with any of its terms, you are free to stop using our Services.


1. General

The Company processes personal data of Site Users, for the purposes and within the limits of the Privacy Policy,during any visit or use thereof.


The Company ensures to comply with the laws and regulations in force when processing these personal data,in particular the European Regulation (EU) 2016/679 of 27 April 2016 relating to the protection of individuals with regard to processing of personal data (hereinafter "the Regulation").


In this respect, and in accordance with these Regulations, the Company:


1. Is legally obliged to carry out a personal data processing of Users. This treatment is described in Article 2 of the Privacy Policy;
2. In addition, processes personal data for the purpose of enabling Users to use the Site and, in addition,for the necessary and legitimate purposes described in Article 2 of the Privacy Policy;
3. Processes, with the prior, free and explicit consent of Users the personal data described in and for the purposes set out in Article 3.


Users are deemed, by accessing the Site and using the Site, to have become aware and accept the Privacy policy. They further guarantee that the data and information provided to the Company are accurate.


2. Personal data processing

2.1. The legal obligations of the Company and the treatments required to use the Site

The Company is required, in order to authenticate and allow Users to use the Site, to process the following personal data for the purposes described below.


A. What data is processed?

The personal data processed are as follows:


1. Last name, first name (s), date of birth, language, gender, home/ postal address, National Registry Number (or identity card or passport number), email address, landline or mobile number;
2. The banking data used during deposit and withdrawal transactions on the Site;
3. Copies of personal documents allowing the authentication of the Users, such as the photo of the identity card, an account statement, proof of deposit or any other document proving the domicile and / or residence of the User.
4. The browsing and activity history of the User on the Site, including the history of his transactions (deposits and withdrawals), connections (browser data, IP address), including via cookies;
5. Any other information that may be exchanged between the Company and the User, in particular by email or any other means of communication, as part of its registration or use by the User Services offered on the Site.


B. What is the treatment done by the Company?

The processing consists in the collection, registration, storage, consultation, organization, use, understanding or any other operation made necessary or useful under the legal and regulatory provisions described in article 2.1.c). The processing may also include the transfer of personal data:


1. to the judicial and administrative authorities;

2. to the suppliers of the Company, whose services are inseparable from the use of the Site and whose list is available on request from the Contact referred to in Article 7.4.


C. What are the purposes of this treatment?

The Company is required to process the personal data described in Articles 2.1 (a) and (b) in order to comply with the legal and regulatory obligations it is subject to, in particular, the Law on the Prevention of Money Laundering and the financing of terrorism.


The Company also processes the personal data referred to in Article 2.1.a) for the purpose of authenticating Users and allowing them to access and use the Site. This treatment is therefore performed to ensure:


• The management of registrations and accounts of User;

• The management of deposits and withdrawals of Users;

• The User’s information relating to the services offered by the Company;

• The customer service management


The Company will also process the personal data referred to in Article 2.1 A. for the following legitimate purposes:


• Promotion, advertising and marketing relating to the Services offering, including the sending of SMS, telephone calls, paper or electronic newsletters;

• Conducting satisfaction surveys, statistical studies, trend analysis and market research, for the purpose of improving the services or the information of the Users or of the protection of the Users and the prevention on the use of tools and information made available to them on the Site

• The development of new Services.


3. The processing of personal data

By using the Site, for any reason whatsoever, the User expresses his free ,specific, informed and unique will to expressly authorize the Company to process personal data in accordance with the Regulations, within the limits and for the purposes defined herein below and without prejudice to the treatments referred to in Article 2.

The User also benefits from the rights,including the right to withdraw his consent at any time, in accordance with the terms defined in article 4.


3.1 Nature of the personal data processed

The data processed by the Company are as follows:

• Last name, first name (s), date of birth, language, gender, home/postal address, National Registry Number (or identity card or passport number), e-mail address, landline or mobile number;

• The banking data used during the payment and withdrawal transactions on the Site;

• Copies of personal documents allowing the authentication of the Users, such as the photo of the identity card, an account statement, proof of deposit or any other document proving the domicile and / or residence of the User.

• The browsing and activity history of the User on the Site, including the history of his transactions (deposits and withdrawals), connections (browser data, IP address), including through cookies;

• Any other information that may be exchanged between the Company and the User, in particular by email or live chat, as part of its registration or the use by the User of the Services offered on the Site.


3.2 Treatment

The treatment consists of the collection, registration, storage, consultation, organization, use, reconciliation of the personal data described in Article 3.1. It also consists of the transfer of such personal data to third parties, the list of which is available on request from the Contact referred to in Article 7.4.


4. Rights of the user

Without prejudice to Articles 2 and 5, Users are entitled to exercise a right of rectification, opposition and limitation, in the manner and within the limits set forth in this Article.


4.1 Right of access

A. The Company provides the Users with all the following information:


• The identity and contact information of the person in charge of the treatment;

• The contact details of the data protection officer;

• The personal data processed;

• The purpose of the processing for which the personal data are intended and the legal basis of the processing;

• The recipients or categories of recipients of personal data, if applicable. And, where appropriate, the fact that the processing officer intends to transfer personal data to a country outside the European Union and in this case, the existence (or the absence) of a decision of adequacy issued by the European Commission, i.e., in the absence of such a decision, the guarantees offered by the third country and the means implemented to obtain a copy of the personal data.

• The possibility of opposing the automated processing of their data, such as profiling, unless there are just reasons to make such processing by the Company necessary, as well as the possibility of opposing any processing of their personal data for prospecting purposes.


B. Users have the right to request, at any time, access to all information set forth in this Article and Article

3.1, by contacting the Contact referred to in Article 7.4. The Company will respond to these requests for information within one month.

C. Users are entitled to obtain a copy of the personal data being processed. The Company reserves the right to claim payment for any costs incurred by this request. These fees will be calculated on the basis of the administrative costs induced by the request and will not exceed 20 euros.

D. Users are entitled to obtain, in a structured format, such access or copy, in such a way that personal data are provided to them in a readable format in accordance with the technical standards in force at the time of their request of access.


4.2 Right of rectification

The Company guarantees and obliges the Users to update and correct their personal data, as long as the data is incorrect or incomplete.

This right of rectification may be exercised upon request to the Contact referred to in Article 7.4.


4.3 Right of opposition

The Company authorizes Users to oppose to the processing of all or part of their personal data, on the following grounds:
• Their data is inaccurate;
• Processing is no longer necessary for the purposes for which the data was collected;
• The User withdraws his consent;
• The data has been unlawfully processed.

The Company also allows Users to oppose:

• an automated processing of their data, such as profiling, unless there are just reasons to make such processing by the Company necessary;
• Any processing of their personal data for prospecting purposes, including profiling, if it is related to this prospection.
This right of opposition may be exercised upon request to the Contact referred to in Article 7.4.


4.4 Right to oblivion

The Company also undertakes to respond to any request for the deletion of personal data as soon as possible when:

• Processing is no longer necessary for the purposes for which the data was collected;
• The User withdraws his consent;
• The data has been illegally processed or must be deleted under a legal obligation.
• The User opposes the automated processing of his data, such as profiling and that there are no good reasons for making such processing by the Company necessary;
• The User opposes the processing of his personal data for prospecting purposes, including profiling, if it is linked to this prospection.


4.5 Right of limitation

Users also have the right to obtain from the Company the limitation of the processing of their personal data when:

• The User considers that his personal data to be inaccurate during the time necessary for the Company to verify the accuracy of these;
• The processing is illegal but the User does not want the data erased but requires a limitation of processing thereof;
• The User objects to automated processing, including the profiling or processing of his personal data for purposes of prospecting and that it is necessary to verify the legitimacy of the reasons why the Company intends to maintain this treatment;
• The Company no longer needs the personal data processed but the individual wants them to be kept for the purpose of ascertaining, exercising or defending legal rights.
This right of limitation may be exercised upon request to the Contact referred to in Article 7.4.

4.6 Transfer of data to a processing manager

Users are authorized to transfer their personal data to another controller without the Company obstructing it.
As far as such a transfer is technically possible, Users are entitled to request the Company for this transfer to be carried out directly by its processing manager.


4.7 Terms

The rights recognized by the Company to the User must be exercised in the manner defined in article 7.4.


4.8 Notification

The Company shall provide the User with a notification of any erasure or correction of data made in accordance with Articles 4.2 and 4.4, unless such notification proves impossible or imposes disproportionate efforts.
This notification will be made by post or by email, based on the contact information provided by the User.


5. Retention and retention period of personal data

5.1. The Company retains the personal data of Users in a form allowing their identification and availability and using appropriate and secure means.
5.2. The personal data of the Users are kept by the Company for the purposes defined in Articles 2 and 3. They are kept for a period of 10 years for all purposes governed by Article 2.
The Company therefore reserves the right to retain the personal data of the User for any purpose that may be imposed by the Law as a result of its activities.
The Company is required to keep a photocopy of the identity card or the document used to identify the User for at least ten years from the last activity of the User on the Site.
Personal data is kept for a period not exceeding the time necessary to achieve the purpose of processing for all the purposes set out in Articles 2 and 3. The data shall then be deleted from the Company's files at the request of the Users addressed to the Contact referred to in Article 7.4.


6. Liability of the Company - Subcontractor

6.1. The Company undertakes that the processing of users' personal data is lawful, fair, and transparent to the User concerned. Any treatment by the Company will comply with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 relating to the protection of individuals with regard to the processing of personal data and this Privacy Policy.
The Company implements all reasonable and appropriate means to ensure the confidentiality, integrity and availability of the personal data it processes.
6.2. Users' personal data are not transmitted to third parties other than the Company's suppliers and partners, except for the purposes described in Articles 2 and 3 and, therefore, if:

• The transfer is made compulsory by law, a regulation or an injunction from an administrative or judicial authority;
• The transfer is necessary for the provision of services, or for maintenance services;
• The User has signed his consent for such transfer;

The Partner will not be considered as a subcontractor unless it processes the Users' personal data on behalf of the Company.
The Company disclaims any responsibility as to the treatment of the personal data of the User by the partner who provides his own services in his own name and on his own account or if it proves that the fact which caused the damage is not attributable to him. In the event that the Company acts as a subcontractor of the partner, it is agreed that it will not be held responsible for the damage caused by a processing of personal data contrary to the Regulation or this Privacy Policy that if it has not complied with the obligations laid down in the Regulation which are specifically incumbent on the subcontractors or that it has acted outside or contrary to the lawful instructions of the partner. Likewise, the Company's liability cannot in any case be incurred if it proves that the fact that caused the damage is not attributable to it.
6.3. The Company ensures that, where the processing is carried out by a subcontractor, the subcontractor provides sufficient guarantees for the implementation of appropriate technical and organizational measures and, more generally, that the requirements are met. In particular, it obliges the subcontractor to comply with the Regulations and, therefore, to maintain a register.
6.4. The Company undertakes that in the event of a security issue related to the data processed, which could affect its confidentiality, it will notify the data protection authority referred to in Article 7.3 as soon as possible.
The Company will also inform the Users concerned, provided that the breach of personal data poses a high risk for the rights and freedoms of the User. This information will be made by post or email to the contact details provided by the User.


7. Miscellaneous

7.1 Integrity - modification of the Privacy Policy

The Privacy Policy contains all the contractual provisions enforceable against Users, without prejudice to the general provisions contained in the Terms of use of the Site of which they form an integral part. The Terms of Use of the Site therefore remain applicable for any matter not covered by the protection of personal data. The Company also reserves the right to modify the Privacy Policy. Any update is enforceable against Users as soon as it is posted on the Site. The Company will ensure to mention the update of the Privacy Policy when posted on the Site.


7.2 Probative value

The User acknowledges that the electronic documents exchanged and the electronic data collected as part of his registration or use of the Site have the same probative value as if these documents and data had been communicated or collected in paper for value because of their electronic support.


7.3 Data Protection Authority

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals in relation to the processing of personal data and the law of 8 December 1992,the User is entitled to request additional information or to file a complaint with the Data Protection Authority.
The Supervisory Authority is the European Data Protection Supervisor:
Wiertz Street 60
1047 Brussels
Phone: +32 2 283 19 00
Fax: +32 2 283 19 50
E-mail: edps@edps.europa.eu
Website: http://www.edps.europa.eu/EDPSWEB/


7.4 Contact - Information on the identity of the processing manager and the data protection delegate

The Company may be contacted for any questions related to the protection of Users' personal data, as follows:

• By email: legal@imperivm-systems.com
• By telephone: +971 48 76 86 25
The person responsible for processing within the Company is Jan Deriuyn

The Company has also appointed a Data Protection delegate within the meaning of Article 37 of the above-mentioned Regulation. He can be contacted by email: dpo@imperivm-systems.com
He is responsible for monitoring and complying with the processing by the Company of Users' personal data.