Privacy policy and compliance information
This Privacy Policy ("Privacy Policy") describes how and why Incharge ServicesLtd ("Incharge", "we" or "us") collects and otherwise processes personal dataabout you as a customer, in the context of providing our services.
The term "processing" is used to cover all activities involving your personal data,including e.g. collecting, handling, storing, sharing, accessing, using, transferringand disposing of your personal data.
"Applicable Data Protection Laws" means all legislation and regulations, includingregulations issued by relevant supervisory authorities, protecting the fundamentalrights and freedoms of individuals and, in particular, their right to privacy withrespect to the processing of personal data that from time to time apply to thisPrivacy Policy, including the Regulation (EU) 2016/679 of the European Parliamentand of the Council of 27 April 2016 on the protection of natural persons with regardto the processing of personal data and on the free movement of such data, andrepealing Directive 95/46/EC (the "GDPR") as well as laws and regulationscomplementing the GDPR.
"Personal data" is defined as any information relating to an identified oridentifiable natural person.
Who is the data controller for the processing ofpersonal data?
Incharge Services Ltd, with the company registration no. HE 322510 and itsregistered address at Makariou III 34, Hadjiyianni Building, 4th floor, Office 401,Limassol, 3065 Cyprus, is the data controller with respect to the processing ofyour personal data as described in this Privacy Policy.
For information about processing conducted by our partners (e.g. in particular ourpayment services partner Intergiro Intl AB (publ.)), where such is a data controller,we refer to such partner's privacy policy.
From where we collect your peronal data?
Personal data is collected from you, as provided when you create an account withus or when you otherwise contact our customer service.
Purposes of the processing of your personal data
Categories of personal data
Legal basis
Identity data
Contact details
Your communication
Contractual necessity. The processing is necessary for the performance of our contract with you or in order to take steps at the request of you prior to entering into the contract.
Retention period: Personal data will be retained during our contractual relationship.
Categories of personal data
Legal basis
Identity data
Contact details
Your communication
Nature of the matter to be handled of our customer service
Legitimate interest. The processing is necessary to fulfil our legitimate interest in improving your experience on our website and to provide you with tailored content.
Retention period: Personal data will be retained during our contractual relationship.
Categories of personal data
Legal basis
All data collected that are necessary tofulfil the purpose.
Legitimate interest. The processing isnecessary in order to fulfil our legitimateinterest to establish, exercise or defend thelegal claim, e.g. in connection with adispute or legal process.
Exemption for special categories of data
Special categories of personal data,including criminal data, are only processed to fulfil our legitimate interest in establishing, exercising or defending legal claims.
Retention period: Personal data will be retained during our contractual relationship.
Categories of personal data
Legal basis
All data collected that are necessary tofulfil the purpose.
Legal obligation. The processing is necessary to fulfil Incharge's legal obligations.
Retention period: Personal data will be retained as long as necessary to fulfil each legal obligation.
Categories of personal data
Legal basis
All data collected that are necessary tofulfil the purpose.
Legitimate interest. The processing isnecessary to fulfil our legitimate interest inmanaging and protecting our website,services and related IT systems.
Retention period: Personal data will be retained as long as necessary in relation to each purpose stated above.
Disclosure and transfer
of personal data
Where necessary, we share your personal data with others. The recipient is the data controller for the processing of your personal data, unless we have stated otherwise.
Recipients
Purposes
Legal basis
Public authorities (including courts), arbitration tribunals, external advisers and counterpar
ties
In order to exercise, establish or defend legal claims.
Legitimate interest. To fulfil our legitimate interest in managing and defending legal claims, e.g. in relation to a dispute.
Public authorities (including courts) and external auditors
To fulfil legal obligations in the field of taxation and accounting.
Legal obligation. To fulfil our legal obligations.
Potential purchasers and vendors, external advisers
Take necessary actions in connection with selling all or part of the business or in connection with a merger.
Legitimate interest. To fulfil our legitimate interest in being able to sell all or part of the business or in connection with a merger.
Incharge’s business partners providing regulated services to Incharge users
In order to fulfil the routines and the verifications of the business partners regarding their internal measures against money laundering and terrorist financing.
Legitimate interest. To fulfil the legitimate interest of our business partners implemen
ting anti-fraud measures.
Payment services partners of Incharge providing regulated services to Incharge users:
• Intergiro Intl AB (publ)
• Finshark AB
• Quickbit EU AP (publ)
• Token GmbH
Incharge will share your personal data with our payment services partners for the purpose of providing you with their respective regulated service.
Intergiro Intl AB (Org. nr: 556965-3537) will act as a data controller for the shared personal data for its processing activities, for the following purposes:
1. setting up and using your payment services account; and
2. when required, for assisting us with solving any customer support enquiries you may have.
Finshark AB (Org. nr: 559203-3855) will act as a data controller for the shared personal data for its processing activities, for the following purposes:
1. Initiating payments on your Incharge account with the “Instant Bank Transfer” functionality for users located within Sweden, Finland and Norway; and
2. when required, for assisting us with solving any customer support enquiries you may have regarding the “Instant Bank Transfer” functionality for users located within Sweden, Finland and Norway.
Token GmbH (Org. nr: 217765 B - Germany) will act as a data processor for the shared personal data for its processing activities, for the following purposes:1. Executing payments on your Incharge account with the “Instant Bank Transfer” functionality for users located within the EEA but outside Sweden, Finland and Norway; and 2. when required, for assisting us with solving any customer support enquiries you may have regarding the “Instant Bank Transfer” functionality for users located within the EEA but outside Sweden, Finland and Norway.
Quickbit EU AB (Org. nr: 559066-2093) will act as a data controller for the shared personal data for its processing activities, for the following purposes:
1. Executing payments on your Incharge account with the “Crypto QB” functionality; and
2. when required, for assisting us with solving any customer support enquiries you may have regarding the “Crypto QB” functionality. For information about how our payment service partners process personal data, we refer to their respective privacy policy:
Intergiro's
privacy policyFinshark’s
privacy policyQuickbit’s
privacy policyToken.io’s
privacy policy
Contractual necessity. The processing is necessary for the performan
ce of our contract with you or in order to take steps at the request of you prior to entering into the contract.
Data processors acting on behalf of Incharge
In order to fulfil the purposes of the processing of your personal data, we transfer personal data to external parties such as service providers that we have engaged as well as other partners. These parties provide services within the areas of inter alia IT (such as data storage, support and management services), finance (e.g. our book-keeping system) and statistics services. These external parties will act as data processors of Incharge and may only process your personal data in accordance with our instructions and not for their own purposes. Incharge is the data controller for the processing of personal data that these external parties carry out on our behalf.
Appropriate safeguards for transfers of personal data outside of the EU/EEA
Should Incharge transfer or disclose your personal data to a recipient in a country outside of the EU/EEA (third country), Incharge will ensure that appropriate safeguards have been taken (such as the EU Commission's standard contract clauses, including other safeguards as necessary in each case) to protect the personal data.
You are, if so provided under Applicable Data Protection Laws, upon request entitled to receive a copy of any documentation demonstrating that appropriate safeguards have been taken in order to protect your personal data during a transfer to a third country.
If you would like to know more about the processing of your personal data and whether it is transferred to a third country, please contact us on the contact details as set out below.
Your rights
You have, under certain circumstances, the right to exercise the following rights:
Under Applicable Data Protection Laws, you have certain rights in relation to the processing of your personal data. We process your personal data to the extent necessary in order to fulfil your rights. Please submit requests for exercising your rights by contacting us on the contact details set out below.
You have, under certain circumstances, the right to exercise the following rights:
Access
You may request confirmation whether or not personal data is processed and, if that is the case, access your personal data and additional information such as the purposes of the processing. You are also entitled to receive a copy of the personal data undergoing processing. If the request is made by electronic means the information will be provided in a commonly used electronic format if you do not request otherwise.
You have the right to object to the processing of your personal data based on a legitimate interest for reasons which concerns your particular situation. In such a situation, we will stop using your personal data where the processing is based on a legitimate interest, unless we can show that the interest overrides your privacy interest or that the use of your personal data is necessary in order to manage or defend legal claims.
Rectification
You have at any time the right to have inaccurate personal data rectified, as well as, taking into account the purposes of processing, the right to have incomplete personal data completed which relates to you.
Erasure
You may have your personal data erased under certain circumstances, such as when your personal data is no longer needed for the purposes for which it was collected. However, we cannot delete your personal data if we e.g. are obligated under law to keep the data.
Restriction of
processing
Our solutions are designed with the end-user in mind, ensuring a seamless and intuitive experience for finance professionals at every level.
Withdrawal of
consent
You have the right to at any time withdraw your consent to processing of personal data to the extent the processing is based on your consent.
Data
Portability
You may ask to receive a machine-readable copy of the personal data processed on the basis of your consent or on the basis that the processing is necessary in order to perform an agreement with you, and which personal data have been provided to Incharge by you (data portability) and ask for the information to be transferred to another data controller (where possible).
Complaints to the supervisory
authority
You acknowledge that you always have the right to lodge complaints pertaining to the processing of your personal data to the Swedish Authority for Privacy Protection (Sw. Integritetsskyddsmyndigheten).
Contact information
If you have any questions or concerns regarding the processing of your personal data, please contact Incharge on the contact details set forth below.
