GlolinkOTC s.r.o. are committed to protecting and respecting your privacy. GlolinkOTC s.r.o. clients information collected about you to meet legal obligations and provide a better service.
In the Privacy Policy, we provide you with information on how and why we might collect, store, use, and/or share “process” any information that relates directly or indirectly to you, your right to privacy and its protection.
– Personal data; any information that is or may be relevant to the Data Subject, such as name, surname, personal identification number or identification number, address, telephone number, e-mail address, video surveillance, economic and other actions specific to the Data Subject.
– We collect personal information that you voluntarily provide to us when you trying to do businesswith us or to get products and Services, when you participate in activities on the Services.
For natural person:
– Name and Surname
– Date of birth
– Citizenship
– Personal code
– Address of residency
– E-mail address
– Phone number
– Copy of your ID document (passport, national ID card)
– IP address
Sensitive Information: Financial data. “The Company shall be entitled to obtain any additional information if the Company finds it necessary to properly & duly establish the identity of the Customer”.
For Legal person:
– Full legal name
– Company number
– Legal form
– Place of business (Registered office address)
– E-mail address
– Phone number
– Websites
– IP address
– “Ultimate beneficial owners” all the information about natural person as given above
– Information about representative of the Company (all information about natural person given above)
– Documents (Articles of Association or another)
– Business activity
Sensitive Information: Financial data: Source of funds, Data on the nature of income.
The main way how we get that kind of personal data is when you provide it to us such as when you:
– Applying for services
– Contacting us by post, e-mail or by phone
– Using our services, incl. visiting our office, visiting our website.
– When we obtain information from third parties such as identity verification services.
When you use the GlolinkOTC s.r.o. platform we collect information on your transactions and other use. We will process your Personal Information only for the purpose(s) of providing to you the service(s) that you ask us to provide and to satisfy the legal obligations stemming from regulatory obligations that arise from providing you the service(s).
– To allow you to use our services on the Platform;
– To process transactions on the Platform;
– To reply to your e-mails or contact you about GlolinkOTC s.r.o. services;
– To analyse use of our Site;
– Verify your identity in accordance with applicable know-your-customer, money laundering and other financial sector legislation or regulations, including as required for compliance with the GlolinkOTC s.r.o. Anti Money Laundering notice, as well as address other law enforcement needs as more fully described in our Terms of Use, and generally as required for compliance with legislation and regulations applicable to GlolinkOTC s.r.o.;
– We need to understand the nature of business and management structure of the Company, obtain the preliminary monthly transaction volumes for the Customer – legal person;
– To verify your identity to protect against fraud, comply with financial crime laws, and to confirm your eligibility to use our products and services.
– We may be use your personal data to send you information related to our marketing communications, dedicated personally to you considering your data.
We may collect information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns and will
not be used to identify any individual unless that same individual. Your data is only accessed internally on a need to know basis, and it will only be accessed or processed if absolutely necessary. We will delete data that is no longer required by any relevant law or jurisdiction in which we operate.
– Correspondence: Information that you provide to us in written or oral correspondence, including using GlolinkOTC s.r.o. services, and with respect to ongoing customer support.
– Location Information: Information that is automatically collected via analytics systems providers to determine your location, including your IP address and/or domain name and any external page that referred you to us, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform;
– Log Information: Information that is generated by your use of GlolinkOTC s.r.o. Services that is automatically collected and stored in our server logs.
We use information we collect in various ways, including the following:
– Providing, operating and maintaining our Services;
– Processing payments, executing Orders, Trades and Transactions in a manner consistent with the rules of market fairness, trasparency, competitiveness, and genuinity;
– Detecting and preventing loss of funds, including losses occuring as a result of fraud and abuse of our Services;
– Ensuring compliance with the relevant laws and regulations to prevent anti-money laundering, terrorism financing, fraud and other financial crimes;
– Complying with the anti-financial crime regimes and obligations, regulated and imposed by the competent authorities of Czech Republic, such as the Financial Analytical Office (Finanční analytický úřad hereinafter, the “FAU”);
– Communicating with you, including direct means or through our partners, to perform customer support activities, to inform you of the changes and updates related to the Services, to notify you of important information related to the Services and for marketing and promotion;
– Sending you e-mails, including notification e-mails, reminders and confirmations;
– Improving the quality of our Services;
– Conducting research and development related to our Services to develop new features and functionalities and introduce new products and services;
– Performing measurement and analytics activities to learn how our users interact with our Services and understand our users’ behaviour and preferences;
– Promoting safety, security and integrity of your funds, our Services and data.
We may share the information we collect in various ways and third parties.
We provide information we collect to vendors and services providers that help us keep our business running. Such vendors include (but are not limited to) payment platforms, web and mobile analytics services, advertisers, partners in IT such as hosting and software providers as well as sales and
marketing products.
Please note that some of our service providers are located outside the EU/EEA region. For detailed information on how your data is handled when shared with third parties outside the EU/EEA, please refer to the International Transfer of Data section of this policy.
– We strive to enhance the security of personal information you are entrusting us with. Therefore, we opt for the most secure and diligent data processors to do the task. Some of such processors are located overseas outside of the EU/EEA area in countries that have different regulations on personal information. However, our partners follow the requirements and safeguards of the GDPR when receiving and handling your personal information that we share with them.
– For transfers of information to and from processors located in the UK, the European Commission adequacy decision has been adopted, meaning that data may flow freely from the EU/EEA to the UK and back since the EU considers the data protection regime in the UK essentially equivalent to the regime of the GDPR.
– For transfers of information into the EU from other countries covered by the European Commission adequacy decisions, such as Andorra, Argentina, Canada, Faroe Islands, Guernsey, Isle of Man, Israel, Japan, Jersey, New Zealand, Switzerland and Uruguay, we are required to comply with the local legal requirements and regulations on transfers of personal data, therefore we make sure the specific arrangements are being followed when receiving data from any of the aforementioned countries.
– For transfers of information to processors located in the US, we no longer rely on processors that are certified under the EU-US Privacy Shield Framework because it has been invalidated in 2020 by the decision of the European Court of Justice.
How long we store your Personal Data depends on the purposes for which we process it and the criteria by which we evaluate the retention periods of your Personal Data.
When determining the terms of storage of your Personal Data, we evaluate:
– The need to store your Personal Data to ensure the performance of a valid service agreement;
– The need for the storage of your Personal Data for the fulfillment of legal obligations, for example, in accordance with the term of 5 years specified in the “Law on the Prevention of Money Laundering and Terrorist and Proliferation Financing” and within the time limits for storage of various documents specified in other legal acts;
– Retention of your Personal Data to protect our interests in the event of various claims after the termination of the business relationship with you, for example, for 10 years in accordance with the general limitation period for liability rights;
– our or a third party’s legitimate interests that could be harmed in the event of the deletion of your Personal Data, for example with regard to your right to restrict the processing of data;
– The need to store your Personal Data in order to provide evidence of lawful processing of Personal Data during the previous period, such as the existence of your consent to previous processing operations;
– If the processing of your Personal Data is carried out on the basis of the Consent, as long as your Consent for the relevant purpose of the processing of Personal Data is valid, in the absence of another basis for the processing of your Personal Data. If, during the evaluation, we find different reasonable retention periods for your Personal Data, such as between the statutory retention period and the period required to protect our interests, this will
be a sufficient basis for storing your Personal Data longer. If one or more of the following criteria are met, we will ensure that your Personal Data is deleted or anonymised.
– GlolinkOTC s.r.o. may use processors to process Personal Data. We ensure that all our processors process personal data in accordance with our instructions, applicable law and take all appropriate organizational and technological security measures.
– Technical and organisational security measures in place will, from time to time, be reviewed in line with legal and technical developments.
– In the event of a personal data breach or the failure of the measures of protection of such information we will immediately notify you without undue delay.
As part of our compliance with privacy and Personal Data protection laws, we act in accordance with your rights, if you submit a written request to us:
1) revoke the given consent to the processing of your Personal Data at any time (in case of issuing the Consent), informing us about it by e-mail in the form of an application using an e-signature.
2) access your Personal Data and receive from us:
– confirmation or rejection of whether or not we process your Personal Data;
– information about your Personal Data that we process;
– additional information about the processing of your Personal Data in order to verify the accuracy of your Personal Data and whether we process your Personal Data in accordance with legal requirements.
3) to correct your Personal Data if you reasonably believe that your Personal Data is inaccurate, as well as, taking into account the purposes of processing your Personal Data, to supplement incomplete Personal Data.
In the event that your Personal Data has changed, as well as if you have identified that we process inaccurate or incomplete Personal Data, please inform us about the need to correct it. In this case, we have the right to request you to present documents supporting the correction.
4) delete your Personal Data if:
– consider that it is no longer necessary or usable for the original purposes of the processing of Personal Data;
– You have reasonable grounds to believe that your Personal Data is being processed unlawfully;
– The deletion of your Personal Data is determined by the data retention periods specified by law.
We will ensure the deletion of your Personal Data in our possession, including deletion from our cooperation partners, if the Personal Data is no longer necessary for the purposes for which we processed it. We will not be able to ensure the deletion of your Personal Data if we are required to provide for such processing in cases required by law, ensuring the retention periods for information or documents set out, for example, in the “Law on the Prevention of Money Laundering and the Financing of Terrorism and Proliferation“. We also have the right to refuse to delete your
Personal Data if it requires a disproportionate effort.
5) restrict the processing of your Personal Data if:
– You dispute the accuracy of your Personal Data; the restriction will apply only for the time during which we will be able to verify the accuracy of your Personal Data;
– You consider that the processing of your Personal Data is illegal and you object to the deletion of the Personal Data by requesting instead a restriction on the use of the Personal Data; the restriction will apply only to the term reasonably specified by you;
– we no longer need your Personal Data, but it is necessary for you to exercise or defend legal rights and interests, make claims, etc.; the restriction will apply only to the term reasonably specified by you;
– You object to the processing of your Personal Data by us on the basis of our legitimate interests, but the restriction only applies for as long as we re-evaluate such legitimate interests.
However, in exercising this right, we will have the right to process your Personal Data, for example to exercise or defend legal rights and interests, to bring claims, the rights of another natural or legal person. We will ensure that your Personal Data held by us and our partners is restricted, if a disproportionate effort is not required.
6) transfer your Personal Data, which we have received from you on the basis of the Consent and the established contractual obligations and which we process by automated means, for personal use or transfer to another service provider, if there are no obstacles to such a transfer of Personal Data. We would like to inform you that the information subject to the portability of your Personal Data may also contain the data of third parties, therefore we will assess the impact of the transfer of this Personal Data on the rights and freedoms of third parties.
7) object to the processing of your Personal Data based on Our legitimate interests. We will have the right to process Personal Data if it is necessary to exercise or defend legitimate rights and interests, to bring claims (for example, for the purpose of legal proceedings).
You will not be able to exercise this right if you have given your Consent to the Processing of your Personal Data or if the Processing of Your Personal Data by us is necessary for the conclusion or performance of the agreement.
8) abandon automated individual decision making, incl. Profiling
With regard to automated individual decision-making, incl., Profiling, which may have legal consequences for you, negative consequences, you have the right to waive such automated individual decisions, incl. Profiling. You will be able to exercise these rights in cases where we need it to enter into or perform an agreement with you, in the cases specified by law, as well as when you have given your exp
GlolinkOTC s.r.o. activities and operations are subject to supervision by the Financial Analytical Office (FAÚ), which is the responsible authority overseeing the appropriate implementation of AML/CTF measures. ICO: 19443641
Users from the UK resident community and those with UK IP addresses cannot access our services.
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