Privacy policy

Protecting Acquirer’s data and using it only as Acquirer expect from Company and as required by law is a top priority for Company. The Company must comply with the legal provisions on data protection, and that Acquirer understands the way Company store and utilizes Acquirer’s data.

This Privacy Policy explains who are the Company, how the Company collect, share and use Personal Data about Acquire when he/she use Company’s Website, and how Acquirer can exercise his/her privacy rights. If Acquirer has any questions or concerns about the Company’s use of his/her Personal Data, then please contact the Company using the contact details provided in this Privacy Policy. Please do not use the Company’s Website and/or FDM-Platform or services if you do not agree with how Company process Personal Data according to this Privacy Policy.

The person responsible within the meaning of the Basic Data Protection Regulation and other national data protection laws of the member states, as well as other data protection regulations, is:

Acquirer or you or user – an individual or a legal entity who is a client of the Company and who acquires (intends to acquire, has acquired) tokens from the Company. It can be a visitor, user.

Consent – means any freely given, specific, informed and unambiguous by which the Acquirer, by a statement or by clear affirmative action, consent to the Processing of Personal data.

By using the Company’s Website or FDM-Platform Acquirer agrees to Company processing of Acquirer information as described in this Privacy Policy. By using the Company’s Website or FDM-Platform Acquirer acknowledges that he/she has read and understood this Privacy Policy and agrees to be bound by it and to comply with all applicable laws and regulations. By using the Company’s Website and FDM-Platform Acquirer gives Company Acquirer’s explicit consent to the Company’s processing of Acquirer personal data as described in this Privacy Policy.

If you do not agree with or you are not comfortable with any aspect of this Privacy Policy, you should immediately discontinue visiting, accessing or using FDM-Platform and/or Company’s Website.

1. What types of information does Company collect?

Personal Information

«Personal Data» is information that, directly or indirectly, identifies Acquirer (you) or another individual and which may include:

  • identity and contact details: name, full name, date and place of birth title, citizenship, place of domicile, data of passport or another identity document, e-mail address, telephone number, postal address, title, company Acquirer work for our own, job function, expertise other data obtained within identity and address verification, browser and device information (including IP Address, the hardware model, operating system and version, the web browser Acquirer use, and other device identifiers), account information (such as username and password), information collected through cookies and other similar technologies;
  • data about transactions completed via the FDM-Platform;
  • details of Acquirer’s payment instruments (i.e. instruments used for deposit and withdrawal of funds within the FDM-Platform), including details of bank cards and cryptocurrency public addresses;
  • communication with Acquirer, including Acquirer’s sound- and video-recording (phone and video calls, e-mails, chats);
  • Acquirer economic profile: employment status; annual income; source of income; current value of wealth; annual investment plans; investment objectives;
  • other personal information Acquirers choose to provide.

If Acquirer submits any Personal Data relating to other people to Company or Company’s service providers in connection with the Website, FDM-Platform Acquirer represents that he/she has the authority to do so and to permit Company to use the information following this Privacy Policy.

Sensitive information

Company does not intend to collect sensitive information through its Website or FDM-Platform such as race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, sexual life or sexual orientation, and criminal records. The Company asks that Acquirer does not provide sensitive data of such nature when using its Website or FDM-Platform. The company directly or indirectly may collect Acquirer’s biometric data which identifies Acquirer or another individual.

Other Information

«Other Information» is any information that does not and cannot be used to reveal Acquirer’s identity or that of another individual, such as information which has been fully and permanently anonymized and aggregated. We use this information to facilitate our operation of the Website or FDM-Platform and for other purposes described below.

The information will be freely provided by you to the Company or collected automatically while using the Company’s website and/or FDM-Platform, by this Privacy Policy.

By providing Company with Acquirer’s personal information, Acquirer also consents for Company to collect, hold, use and disclose Acquirer’s personal information following this Privacy Policy. In addition to providing the foregoing information, if Acquirer chooses to correspond further with Company through e-mail or the “contact” section of Company’s Website or FDM-Platform, the Company may retain, use and disclose the content of Acquirer’s messages together with Acquirer e-mail address and Company’s responses.

2. Purposes for which Company uses your Personal Data

2.1. Provision of the website and log files creation

2.1.1. Description and scope of data processing

Every time Acquirer visits the Company’s Website or FDM-Platform, Company server logs automatically collect data and information from the accessing computer system. The following data is collected: 1) information about browser type and version used; 2) the Acquirer’s operating system 3) the Acquirer’s internet service provider 4) the IP address of the Acquirer 5) date and time of access 6) referrer URL (previously visited pages) 7) websites accessed by the Acquirer’s system via the Company’s website or FDM-platform. The data is also stored in the log files of the Company’s system. This data is not stored along with other Personal Data of the Acquirer. Company’s Website or FDM-Platform may contain links to other websites run by other organizations. This Privacy Policy applies only to our Website or our FDM-Platform‚ so Company encourages Acquirer to read the privacy statements on the other websites Acquirer visit. The company cannot be responsible for the privacy policies and practices of other sites even if Acquirer access those using links from the Company’s Website or FDM-Platform. Also, if Acquirer linked to Company’s Website or FDM-Platform from a third party site, Company cannot be responsible for the privacy policies and practices of the owners and operators of that third-party site and recommend that Acquirer check the policy of that third party site.

2.1.2. Purpose of data processing

The temporary storage of the IP address is necessary to allow the access of the Acquirer’s device to the Company’s Website or FDM-Platform. For this purpose, the IP address of the Acquirer must remain stored for the duration of the session. Other purposes for which Company may use Personal Data Acquirer provide to it: 1) to administer and manage Company’s Website or FDM-Platform; 2) to understand how Acquirer use the features and functions of its Website or FDM-Platform to improve Acquirer’s experience; 3) to develop its businesses and services.

The data is stored in log files to ensure the functionality of the Website or FDM-Platform. Also, the data serves the Company to optimize the Website or FDM-Platform and to ensure the security of the Company’s information technology systems. An evaluation of the data for marketing purposes does not take place in this context.

2.1.3. Duration of storage

The data will be deleted as soon as the purpose for which it was stored is fulfilled. In the case of collecting the data to enable access to the Company’s Website or FDM-Platform, the data will be deleted once the Acquirer’s session expires. Additional storage is possible; in this case, the IP addresses of the Acquirers are deleted or alienated, so that personalization of the data is no longer possible.

2.2. Use of cookies

2.2.1. Description and scope of data processing

Company’s Website or FDM-Platform utilizes Cookies; they are text files which are stored in Acquirer’s device to provide an analysis of Acquirer use of Company’s Website or FDM-Platform. When an Acquirer visits a Website or an FDM-Platform, a cookie may be stored in the Acquirer’s operating system. This cookie contains a distinguishing character string that enables a unique identification of the browser when the Website or FDM-Platform is visited again. If cookies are disabled for the Company’s Website or FDM-Platform, it may not be possible to use all its functions to the fullest. The Acquirer’s (user) data collected by technically necessary cookies are not used to create Acquirer (user) profiles.

Cookies are placed on Acquirer’s device only if Acquirer consents to it unless cookies are necessary for the strictly technical functionality of the Company Website or FDM-Platform. To record and analyze how Acquirer’s use the Company Website as well as to improve Acquirer’s experience, the Company collects details of Acquirer’s visits by using Google Analytics. Google Analytics places and uses cookies that allow Company to track Website traffic and Acquirer’s (Users’) interaction with the Company Website. The company uses cookies to make its website more user-friendly. Some elements of the Company’s Website require the Acquirer’s browser to be identified even after a page change.

2.2.2. Purpose of data processing

The purpose of using technically necessary cookies is to simplify the use of Website or FDM-Platform for Acquirers. Some functions of the Company’s Website or FDM-Platform are not available without the use of cookies; therefore, the browser must be recognized even after a page change. For further information about the types of Cookies Company uses, why, and how you can control Cookies, please see Cookie Police at Company’s website.

2.2.3. Duration of storage, the possibility of objection and elimination

Cookies are stored on the device of the Acquirer (user) and transmitted to Company. Therefore, Acquirer (user) has full control over the utilization of cookies. By changing the settings in Acquirer’s internet browser, Acquirer (you) can disable or restrict the transmission of cookies. Already saved cookies can be deleted at any time. This can also be done automatically. If cookies are disabled for the Company’s Website or FDM-Platform, it may not be possible to use all its functions to the fullest.

2.3. Registration

2.3.1. Description and scope of data processing

We offer Acquirer of Website or FDM-Platform the opportunity to register as a client by inputting Personal Data, which is transmitted to Company and saved. A transfer of this data to third parties does take place. The following data is collected during the registration process:

  • identity and contact details: name, full name, date and place of birth title, citizenship, place of domicile, data of passport or another identity document, e-mail address, telephone number, postal address, title, company Acquirer work for our own, job function, expertise other data obtained within identity and address verification, browser and device information (including IP Address, the hardware model, operating system and version, the web browser Acquirer use, and other device identifiers), account information (such as username and password), information collected through cookies and other similar technologies;
  • data about transactions completed via the FDM-Platform;
  • details of Acquirer’s payment instruments (i.e. instruments used for deposit and withdrawal of funds within the FDM-Platform), including details of bank cards and cryptocurrency public addresses;
  • communication with Acquirer, including Acquirer’s sound- and video-recording (phone and video calls, e-mails, chats);
  • Acquirer economic profile: employment status; annual income; source of income; current value of wealth; annual investment plans; investment objectives;
  • other personal information Acquirers choose to provide;
  • Acquirer’s messages to Company, Company’s messages to Acquirer.

As part of the registration process, the consent of the Acquirer to process this data is requested and obtained.

2.3.2. Purpose of data processing

Acquirer registration is required for the provision of certain content and (or) services on the Company’s Website or FDM-Platform.

2.3.3. Duration of storage

The data will be deleted as soon as the purpose for which it was stored is fulfilled. This is the case for the data collected during the registration process when the registration on the Company’s Website or FDM-Platform is canceled or modified. As an Acquirer (user), you can cancel your registration and change the stored data from Acquirer at any time. The acquirer can request this to Company in writing at any time.

2.4. Contact form and e-mail contact

2.4.1. Description and scope of data processing

There is a contact form available on the Company’s Website or FDM-Platform to establish electronic contact with the Company. If an Acquirer utilizes this option, the data entered in the input mask will be transmitted to Company and saved. At the time of sending the message, the following data is stored: 1) name and date of birth, 2) telephone number, 3) email address. For the processing of the data when utilizing this function, Acquirer’s consent is requested, obtained, and referred to this Privacy Policy. Alternatively, contact with the provided e-mail address is allowed. In this case, the Acquirer’s Personal Data transmitted by e-mail will be stored. In this context, there is no disclosure of the data to third parties. The data is used exclusively for processing Acquirer’s request.

2.4.2. Purpose of data processing

The processing of the Personal Data from the input mask serves Company only to process the contact. In the case of contact via e-mail, this also includes the required legitimate interest in the processing of the data. Other Personal Data processed during the contact serve to prevent misuse of the contact form and to ensure the security of the Company’s information technology systems.

2.4.3. Duration of storage

The data will be deleted as soon as the purpose for which it was stored is fulfilled. Regarding Personal Data from the input form and sent by e-mail, this is the case when the respective conversation with the Acquirer has ended. The conversation is ended when it can be inferred from the circumstances that the relevant facts have been finally clarified. The Acquirer can revoke their consent to the processing of their Personal Data at any time. If the Acquirer contacts Company per e-mail, Acquirer may object to the storage of his/her Personal Data at any time. In such a case, the conversation cannot continue.

2.5. Use of data for order purposes

Company may use Acquirer’s data to interact with Acquirer and/or respond to Acquirer requests/inquiries, to negotiate, perform or facilitate a contract with Acquirer or related to Acquirer, to send Acquirer invitations to events it organizes, to share with Acquirer information Company might be interested in and/or inform Acquirer about Company’s services. Company may also use Acquirer’s Personal Data to comply with law, regulations, public authority requests or court orders.

The company saves Acquirer’s Personal Data through Company’s Website or FDM-Platform only when provided by Acquirer, e.g. when Acquirer contact Company via Company web form, with an online application, or to carry out a contract. The acquirer will be informed in the respective entry and contact forms about the purpose of collecting the respective data, as well as in this Privacy Policy.

Individuals under the age of 18 should not submit any Personal Data without the consent of their parents or guardians.

All Personal Data and information Company receives from Acquirer will be kept strictly confidential. These are used for the processing of orders, provision of services, and processing of payments. If Acquirer pays on account, Acquirer’s credit rating may be requested from credit institutions:
1) contact details (name, address, telephone, e-mail address) 2) registration number (tax numbers, EORI, VAT ID number) 3) bank details 4) order data.

2.6. IP address

The company needs to know Acquirer IP address to be able to determine Acquirer’s location (the country only), which Company needs to know to comply with legal obligations that may vary depending on Acquirer’s location.

Company reviews our retention periods for Personal Data regularly. Company is legally required to hold some types of information to fulfill the Company’s statutory obligations. Company will hold Acquirer’s Personal Data on her/his systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract Acquirer hold with Company. The company website does not collect or compile personally identifying information for sale to third parties for consumer marketing purposes.

The Company’s Website or FDM-Platform does not collect or compile personally identifying information for sale to third parties for consumer marketing purposes.

3. How does the Company collect Personal Date?

  • when Acquire contact with Company through the Company’s Website or FDM-Platform, by telephone, post, e-mail or through any other means;
  • when contacting Company through live chats on the Company’s Website or FDM-Platform. This is needed when the Company is not ready to answer Acquire immediately and need more time to handle Acquirer’s request. When Acquirer gives Company Personal Data in live chat, Company assume that Acquirer consent to process it by Company;
  • when Acquirer register with Company and set up an account to receive Company’s services;
  • when Acquirer make payments to Company;
  • when Acquirer use Company’s services;
  • by using cookies.

Company will use the Personal Data Company collect from Acquirer only for the purposes described in this Privacy Policy. The Company can act as the data controller of Acquirer’s Personal Data, as well as the data processor – depending on how the Company collects Acquirer’s Personal Data. For details on how the Company acts as a data processor, please refer to clause 11 below.

4. Who does Company share Personal Data with?

Company may disclose Acquirer’s Personal Data to the following categories of recipients:

  • to third-party agents, services providers, and partners. Company contract with other companies and people to perform tasks on Company’s behalf and share Acquirer’s Personal Data with some of them to provide services to Acquirer or to otherwise communicate with Acquirer. Examples include removing repetitive information from customer lists, analyzing data, providing marketing assistance, conducting billing, processing credit card payments, engaging technical support for Company’s services, providing Acquirer service, and performing analysis related to Company’s products or services. The company also provide Acquirer’s Personal Data to agents and service providers to verify or compile aggregate usage data that the Company provides to Company’s partners. When the Company shares this information in this way, the Company requires the agent or service provider to maintain the privacy, confidentiality, and security of the Personal Data;
  • to any competent law enforcement body, regulatory, government agency, court or other third party in case it should occur that Company believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend Company’s legal rights, or (iii) to protect Acquirer’s vital interests or those of any other person;
  • to a potential acquirer of Company and its agents/advisers in connection with any actual or proposed purchase, merger or acquisition of any part of Company’s business, provided that Company inform the buyer it must use Acquirer’s Personal Data only for the purposes disclosed in this Privacy Policy;
  • banking institutions and other payment service providers;
  • the companies being in the same corporate group as Company;
  • data storage providers;
  • AML risk assessment providers;
  • verification providers (i.e. those verifying the information provided by Acquirer to Company, or those enabling to make sure that it is Acquirer who is accessing the FDM-Platform or the Website or initiating requests via it);
  • its employees who are in contact with Acquirer or who are responsible for marketing;
  • to any other person with Acquirer’s consent to the disclosure.

Acquirer gives Company consent to the processing of his/her Personal Data by third parties described in Clause as provided by this Privacy Policy.

All the third parties with which Company share Acquirer’s Personal Data only get the minimum amount of Personal Data that are reasonably required for them to provide their service to Company and therefore to Acquirer. All third parties with which Company share Personal Data are required to protect such Personal Data following all relevant laws and regulations and like the way, Company protects the same. Company will not share Acquirer’s Personal Data with third parties who are considered as not being able to provide its clients and potential client with the required level of protection.

5. Legal basis for processing Personal Data

Company legal basis for collecting and using the Personal Data described above will depend on the Personal Data concerned and the specific context in which Company collects it.

However, Company will normally collect Personal Data from Acquirer only (1) where Company needs the Personal Data to fulfill her contractual obligations with Acquirer, (2) where the processing is in Company legitimate interest and not overridden by Acquirer’s rights, or (3) where Company has Acquirers consent to do so. In some cases, Company may also have a legal obligation to collect Personal Data from Acquirer or may otherwise need the Personal Data to protect Acquirer’s vital interests or those of another person.

If Company collect and use Acquirer Personal Data in relation to Company’s legitimate interests (or those of any third party), this interest will normally be to operate Company’s Website or FDM-Platform and communicate with Acquirer as necessary to provide Company’s services to Acquirer and for Company’s legitimate commercial interest, for instance, when responding to Acquirer’s queries, improving Company’s Website or FDM-Platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities. Company may have other legitimate interests and if appropriate Company will make clear to Acquirer at the relevant time what those legitimate interests are.

6. How does Company keep my Personal Data secure?

Company has implemented appropriate organizational, technical, and administrative measures to protect Personal Data within the Company organization, including security controls to prevent unauthorized access to the Company’s systems. While Company take reasonable steps to secure Acquirer Personal Data from loss, misuse, interference, and unauthorized access, modification and disclosure, Acquirer should be aware no security procedures or protocols are ever guaranteed to be 100 percent secure from intrusion or hacking, and there is therefore always some risk assumed by sharing Personal Data online. If Acquirer has reason to believe that his/her interaction with Company is no longer secure (for example, if Acquirer feels that the security of his/her account has been compromised), please immediately notify Company by sending an email to info@fundamentum.io

7. Transfers to third countries

Acquirer’s Personal Data may be transferred to and processed in, countries are other than the country in which Acquirer reside. These countries may have data protection laws that are different from the laws of Acquirer’s country (and, in some cases, may not be as protective). This includes countries outside the European Economic Area with no adequate level of Personal Data protection (third countries).

Whenever Company transfer Personal Data to other countries, the Company will ensure that the information is transferred by this Privacy Policy. As some of the countries where Company’s controllers/processors are situated are not yet recognized by the European Commission as countries with an adequate level of Personal Data protection, these controllers/processors have access to Personal Data on the basis of instruments that cover the European Union requirements for the transfer of Personal Data to data controllers/processors outside the European Union (Standard Contractual Clauses approved by the European Commission). Acquirer may ask Company to inspect copies of these clauses by contacting its data protection officer.

8. Third-party providers

When Company transfers Personal Data, it does so for the purposes for which the information has been collected/submitted, for the purposes listed above. The Company works only with those third-party providers that are bound to maintain appropriate levels of security and confidentiality, to process Personal Data only as instructed by Company and to flow those same obligations down to their sub-processors.

9. Retention of Acquirer’s Personal Data

Company will retain Acquirer’s Personal Data for some time consistent with the original purpose of collection, including pursuing Company’s legitimate business interests, complying with Company’s legal obligations, resolving disputes and enforcing applicable agreements.

The Personal Data of the Acquirer will be deleted or blocked as soon as the purpose of the storage is fulfilled. Furthermore, data may be stored if this has been provided by the European or national legislator in EU regulations, laws or other provisions to which the Company responsible is subject. The data will also be blocked or deleted if a storage period prescribed by the mentioned standards expires unless there is a need for further storage of the data for the conclusion or fulfillment of a contract.

10. Rights about your Personal Data

As a data subject (a person whose Personal Data is collected, stored and processed) you have several rights under GDPR:

  • The right to access. The acquirer has the right to obtain confirmation if Acquirer’s Personal Data is being processed by Company. If that is the case, Acquirer can access Acquirer’s Personal Data and the following information: (a) the purposes of the processing; (b) the categories of Personal Data; (c) to whom the Personal Data has been or will be disclosed; (d) the planned duration of the storage of the Personal Data concerning Acquirer or, if specific information on this is not possible, criteria for determining the storage period. If Acquirer would like to have a copy of his/her Personal Data from Company, Company will provide it if: (1) Acquirer provide Company with a proof of his/her identity, (2) it will not adversely affect the rights and freedoms of others. The first copy will be provided for free, and for any further copies, Company may charge a reasonable fee based on the associated administrative costs.
  • The right to rectification. The acquirer has the right to demand that Company correct without undue delay Acquirer’s Personal Data which Company has in his/her systems if it is inaccurate or incomplete.
  • The right to erasure («right to be forgotten»). Acquirer has the right to demand that Company erases Acquirer’s Personal Data, and Company shall erase it without undue delay where one of the following grounds applies: (a) the data is no longer necessary in relation to the purposes for which it is was processed; (b) Acquirer withdraw consent on which the processing is based, and where there is no other legal ground for the processing; (c) Acquirer object to the processing and there are no overriding legitimate grounds; (d) Acquirer’s Personal Data has been unlawfully processed; (e) Acquirer’s Personal Data has to be erased for compliance with a legal obligation.
  • The right to restriction of the processing. Company has the right to restrict the Company’s capacity and ability to process Acquirer’s data where one of the following applies: (a) Acquirer contest the accuracy of Acquirer’s Personal Data and Company are verifying it; (b) the processing is unlawful and Acquirer want to restrict it instead of erasure; (c) Company no longer need Acquirer’s Personal Data, but Acquirer need it for some legal reasons; (d) Acquirer has objected to processing and Company is verifying whether the legitimate grounds override Aсquirer’s request.
  • The right to data portability. Acquirer has the right to receive Acquirer’s Personal Data which Acquirer provided Company in a structured, commonly used and machine-readable format and has the right to transmit that data to another company, where: (a) the processing is based on Acquirer’s consent or a contract; and (b) the processing is carried out by automated means. Where technically feasible, Acquirer can demand Company to transmit that data directly to another company.
  • The right to object. The acquirer has the right to object to the processing of his/her Personal Data based on the Company’s legitimate interests. Company shall no longer process Acquirer’s Personal Data unless Company demonstrates compelling legitimate grounds for the processing of, or for the establishment, exercise or defense of legal claims. Where Personal Data is processed for direct marketing purposes, Acquirer has the right to object at any time to the processing of Acquirer’s Personal Data for such marketing purposes.
  • Automated individual decision-making, including profiling. The acquirer has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects on Acquirer. Please note that Company doesn’t make any automated decisions including profiling based on information that Company has about Acquirer.
  • The right to withdraw consent. The acquirer has the right to withdraw his/her consent for the processing of Acquirer’s Personal Data at any time. Withdrawing Acquirer’s consent will not affect the lawfulness of any processing Company conducted before Acquirer’s withdrawal, nor will it affect the processing of Acquirer’s Personal Data conducted in reliance on lawful processing grounds other than consent.
  • Right of information. The acquirer has the right to get any available information on the origin of the data if the Personal Data are not collected from the data subject. The acquirer has the right to request information as to whether the Personal Data concerning Acquirer is transferred to a third country or an international organization. In this context, Acquirer may request to be informed of the appropriate guarantees.
  • The right to complain. The acquirer has the right to complain about a supervisory authority, in particular in the Member State of Acquirer’s habitual residence, place of work or place of the alleged infringement if Acquirer considers that the processing of Acquirer’s Personal Data infringes GDPR. For more information, please contact your (Acquirer’s) local data protection authority. A list of the relevant data protection agencies can be found here.

There are cases when the Company can retain copies of the Personal Data Acquirer requested it to erase. They concern the necessity to protect the legitimate interests of Company or third parties, comply with governmental orders, resolve disputes, troubleshoot problems, or enforce any agreement Acquirer has formed with Company.
For Acquirer’s protection, Company only implements requests concerning the Personal Data associated with the particular email address that Acquirer use to send Company his/her request, and Company needs to verify Acquirer’s identity before implementing Acquirer’s request. Company will respond to Acquirer’s request within 30 days. Please note that Company needs to retain certain information for recordkeeping purposes and/or to complete any transactions that Acquirer began before requesting such access, change or deletion.

11. How does Company protect and store Personal Data as data processor?

The company provides Company services to our Partners. Most of Company’s services involve the processing of the Partners’ data, hereunder their Personal Data. The purposes of processing are determined by our Partners not by Company, making the Partner the data controller. Company does in such cases act as a data processor and process the data on behalf of and according to instructions given by the Partner. The relation between the Partner as a data controller and Company as data processor shall be regulated by a data processing agreement. When the Partner act as data controller the Partner shall, according to applicable privacy legislation, ensure the legal grounds for processing the Personal Data. Further, the Partner shall assess and establish ownership of the risks posed to data subjects by processing their Personal Data. Another important aspect of the Partner’s duty as the data controller is to comply with the information duty towards data subjects. Company is a natural part of the Partner duties as a data controller; in the sense that Company’s services constitute parts of the processing of Personal Data that the Partner must ensure are compliant with applicable privacy legislation. Thus, when Company processes Personal Data on behalf of their Partner, Company must do so by privacy legislation applicable to data processors. In short, the Partner and Company are obligated to cooperate to ensure privacy for data subjects. Company shall provide the information necessary for the Partner to be compliant with applicable privacy legislation.

12. Updates

As far as Company introduces new products or services, or as the Internet and computer security technology evolves or in Company’s sole discretion at any time, this “Privacy Policy” will be updated. The company consequently reserves the right to change or supplement further explanations as needed, and changes will be published on this page of the Company’s Website. The acquirer must periodically visit the Company’s Website to review any changes that may be made to this Privacy Policy. Acquirer continued use of the Company’s Website or FDM Platform constitutes Acquirer’s agreement to be bound by any such changes to this Privacy Policy.

13. Our contact details

If Acquirer has any questions or believe your (Acquirer’s) Personal Data has been used in a way that is not consistent with this Privacy Policy or applicable legislation, or Acquirer has any other data protection related issues or queries, please, contact Company’s Data Protection Officer by e-mail sent to
info@fundamentum.io.