1.3. The personal data includes any information about you (e.g. name, contact details, details related to using the Website, etc.) that we may process for our established purposes. The Processing of the personal data involves any and all operations we may perform with the personal data (incl. collection, storage, use, disclosure, etc.).
1.4. We process personal data pursuant to our obligations arising from the relevant legislation applicable in the European Union and in the Republic of Estonia and observe the principles of legitimate and secure processing of personal data.
1.6. The personal data requested from you in the process of registering as a User and using the services provided on the Website is necessary for using the services provided on the Website and, if you choose not to submit the personal data, the use of the Website is respectively restricted or impossible. By submitting the data to the Website or providing it to Fundament in any other manner, you confirm the accuracy of the submitted data.
2. Categories of the personal data
2.1. We process the personal data that you provide to us upon registering as a User of the Website and by using the Website and services provided on it. We may also process your personal data received from third parties such as governmental bodies, public registers.
2.2. The personal data processed by Fundament may include the following categories of personal data:
2.2.1. personal details (such as first name and surname, personal identification code, date of birth, representation rights);
2.2.2. documents and data obtained for verifying the identity of the User (image of their identity document, a picture or video of their face, metadata of and machine-readable data in the images, timestamps, biometric data from facial images);
2.2.3. contact details (such as phone, e-mail address);
2.2.4. data relating to the use of the Website (such as User Profile details, User ID, password, language, information and details regarding your visits and interactions and the way you use the Website, communication with Fundament, correspondence via the Website, necessary information regarding the User’s Bank Account);
2.2.5. details of the transactions performed in the Website (e.g. declarations of intention, orders for transactions and contractual documents, the details and balance of the User’s Virtual Account).
3. Purposes of and legal basis for the processing
3.1. The performance of the operations required prior to entry into the contract and for the performance of the contract concluded with you for using the Website is the legal ground for processing the personal data for the following purposes:
3.1.1. the creation of the User Profile and linking it with a specific and duly identified person, administration of the User Profile and enabling the secure logging into the User Profile;
3.1.2. provision of services via the Website and enabling the use of the Website for its intended purposes (e.g. fulfilling orders for transactions and verification in connection therewith, preparing and retaining documents of transactions, making payments on the User’s Virtual Accounts, displaying reports and overviews to the user, sending e-mails related to the use the Website and contacting you in connection with using the Website, if necessary).
3.2. The legitimate interest of Fundament to carry out and develop our economic activities is the legal ground for processing the personal data for the following purposes:
3.2.1. improving the user experience of the Website (including troubleshooting, data analysis, testing, research and service improvement and notifying you about the changes of the services provided on the Website);
3.2.2. activities relating to the marketing and promotion of the Website and services provided on it, including relevant messaging;
3.2.3. performance of financial and statistical analysis;
3.2.4. identification and due diligence measures for the prevention of fraud, money laundering and terrorist financing;
3.2.5. if and as necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
4. Recipients of the personal data
4.1. Fundament discloses your personal data to any third party only in accordance with applicable legislation.
4.2. We may disclose your personal information to the following categories of recipients:
4.2.3. to third party controllers if and to the extent which they are legally entitled to receive certain personal data under applicable legislation (banks, government bodies, law enforcement and supervisory authorities, research institutions) or in the context of the services they provide to Fundament and have undertaken to maintain the confidentiality of the personal data (e.g. advisors) or if it is necessary for defending our legitimate interests or claims;
4.2.4. to the other party of any contract you have entered into via the Website and, if relevant, to the person acquiring the claim deriving from such contract, as well as, if necessary, to the security agent.
4.3. We transfer your personal data outside of the European Union or the European Economic Area only in cases specified in article 49 of the General Data Protection Regulation.
5. Exercising your rights regarding data processing
5.1. If you would like:
5.1.1. to receive information on whether and which personal data and how are processed by us within the services provided on the Website;
5.1.2. to request the rectification, amendment, or complementation of your personal data if they are incorrect, incomplete, or insufficient;
5.1.4. to submit objections against the processing of your personal data for the purposes of direct marketing or for processing your personal data based on a specific situation, if such processing is based on Fundament’s legitimate interest;
5.1.5. to restrict the processing of your personal data (if you have disputed the accuracy of the data, we do not need your data for the purposes of the processing, and you are not interested in the deletion of your data or if you have submitted an objection against the processing of your personal data);
5.1.6. to request the transfer of your personal data to another data controller in compliance with the applicable legislation;
5.1.7. to withdraw your consent given to the processing of your personal data for specific purposes (the withdrawal does not affect the lawfulness of the processing based on the consent before its withdrawal); or
5.2. Please be informed that the above-mentioned rights are not unlimited and, in certain cases, the rights of other persons or the legitimate interests and/or obligations of Fundament may restrict the execution of your rights. We strive to ensure lawful and transparent processing of personal data, respecting the rights of the data subject. Should you find, however, that we have processed your personal data unlawfully or have violated your rights in connection with processing the personal data, please notify us thereof by sending an e-mail to the address specified in Clause 9. You may also file a complaint with the Estonian Data Protection Inspectorate (e-mail address: firstname.lastname@example.org).
5.3. The Website may, from time to time, contain links to and from third-party websites. Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
6.1. We maintain adequate administrative, technical and physical security measures to protect your personal data against accidental, unlawful or unauthorized destruction, loss, change, access, disclosure, or use and other unlawful uses.
6.3. We test our systems regularly to make sure our security mechanisms are up to date. The security measures in place will, from time to time, be reviewed in line with legal and technical developments.
6.4. 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 the data transmitted to the Website. Once we have received the data, we will use strict procedures and security features to try to prevent unauthorized access.
7.1. A cookie is a small data file that is saved automatically in your device through the browser when you are using the browser. Cookies include the specific details of the specific user of a website and the specific website. Cookies help you identify yourself on a website and enable you to use various functions on a specific website – for example, a website use your cookies to remember your preferences, settings, user habits, to collect data about visits to the website, etc. Fundament also uses Local Storage Objects for the same purpose.
7.3. Refusing to accept the cookies may reduce the quality of your user experience and you may not have access to some of the services provided by us.