Privacy policy

Privacy policy

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Preliminary information

Cinkciarz.pl Sp. z o.o. with its registered office in Zielona Gora at 9 Sienkiewicza Street (hereinafter referred to as "Cinkciarz.pl") is the controller of your personal data within the meaning of the data protection provisions of the European Union. This means that we determine the purposes and means of processing data ourselves and under our own obligation. Additionally, the controller of the services available at Conotoxia.com depends on the services you use. The services and their controllers are listed below:

  • currency exchange - Cinkciarz.pl sp. z o.o. with its registered seat in Zielona Gora at 9 Sienkiewicza Street
  • money transfers - Conotoxia sp. z o.o. with its registered office in Zielona Gora at 9 Sienkiewicza Street
  • Forex trading - Conotoxia Ltd. established at Chrysorroiatissi 11, 3032 Limassol, Cyprus

If you have any questions regarding the protection of your personal data, you can contact us directly by sending an email to dpo@conotoxia.com or contact@conotoxia.com.

Personal data is any information that can identify a person, such as his or her name, phone number, email address. In turn, the term processing relates to all the operations performed on the personal data, e.g. collecting or analyzing it for the purpose of providing services.

The Privacy Policy applies to the personal data and other information that we receive from you when you use our services and any payable services and any information provided by telephone, text message, email, letter or other correspondence and in person. This Privacy Policy also applies when we use your personal data collected through the following online services:

  • Any websites that refer to this Privacy Policy
  • Social media or Cinkciarz.pl's official content available on websites administered by other processors
  • Mobile apps

We are obligated to protect your personal data. We carefully select and apply the appropriate security measures to ensure that your data is protected. We are obliged to use your personal data in accordance with the applicable data protection legislation (which we describe accordingly in this Privacy Policy and Cookie Policy as "data protection legislation").

The use of our services, including downloading a mobile app or using related services, is subject to review of this Privacy Policy, the Online Terms and Conditions and the applicable Payment Service Terms available here. Any terms written in capital letters, if not defined below, have the meaning given in the Online Platform Terms and Conditions. The Privacy Policy is an integral part of these Terms and Conditions.

In the following section of this Privacy Policy you shall find the following information:

  • What information is collected and how is it collected?
  • IP address, cookies and mobile device identification numbers,
  • How long is your personal data stored?,
  • What is the legal basis for the processing of your personal data?,
  • Is your personal data shared with others?,
  • Your rights with respect to the personal data you provide,
  • Changes in this Privacy Policy and other information.

What information is collected and how is it gathered?

Providing personal data for the purposes of using our services is voluntary, with the exception of cases where the obligation to provide such data is subject to the applicable law. However, the submission of data is necessary in order to execute some of our services.

Your personal data is collected directly from you - this is the information you provide in order to use our services as well as that provided when contacting us. We may also collect information ourselves through our services or through our affiliated partners, which we will share with you in response to your individual request at dpo@conotoxia.com or contact@conotoxia.com.

In order to open an Account, you must provide (a) your User Name (email), (b) your password and (c) your country of residence. We need this information to allow you to use your Account. Your Account Password is encrypted and you are required to protect your Account login details from unauthorized access by third parties.

Using Payment Services involves providing additional personal data, which includes, your name, identification numbers, address data, identity document number or bank account number. You may also be asked to provide a copy of your ID card or other identity documents to confirm your personal data and address. On some occasions it may be necessary to submit other documents or information in order to use our services for the purpose of applying the financial security measures required by counteracting money laundering and terrorist financing laws in order to use our services.

The processing of your personal data is carried out in order to identify you as well as to identify beneficial owners within the meaning of the counteracting money laundering and terrorist financing laws, to monitor our business relationship on an ongoing basis and to investigate the origin of assets. In addition, on the basis of the information obtained from you, we determine the purpose and nature of your business relationship and perform any other activities required by anti-money laundering and anti-terrorist financing laws, in particular, we determine that the first payment to our bank account has been made through your bank account via a financial services provider, where the payer’s details are consistent with the information provided by you.

The counteracting of money laundering and terrorist financing laws allow us to supplement your personal data - we need to be sure of your identity whenever we provide our services to you. In the case of certain services offered by Conotoxia Holding Group, due to their special nature, which is based on our trust in you and your ability to execute your contract for the provision of such a service, your personal data will be verified with information obtained from third parties, provided that you give your separate consent to do so.

In addition, we ask you to provide us with the personal data concerning other parties. This applies, for example, if you are a co-owner of a bank account or if you define the bank account of a person to whom we make a transfer. We are committed to protecting the processing of third party data submitted to us in the course of providing the services to you as much as we are committed to protecting your data. Remember that the application of your personal data rights must not negatively affect the rights and freedom of others, including those who you have given us.

We process your personal data when you contact us, e.g. through the User Service section. This includes information necessary for communicating with you, including answering any questions or concerns you may have. For this purpose, we use the data you have provided in your Account. The scope of data processing shall be limited solely to the information required to provide support, including the content of the message.

We may process personal data that you provide to us directly during the recruitment process by sending application documents and by collecting information from platforms to which you have provided your data. The scope of data processing depends on the nature of particular recruitment processes.

In addition, we process your personal data in order to present offers regarding the services provided by the online platform. We collect your data directly from you and as part of our partnership with business information providers. The data may include, for example, your name, email address, correspondence address and phone number. These are processors to whom you disclose data on the grounds of your own resolution, we have no control over the processing of personal data by the aforementioned processors.

Your personal data is also collected when you contact us using the available tools, including the contact form and the form used for reporting situations that you believe to be fraudulent, i.e. financial crime. The data collected includes, among others, your name and email address. We process your data for purposes directly related to the operation, correct execution of our services and due to the applicable legal requirements that oblige us to prevent various violations of the law.

Your personal data is also processed when you subscribe to our newsletter or when we organise contests or competitions. We use your personal data for the efficiency of operations, including notifying you when you have won.

When you use the services, we may also gather information such as technical data about the devices you use to access them, including your internet connection, IP address, or other technical details provided by your browser. In addition, we process specific information about your use of our services, such as measurement data about when and how you use the services, traffic data, your transaction history list and the type of transactions you make. In addition, we collect information in the form of technical logs in order to obtain data about the usage of services by you and what your activity is, as well as any other information that you submit when we provide our services to you. We collect data using cookies or similar technology. For more information, please refer to our Cookies Policy, which is an integral part of this Privacy Policy.

Please be informed that we use a variety of third-party services, that set their own rules regarding the processing of personal data. These entities also use cookies. Therefore, we encourage you to familiarize yourself with the processing of personal data by the aforementioned entities, the full list of which can be found in the Cookies Policy.

We are not responsible for the privacy policy of other websites, both those available through links placed on Conotoxia.com and those that place links to our website. This privacy policy does not cover external websites. Please review the relevant privacy policies.

How do we use the collected data?

Your personal data is used to:

  • fulfil our obligations under agreements between us and you, such as opening an account, providing access to it and managing it,
  • provide specific services and their functionality,
  • provide information regarding the status of the executed services,
  • implement financial and other security measures resulting, among others, from the Act on Counteracting Money Laundering and Financing Terrorism,
  • comply with legal obligations, including tax or accounting regulations and legal regulations,
  • the rules on the protection of personal data are complied with accordingly,
  • carry out direct marketing available within the scope of the services provided by the online platform; to inform about services available at Conotoxia.com, however, in the cases required by law, this is done with your consent, e.g. when you subscribe to the newsletter or other commercial information within the meaning of the Act on Rendering Electronic Services - remember that you can withdraw your consent to sending commercial information at any time by adjusting your settings in the Notification settings tab,
  • improve marketing activities, including the adaptation of content that you may be interested in. We may personalize our offer or advertisement, but always based on pseudonymized information, which means that we do not determine your identity. Please be informed that we do not make automated decisions that may affect your legal position. We use aggregated information that is not personal information, for example, to determine the volume or frequency of transactions, which allows us to continuously improve our offer,
  • provide support during the term on which the services are provided by the Customer Care Department, as well as solve technical problems and other issues through the contact form,
  • carry out recruitment processes,
  • contact you, including providing information about changes in our Terms and Conditions and Policies,
  • provide the services as efficiently as possible due to the devices through which you access our services,
  • contact you for purposes related to the services, support and marketing - through all available channels of communication
  • electronically send information about Exchange Rates,
  • sale and support of Currency Cards,
  • consider complaints regarding the services,
  • ensure the security of the offered services, including the execution of the Terms and Conditions and counteracting fraud and abuse,
  • conduct court proceedings and other legal actions,
  • settle accounts for the services,
  • organisation of competitions and promotional campaigns.

How long do we store your personal data?

All personal data submitted to us is stored on our servers or on those of our affiliates. We use appropriate technical and organizational security measures to protect your personal data against unauthorized or unlawful processing, accidental loss, damage or destruction. The entities cooperating with us are also obliged to manage the data in accordance with the security and privacy requirements adopted by us.

We only process your personal data for the period necessary to fulfill the objectives set out in this Privacy Policy. Please be informed that the specific nature of our services means that in most cases we are required by law to process your data even if you no longer use our services. This applies in particular to counteracting terrorist financing and money laundering provisions. Such obligations arise additionally from tax or accounting regulations. In most cases, even if you close your account, your personal data will still be processed by us. If you do not have an account but have contacted us, we will store this information for as long as it is necessary for legal or accounting issues.

We assure you that if we do not need your personal data in order to provide the services or for other reasons, such data will be immediately erased or anonymized.

What are the legal grounds for processing your personal data?

We process your personal information to allow you to use our services, which can be defined as a requirement to perform our service agreement. We process your data as it is necessary to comply with our legal obligations. In addition, we rely on legitimate interests, by which we mean information about the services offered by the online platform. In such situations, we always consider the impact that the processing of personal data will have on your rights and freedom. In other cases, data processing is done on the grounds of your voluntary consent, which can be withdrawn at any time. This will not undermine the legality of processing based on the consent given before withdrawal. This applies, for example, to the transmission of commercial information or recruitment processes beyond the scope of the provisions of the labour law.

Do we disclose your personal data to others?

We do not disclose your personal data to anyone except to the extent that we are legally obligated to do so.

Additionally, in order to provide access to the services offered by Cinkciarz.pl, its provider may be changed, of which you are informed each time. This applies to companies such as Conotoxia Sp. z o.o. for the purpose of money transfers or Conotoxia Ltd. offering access to the Forex market. Please be informed that we are constantly expanding our offer. Therefore, the list of processors to whom we share your personal data is expanding. However, we assure you that the data is only disclosed to the extent necessary to provide a particular service. Moreover, it takes place after acceptance of the Terms and Conditions for the particular service. The grounds for processing your data, in this case, is the necessity to execute the contract. Due to the disclosure of personal data to the aforementioned processors, they become independent data controllers.

We use the services of entities that provide us with tools that improve our work, in particular for internal communication and internal data sharing, as well as marketing tools and more efficient electronic communication management. Moreover, a variety of social media is also used and cannot be omitted.

As an institution obliged to apply anti-money laundering and anti-terrorist financing regulations, we are obligated to submit reports to relevant supervisory authorities, including the Chief Inspector of Financial Information, who, as a government administration entity, controls compliance with the aforementioned regulations. Reports are generated and transmitted automatically by our software.

Additionally, our company uses the professional services of legal, tax, accounting and auditing specialists. Moreover, your data is disclosed to banks, the aforementioned Chief Inspector of Financial Information and other entities when required by law.

We are also obliged to maintain security measures. Therefore, we may also disclose your personal data to the police or other authorities, especially if you are involved in a suspicious transaction or if your activity indicates a high risk of money laundering or other criminal activity.

Please be informed that if you use the online forms available on this website, we will make a request via the reCAPTCHA plugin which will include sending you your IP address and any other data required by Google Inc.

Your rights regarding the personal data you submit to us

At any time, you have the right to object to the processing of your personal data in certain situations, e.g. for marketing purposes. You can do this by sending an email to dpo@conotoxia.com or contact@conotoxia.com, changing your settings in the Notification settings tab or by unsubscribing from the messages you receive from us.

You have the right to access your data, rectify it, obtain a processing restriction and request for it to be forgotten. Moreover, you have the right to data portability and erasure of your data. In addition, you can lodge a complaint with the Data Protection Authority. You can claim these rights by contacting us at dpo@conotoxia.com or contact@conotoxia.com.

More information regarding your rights can be found in the Security section.

The aforementioned rights entitle you to update your personal data. Please be informed that this is necessary for the proper execution of the services.

Changes to the Privacy Policy and other relevant information

We reserve the right to introduce changes to the Privacy Policy regardless of changes in the Terms and Conditions. You are responsible for reviewing these modifications.

If you have any questions regarding confidentiality, protection or processing of your personal data, please contact us at dpo@conotoxia.com.