With this Privacy Notice we provide you information on why and how we process your personal data in connection to EUROe.
If you want to know how we process personal data in connection to our other business operations, please have a look at our General Privacy Notice.
1) WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?
The controller of your personal data is Membrane Finance Oy (business ID: 32368862), and we are located at Linnankatu 3 A 24, Turku, Finland.
You can reach us via email at: firstname.lastname@example.org.
2) WHAT DEFINITIONS ARE USED IN THIS PRIVACY NOTICE?
AML Act means the Act on Preventing Money Laundering and Terrorist Financing of Finland (444/2017).
Controller means a party that is in charge of the personal data processing activities.
Customer means our customer who purchases EUROe from us or sells EUROe to us. Please note that all our customers are renowned companies operating in the field of virtual assets, whereby we shall not have any private individuals as customers.
Data subject is a term for a human being in accordance with data protection laws.
EUROe means our euro-backed stablecoin.
Legal basis for processing means the legal basis with which the controller processes personal data of a data subject. Article 6 of the GDPR contains provisions on legal basis for processing.
Personal data means any data concerning a data subject or data with which a data subject can be identified with.
Privacy Notice means a data protection document that has been drafted according to Articles 13 and 14 of the GDPR, and with which the controller may inform its data subjects of the ways their personal data is processed.
Processor means a party that processes personal data for and on behalf of the controller.
Purpose for processing means the reason why the controller processes personal data of a data subject.
3) WHY DO WE PROCESS YOUR PERSONAL DATA?
We process personal data to be able to provide EUROe to our customers, comply with our legal obligations under the AML Act, enhance as well as develop EUROe and maintain EUROe reserves.
Our legal basis for processing personal data depends on the purpose for which we process personal data. We use as a legal basis (i) our contractual obligations when we provide EUROe to our customers and maintain EUROe reserves, (ii) our legal obligations when complying with the AML Act and (iii) our legitimate interests when enhancing and developing the EUROe.
In our personal data processing activities, we process names, contact information, data related to the use of the EUROe and data we are required to process under applicable laws of the representatives of our customers and EUROe reserve auditor(s).
4) FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?
We collect your personal data from you when you interact with us in regard to EUROe, from digital services we use from time to time (e.g. compliance tools for anti-money laundering purposes) and from public sources (e.g. official registries such as trade registry).
5) DO WE DISCLOSE OR TRANSFER YOUR PERSONAL DATA?
As a general rule, we will not disclose your personal data to third parties. However, if we are required by mandatory law or governmental authorities to disclose your personal data, we will assess the legality of such disclosure on a case-by-case basis.
We do share, i.e. transfer your personal data to others as part of our normal business activities when using various digital services. For example, we use the following digital services provided by data processors, which involve the processing of personal data: data storage services (e.g. cloud services), communication services (e.g. e-mails) and compliance tools.
6) DO WE PROCESS YOUR PERSONAL DATA OUTSIDE THE EU AND THE EEA AREA?
Your personal data may be processed outside the EU and the EEA area. In these situations, we ensure an adequate level of data protection, for example, through standard contractual clauses, adequacy decisions and other similar arrangements.
7) HOW LONG DO WE RETAIN YOUR PERSONAL DATA?
We retain personal data for (i) at least five (5) years after the end of customer relationship, when processing personal data to ensure compliance with the AML Act, and (ii) as long as it is necessary to fulfil the purpose of data processing, when we process personal data for the purposes of enhancing and developing EUROe.
8) WHAT DATA PROTECTION RIGHTS DO YOU HAVE?
You may have the right to use the below listed data protection rights under the GDPR:
Right to inspect (art. 15)
Right to rectify (art. 16)
Right to erasure (art. 17)
Right to restriction of processing (art. 18)
Right to data portability (art. 20)
Right to object; especially when processing personal data based on legitimate interests (art. 21)
Automated individual decision-making, including profiling (art. 22)
If you would like to use your rights or inquire something about data protection, please be in touch via email (see contact information from Section 1).
You may also have a right to lodge a complaint with the data protection authorities, if you think that the processing of your personal data infringes data protection laws.
9) CAN THIS PRIVACY NOTICE BE AMENDED?
We may unilaterally amend this privacy notice. We update the privacy notice as necessary, for example, when there is a change in legislation. Amendments to this privacy notice will take effect immediately when we post an updated version on our website.
If we make significant changes to the privacy notice, or if there is a significant change in the way it is used, we will notify the data subjects.