Privacy Policy

By using this Website and/or the Services provided by Ovvio, you agree to the processing (as defined below, see "Definitions"), including collection and use of your Personal Data (as defined below, see "Definitions") in accordance with this Privacy Policy Notice (the "Notice"). Unless otherwise defined in this Notice, terms used in this Privacy Policy have the same meanings as in our Terms of Service at [https://www.ovvio.finance/terms-conditions].

Generalities

This Notice describes the processing of Personal Data when you use the websitehttps://www.ovvio.finance/ (the "Website") as a visitor, user, and/or client, and/or when you use the services (the "Services") provided by Eazypay Swiss Ltd (IDE CHE- 401.397.334), registered office in Geneva, Switzerland ("Ovvio", "We (we)", or "us").

Ovvio carries out the processing of the data lawfully, proportionately and in good faith. We will not use or share your Personal Data with anyone except as described in this Notice.

For the purposes of this Notice, Ovvio shall comply with the applicable data protection laws of Switzerland (in particular, the Federal Act on Data Protection (FDPA) and the Ordinance to the Federal Act on Data Protection) and, when offering its services to the clients in the European Union (EU), the laws and regulations of the EU, in particular the General Data Protection Regulation (GDPR), as law, ordinance and regulation may be amended from time to time.

Definitions

"Processing" means any operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

"Personal Data" under this Notice, we mean any information through which we can identify you as an individual. Anonymized data are not considered as Personal Data within the meaning of this Notice.

Notice Review

Ovvio may update this Notice and its content from time to time. Ovvio will notify you of any changes by posting the new Privacy Policy on its Website. Changes to this Privacy Policy are effective when they are posted. Please review this Privacy Policy periodically for any changes.

General purpose of Personal Data collection, processing and use

We may use your Personal Data to:

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provide and improve the Website, the Services and products (such as any application) provided to you;
open an account to use our Services;
verify your identity;
customize this Website, the products or our Services to individual users or group of users;
notify or contact you about the Services provided by Ovvio and other information that we believe may be of interest to you (including the marketing of our Services or products);
respond to your queries, questions and complaints;
communicate with you. We may use your Personal Data to contact you with newsletters, marketing or promotional materials, and other information that we consider may be of interest to you. [You may opt out of receiving any, or all, of these communications from us (see "Opting out of email marketing").]
protect and/or enforce our legal rights and interests, including defending any claim;
share your Personal Data with other persons if we have a good-faith belief that access, use, preservation or disclosure of that Personal Data is reasonably necessary to (i) meet any applicable law, regulation, legal process or enforceable governmental or regulatory body request, (ii) enforce or investigate potential violations of our Terms of Service or other contract provision, (iii) and/or detect, prevent, or otherwise address fraud, security or technical issues, (iv) allow us to provide better services to you, (v) and for any other purpose authorized by you or by law.

You will find more details on specific data collection, processing and use in section "Specific extent and purpose of Personal Data collection, processing and use" below. You will find more details on your rights in the section "Information, right of access, correction, deletion, restriction, portability, right to complain, revocation and right to object" below.

Legal basis for processing your Personal Data

Ovvio is processing Personal Data according to the applicable data protection laws. The following describe the legal basis for processing your Personal Data:

acting upon your consent. You may withdraw your consent at any time by contacting us (see the section "Contact" below);
performing an agreement to which the you are a party, or if taking steps at your request before entering into an agreement. This includes any Services provided according to our Terms of Service;
ensuring compliance with our legal obligations, such as anti-money laundering obligations;
pursuing our legitimate (business) interests or those of third parties, which include, but is not limited to:

managing our CRM system and databases, and contacting you for marketing or other commercial purposes (see also "Offline processing of client data");
detecting fraud, preventing crimes, hacking, spamming etc.;
protecting integrity of our systems and ensuring optimal functioning and security of our Website, any application and our Services;
measuring the effectiveness of our marketing and improving it;
developing our business activities and improving the quality of our Services or products;
pursuing management, recordkeeping, training and learning purposes; and
managing business operations and facilitating corporate transactions.

You will find more details on specific data collection, processing and use below. You will find more details on your rights in the section "Information, right of access, correction, deletion, restriction, portability, right to complain, revocation and right to object" below.

Specific extent and purpose of Personal Data collection, processing and use

Website visit/access

The provider of this Website and its pages automatically collects and stores information in so-called "server log files" (the "Log Data"), which your browser communicates to us automatically. The Log Data comprises in particular:

the type and version of browser used
the used operating system
name and Uniform Resource Locator (URL) of the data accessed
the hostname of the accessing compute
the data and time of the server inquiry
the Internet Protocol (IP) address

The Log Data is not merged with other data sources. IP address of the requesting computer or device. The Log Data is collected and processed for the purpose of allowing the use of the Website, ensuring security and stability of the Website and allowing improved online offering as well as for statistical purposes. The collection and storage of the Log Data do not require any action on your side and such data is automatically deleted after twelve months. We rely on our legitimate interests to process the above data for these purposes.

Use of contact form for general requests/inquiries

The following Personal Data are required in order to use the online form for general requests or inquiries available on our Website:

name (first name and surname)
email address
message/requests

We use this data to be able to process your contact request, in particular to reply to any question or provide the requested Services. We rely on our legitimate interests to process the above data for these purposes.

Contact via email

You may contact Ovvio by using the email address available on our Website info@base10.finance. In such a case, Ovvio will collect the Personal Data you voluntarily provide us. This data are necessary to allow us to process your contact request. You are sole responsible for any communication or content you submit to Ovvio, including sensitive information. To reply or answer, we may have to require additional information from you, such as for instance your address or your telephone number. We rely on our legitimate interests to process the above data for these purposes.

Registration as client

In order to benefit from our Services, you can register as a client (either an individual or corporate client). When you contact us to register as client, we collect the following data:

company name (if relevant)
name (first name and surname)
email address
phone number
additional information you want to provide us with
language

To open a client account/relationship, we request additional information:

birthday (day/month/year)
nationality
address (Street/Zip Code/City/State/Country)
citizenship
regulatory requirements (in particular KYC and AML information/documents)
photo of international passport or European ID)

We use this data to enable you to use our Services and get in contact with you. We collect these data to fulfil our pre-contractual and contractual obligation.

Cookies

Ovvio's Website uses cookies. Cookies are small text files that are permanently or temporarily stored on the computers of visitors when visiting our Website. The purpose of the cookies is specifically to provide a statistical analysis of the use of our Website in order to allow for improvements to be made. Ovvio's Website visitors and users can disable the use of cookies on our Website, in whole or in part, in their browser’s cookie or privacy settings at any time. If cookies are disabled, however, Website visitors and users may no longer be able to access all of our Website's functions.

You may find the direction to disable cookies at the following links:

We also provide you with the option to select or deselect the cookies through the cookie banner that appears on the screen when entering the Website.

The legal basis for processing the above data in line with the aforesaid purpose lies in the consent you have given to us via the cookie banner or respectively in our legitimate interest in ensuring the functionality and optimization of the Website.

Offline processing of client data

Ovvio collects data about its clients (corporate and individuals) (the "Client Data"). Client Data may be collected offline for the purposes of providing the Services. In particular, in case of corporate clients, Ovvio collects the contact details of the contact persons of its client. Further, Ovvio collects the following data of corporate and/or individuals:

name (first name and surname)
birthday (day/month/year)
nationality
email address
phone number
address (street/zip code/city/state/country)
citizenship
regulatory requirements, such as KYC and AML information/documents
photo of international passport or European ID (incl. document number, expiration date (month/year), issuing country)
photo of you and your document of identification
proof of domicile, no older than 3 months, such as utility bill or bank statement)
profession and industry/sector
purpose of the business relationship
expected trading volume
annual income
type of income assets
origin of funds used in your business relationship with Ovvio
your wallet ID

We use this data to open our relationship with you and to enable you to use our Services. Furthermore, we collect this date to comply with our legal obligations. We collect this data to fulfil our pre-contractual and contractual obligations and to comply with legal obligation to which we are subject to.

Third-party services and tools

We may use third-party services, including but not limited to:

Services supplied by Google Inc. This includes the Google AdWords remarketing service and Google Mail. We also use the tool "Google Analytics" to collect information about your use of the Website. Google Analytics collects information such as (i) anonymized IP address and location (city and country), (ii) our websites you are visiting, (iii) User ID, (iv) language settings, session duration, actions, frequency and recency, and (v) aggregated data if Ads Personalization is turned on. We use the information we get from Google Analytics only to improve our Website and our Services. We do not combine the data collected through the use of Google Analytics with personally identifiable information. Google's ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: [http://www.google.com/settings/ads]. Google also recommends installing the Google Analytics Opt-out Browser Add-on – [https://tools.google.com/dlpage/gaoptout] – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/policies/privacy/.

The legal basis for the aforementioned processing lies in the consent you have given Ovvio via cookie-banner respectively on our legitimate interest to make our Services more user friendly and to optimize them.

The third-party services and tools may collect, monitor, and analyze information, including your Personal Data, to support our activities and increase our Services' functionality. These third-party services may use cookies, or otherwise process your Personal Data, to help us analyze how our visitors and/or clients are using this Website and/or the Services. Ovvio uses remarketing services to advertise on third-party web sites to you after you visited this Website. We, and our third-party vendors, use cookies to inform, optimize and serve ads based on your past visits to this Website. These third parties have their own privacy policies addressing how they process Personal Data.

Our Website may contain links to other sites including social media buttons, that are not operated by us. If you click on a third-party link, you will be directed to that third-party's site. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for any third-party sites or services' content, privacy policies, or practices. We are not responsible for the processing Personal Data by the relevant third parties.

We may also use social media companies' analytics tools to review from time to time our social media communication. These tools can also be used to optimize advertising materials. If you want to disallow any social medial companies from tracking your behavior on this Website, their website or on other webpages, please see their privacy policies and options.

Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to Services requests, or for other non-marketing purposes. To otherwise opt-out, you may either (i) access your account settings and update your preferences, or (ii) contact us to request to be removed from the marketing email list.

Disclosure of Personal Data to third-parties

We only transfer your Personal Data to third parties if you have given us your explicit consent, if there is a legal obligation to do so, or if it is necessary for the enforcement of our rights. In addition, we will disclose your Personal Data to third-parties as far as it is necessary for the use of the Website, the Processing of your contact requests or inquiries and the providing of any Services you requested. The use of data by third-parties is strictly limited to the aforementioned purposes. Several service providers to whom your Personal Data is forwarded are already mentioned above. Another service provider to whom Personal Data collected on the Website is forwarded or who has or could have access to said data, is our website hosting company. The Website is hosted on servers provided by Amazon Web Servcies. The data is shared for the purpose of providing and maintaining the functionalities of our Website.

Transmission of Personal Data abroad

Ovvio is entitled to transfer your data to third-party companies located abroad to the extent this is required in connection with the Processing described in this Privacy Notice. Any such third-party companies are required to respect the privacy of users to the same extent as the provider itself. If the level of data protection in a jurisdiction does not correspond to the Swiss or European level, we will ensure, by means of a contract (Standard Contractual Clauses), based on a adequacy decision in accordance with Swiss data protection rules or GDPR or upon you explicit consent that the protection of your Personal Data corresponds to that in Switzerland or the EU at all times.

Information, right of access, correction, deletion, restriction, portability, right to complain, revocation and right to object

Subject to certain exemptions and exceptions set out in the FDPA, respectively GDPR, you have certain rights in relation to the Personal Data processed by Ovvio, namely:

information right. You have the right to be informed about the collection and use of the Personal Data. Ovvio generally informs the data subject about the data collection by the mean of this Notice;
right of the access. Upon your request, Ovvio will give you access to your Personal Data by confirming whether Ovvio is processing your Personal data, on what legal basis, and will provide you with a copy of Personal Data processed;
correction right. You may at any time request to rectify inaccurate or incomplete Personal Data;
deletion right. Under the certain circumstances provided by law, e.g. listed in the art. 17(1) GDPR and equivalent legal basis in the FDPA, you may request to erase your Personal Data;
right to restrict processing. If one of the conditions listed in the art. 18(1) GDPR applies and equivalent legal basis in the FDPA, you may restrict Personal Data processing;
data portability right means that you may request Ovvio to provide a copy in a machine-readable format of certain Personal Data that Ovvio processes;
right to complain. You may at any time contact Ovvio with your concerns with regard to this Notice. You may also complain to an appropriate data privacy regulatory authority, such as the Federal Data Protection and Information Commissioner (FDPIC) in Switzerland. A list of local data protection authorities in EEA countries is published here;
right of revocation. You can at any time withdraw your consent for the processing of your Personal Data. Please note that a withdrawal of consent does not affect the lawfulness of any processing that has taken place prior to consent withdrawal, and that we can only give effect to your request in accordance with applicable law;
right to object. You may object, on grounds relating to your particular situation, if the lawfulness of the data collection is based on the public interest or legitimate interests of the controller or third party.

The above-mentioned rights are subject to some exemptions in case the public or Ovvio's legitimate interest is in question. Ovvio shall check whether you are entitled to the exercised right and contact you as a rule within one calendar month. Demand or request that is more complex or multiple demands or requests may require additional time to be processed by us. If we need additional information from you to be able to deal with your request, the time limit will begin once we have received this information.

Data retention

Ovvio only stores Personal Data for as long as is necessary to carry out the above tracking services and further processing in the context of its legitimate interest. Ovvio keeps contract data for longer, as this is required by legal storage obligations. Obligations to store data results in particular from accounting and tax regulations. According to this regulations business communication, conclude contracts and accounting documents must be stored for up to 10 years. Anti-money laundering regulations also impose retention obligations for all relevant anti-money laundering documents for a minimum of 10 years after the termination of the business relationship or completion of the transaction.

Data security

Ovvio takes all the reasonable technical and organizational security measures that it deems appropriate in order to protect your stored data against manipulation, loss, or unauthorized third-party access. [In particular, among other measures, for security reasons and to protect the transmission of confidential content, this Website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from "http://" to "https://" and by the appearance of the lock icon in the browser line, if the SSL or TLS encryption is activated.] Our security measures are regularly review and adapted to technological development.

While Ovvio strives to use commercially acceptable means to protect your Personal Data, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your Personal Data, transmission of personal information to and from our Website and when using our Services is at your own risk. You should only access the Website and use our Services within a secure environment.

Contact

You can contact us with any question, request or complaint with regard to this Notice or your Personal Data.

Ovvio Ltd

Rue du Rhône 118

1204 Geneva

Switzerland

E-mail: info@ovvio.finance

Last update: April 2023

Ovvio finance Privacy Policy