Last update: January 18, 2023
Data Controller: Klink Finance Limited, reg.no.14228138, legal address: Birchin Court 20 Birchin Lane, London, EC3V 9DJ.
Contact information: firstname.lastname@example.org
i) Data means personal and non-personal User’s data that is submitted, generated, featured and displayed through the Platform, collected from the use of the Service and stored.
ii) Data Subject means any living individual whose personal data is collected, held or processed by our Platform.
iv) Data Controller or Owner means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data, including the security measures concerning the operation and use of this Platform. The Data Controller, unless otherwise specified, is the Owner of this Platform.
v) GDPR means the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, namely the General Data Protection Regulation, on the protection of natural persons with regard to the processing and free movement of their personal data.
vi) Personal Data (or Data) means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
vii) Service means the service provided by this Platform as described in the relative terms and on this Platform.
viii) Platform means the website or application through which the Personal Data of the User is collected and processed.
ix) Usage Data means Information collected automatically through this Platform (or third-party services employed in this Platform), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Platform, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Platform) and the details about the path followed within the Platform with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
x) User means the individual using this Platform who, unless otherwise specified, coincides with the Data Subject.
WHO ARE WE?
As data controllers, we determine the purposes and means of your data processing activities. The data may be controlled by any of our subsidiaries may vary according to the jurisdiction you are residing in. If you have any questions or complaints regarding our data processing, you can contact us at email@example.com and provide us with a chance to deal with your concerns before exercising your right to make a complaint to any data protection regulatory authority.
Please note that our Platform also makes use of third-party plug-ins and applications (hereinafter “third-party sites”), enabling these sites allows third-party sites to collect your data. We have no control over the privacy statement and policies of these sites. You are advised to read through their policies before visiting or using these sites.
WHAT DATA DO WE COLLECT FROM YOU?
We collect the following personal data from you:
• Identity and contact information: These include your name, email address and phone number, identification documents and any other information you provide to prove you are eligible to use our Services.
• Unique Identifier Information: These include your username, password, and other registration information, your use of our Services and your participation in our Competitions, your Coin Balance, Number of tickets, transactions you effect through our app, any prizes you win and transactions we carry out to provide you with your cash prizes, your privacy and marketing preferences etc.
• Financial Information: These include your bank account details (such as account number, sort code and IBAN) which you have linked to your Profile, details of your Electronic Money Account which you share with us, your transactions, relevant information provided by fraud prevention agencies etc.
• Communications Information: These include records of your communications with us and our customer service team (such as records of emails, chat and in-app communications and voice recordings) etc.
• Technical information: This includes device identifiers, IP address, your location (if enabled by you), how you use our website and app etc. This information is mainly collected through cookies and you can refer to our Cookies Policy for more details.
We collect the following categories of Personal data for the following activities:
WHY DO WE COLLECT THIS DATA FROM YOU?
The personal information we collect varies according to user, transaction, and purpose, but our primary purpose is the efficient and satisfactory conduct of our business and for related legal purposes. Please not that you are responsible for any third-party personal data obtained, published, or shared through our Platform by you.
We use your personal data for the following purposes:
HOW DO WE COLLECT YOUR DATA?
This section explains generally the sources from which, and how we collect and process personal data.
i) During profile registration:
We collect Personal Data from you when you use certain services on our Platform including when you sign up for an account, create or share, and message or communicate. This can include information on or about the services you provide or about how you use our Services. Personal Data and other details about you that you supply as part of the registration process or that are collected by us when you use the Services are used to provide you with the Services and information as set out in our Terms of Service. We will not use that information for any purpose other than the Services.
ii) When you communicate with us:
If you contact us in relation to any of the Services (via email, telephone, post or otherwise), we may collect and retain your contact details and your communication for the purpose of handling your query and keeping records of communications. When your communications with us provide us with certain technical information, such as internet protocol (IP) address, browser type, time zone setting, location, device operating system, and other technologies that may be utilised for you to access our Platform or communicate with us otherwise.
iii) When you submit any personal information:
When you submit your personal information to us voluntarily for any purposes, we may retain such information and process it. This information may include details such as (name, age, gender, identity card number, passport number, date of birth, education, race, ethnic origin, nationality, citizenship, biometric information), contact details such as (address, email, phone numbers), family information such as (marital status, name of spouse or child or immediate family), occupation details, bank details such as (bank account number(s), card details) and other information. In addition, we may from time-to-time request for certain other personal information that may be relevant for us to consider your request for any other products, services or features made available on our Platform. Failure to supply such data may result in us being unable to open, establish, continue and/or provide Account, products, services or features in relation to guidelines issued by authorities.
iv) When you visit our Platform:
When you visit our Platform, we may collect your location data, GPS related and other relative information from the internet browser you are using.
v) When you link your payment institution:
When you link your payment institution to your profile on our Platform, we may collect information from your bank, any partner institution, crypto wallet and/or from any provider issuing and managing the distribution of e-money to you. This is required for us to provide our Services.
vi) When you link/interact with any social media account:
We may collect information related to your social media account once you connect it to our Platform and/or when you interact with us or our content through any social media features (e.g., the “Like” buttons) integrated on our Platform.
vii) When fraud prevention agencies and/or other third parties carry out identification checks:
We may also verify and source personal information/data about you from third party sources, (both public and private) such as your employers, regulatory or other authorities, the Financial Action Task Force (FATF) as well as from the public domain.
HOW WILL WE USE YOUR DATA?
We use the personal data we collect or receive from our Users for the purposes described in this Policy and for other business purposes allowed by law, including the development, delivery, and performance of our services, and sharing of such data with our affiliates for business related purposes, and as follows:
• To provide and maintain our Service.
• To manage your Account registration and usage.
• For the development, compliance and undertaking of the contract for the Services or of any other contract with us through the Service.
• To contact you by email, telephone calls, SMS, or other equivalent forms of electronic communication.
• To attend and manage your requests to us.
• To resolve disputes, investigate and address your concerns, and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Platform, databases, and technology assets and to detect and prevent transactional fraud.
• For testing, research, analysis, and a product and service development.
• For facilitating and processing your transactions with us and with our third party affiliates and business partners.
• To respond to law enforcement requests and as required by applicable laws, court orders, or governmental regulations.
• For fraud or crime prevention and investigation, transaction disputes, data analytics, audit and debt collection and in order that services may be processed by us.
• Conducting any action to meet our obligations to comply with Anti Money Laundering and Counter Terrorism Financing (“AML-CFT”) regulations and/or international guidance or regulatory requests relating to or in connection with the detection, investigation and prevention of money laundering, terrorist financing, bribery, corruption, tax evasion, fraud, criminal and/or unlawful activities, evasion of economic or trade sanctions and/or any acts or attempts to circumvent or violate any laws relating to these matters.
• For investigations or enquiries as to whether or not any user is a sanctioned person, or otherwise related to and/or associated with a sanctioned entity in any way; and for reporting or taking any remedial or preventive action in relation thereto.
• For our internal record keeping and/or any activity related or incidental to any above mentioned purposes.
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, to evaluate and improve our service, marketing and your experience with us etc.
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, as described hereinabove. You can obtain information on any of our balancing tests by contacting us using the details set out in the “Contact Us” section below.
Wherever we rely on your consent related to your data, you will always be able to withdraw such consent at any time. Please note that we may have other legal grounds for processing your data for other purposes including those set out hereinabove. You have the right to opt-out of direct marketing or profiling we carry out for direct marketing purposes at any time. You can do this by (i) clicking on the unsubscribe link in the relevant marketing communication, (ii) changing your marketing preferences through your Profile, or (iii) emailing us using the contact details given hereinabove. We do not use your personal data to make automated decisions about you which have a legal or similarly significant effect upon you. We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, as described hereinabove. You can obtain information on any of our balancing tests by contacting us using the details set out in the “Contact Us” section below.
METHODS OF DATA PROCESSING
We, at Klink Finance Limited, take appropriate security measures to prevent unauthorised access, disclosure, modification, or any unauthorised destruction of your data. The data processing is carried out using computers and/or IT enabled tools that follow organisational procedures and methods which are strictly in adherence to the purposes indicated in this Policy. In addition to us, the data may be accessible to certain types of persons in charge, involved with the operation of this Platform (administration, sales, marketing, legal, system administration) or external parties appointed by us (such as third-party technical service providers, mail carriers, payment providers, host servers), if necessary. The updated list of these parties may be requested from us at any time.
TRANSFER AND SHARING OF DATA
Depending on your location, your data may be transferred to a server in a country other than where you are resided, for storage or processing. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire from us using the information provided in the contact section. We may store, process, and/or transfer personal data to countries outside of the European Economic Area or EEA, including countries where the European Commission has not made a decision of an adequate level of protection of personal data, but in these cases we will ask for your consent regarding such a data transfer.
We may share your personal data with following recipients:
• Internal recipients – We may disclose your data to authorised employees who require such access in order to fulfil their role with us. Our employees are specifically trained with regards to the sensitivity, handling and protection of your data and its privacy.
• Judicial, administrative and other public authorities – We may share or disclose your data if required to do so by the law, by a request from a competent authority or regulator, to comply with a court order, to obtain legal remedies or defend our Platform’s rights, to contribute with investigations related to fraud, identity theft etc. We may also share your data with fraud prevention agencies: we share and confirm information with these parties so as to confirm that you are eligible to use our Services and prevent fraudulent activity through our Services.
• Service providers – We may share your data with third-party service providers who may process it on our behalf for the purposes identified in this Policy. These parties shall use your information on our instructions and only to the extent of providing us with their services. In particular, we may use third-party providers for website hosting, maintenance, payment provider services, mail carriers, customer support, marketing services, identity checking etc.
• Banks and payment institutions – We may share your data with the banks and/or other payment institutions and providers issuing and managing the distribution of e-money to you including any crypto exchange etc., which you link to your profile for the purposes of payment or transfer.
• Business advisers - We may share your data with our legal advisers, accountants, business consultants, insurers and other business advisers, to the extent as is necessary for them to provide us with their services.
• In the event that our business is sold or integrated with another business – We may share your data with our advisers and/or any prospective purchaser’s adviser and such data shall be passed to the new owners of the business/our legal successors.
Please note that we publicly disclose the identity of the winners of our sweepstakes, unless you specifically ask us not to do so.
We will store your data for as long as it is required for us to fulfil the purposes for which we have collected it, as described in this Policy, and for such further period as is necessary to comply with our legal and regulatory obligations, to exercise our legal rights and to protect our business from legal claims ancillary thereto. Therefore:
• Personal Data collected for purposes related to the performance of a contract between us shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the our legitimate interests shall be retained as long as needed to fulfil such interests. You may find specific information regarding the legitimate interests pursued by the us within the relevant sections of this Policy or by contacting us.
We may retain your data for a period longer than mentioned hereinabove, after seeking your consent to such prolonged retention up until you withdraw your consent. Once the retention period expires, your data will be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
YOUR RIGHTS RELATED TO YOUR DATA
You have the right to exercise any or all the following rights in relation to your data shared, stored, processed and/or retained by us:
• Withdraw consent at any time: You have the right to withdraw your consent to the processing of your data at any time.
• Object to processing of your data: You have the right to object to the processing of your data even if the processing is being carried out for legal reasons other than those based on your consent. Further details are provided in the dedicated section in this Policy.
• Access Data: You have the right to learn how your data is being processed by us and obtain disclosure regarding certain aspects of the processing.
• Verify and seek rectification: You have the right to verify the accuracy of your data and ask for it to be updated or corrected.
• Restrict the processing of your data: You have the right, under certain circumstances, to restrict the processing of your data. In such a case, we will not process your data for any purpose other than storing it.
• Deletion or removal of your data: You have the right, under certain circumstances, to request the erasure or removal of your data from our Platform.
• Request details or transfer of your data: You have the right to request the details of your data in a structured and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data is processed through automation and that the processing is based on your consent, on a contract which you are a party to or on any pre-contractual obligations thereof.
• Lodge a complaint: If you have any unresolved concern, you have the right to complain to the data protection authority. However, we will appreciate it if you address your issues with us first before approaching the relevant authorities, and we will try our best to resolve your issues. Any requests regarding your user rights can be made to by writing to us directly at our e-mail provided hereinabove. These requests can be made free of charge and will be addressed by us as early as possible. If any of these issues further persist, you can send a request to the relevant data protection authority.
Intellectual Property Rights
You acknowledge and agree that:
(i) any trademark, logos or other proprietary marks related to intellectual property used in our Platform are either owned by us or licensed to us by third party licensors;
(ii) no rights related to such intellectual property has been granted to you through your use of our Services and/or Platform;
(iii) no part or parts of the Platform may be reproduced, republished, displayed, hyperlinked, modified, adapted, distributed or otherwise commercially exploited in any manner whatsoever or stored in any system without a prior written consent by us.
You shall not use, scan, capture or otherwise share information on our Services and/or Platform, or otherwise use any data-mining technology to conduct any non-authorised activity, and shall not allow its agent or subcontractors to do the same. Data mining is strictly prohibited. Any violation of such would make you liable to Applicable Laws.
Except as expressly provided through a written agreement granting consent for sub-licensing for any rights, a Licensee shall not grant sublicense to any agent, subcontractor or other third party. Incase of such consent, the Licensee shall be responsible for the conduct of all sub-licensees and the operations of all sub-licensees shall be deemed to be the operations of the Licensee.
Your data may be used for legal purposes by us in Court or at any stage leading to a possible legal action which may arise in relation to our Platform or related Services.
System logs and maintenance
For operation and maintenance purposes, this Platform and our third-party partners may collect data recording your interaction with our Platform (System logs, IP address etc.) for such purpose.
Information not contained in this policy
Any further details regarding the collection or processing of your data may be requested from us at any time. Please see our contact information regarding your queries.
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