WE CARE ABOUT THE PROTECTION OF YOUR PERSONAL DATA

Whether you are a customer of RYVYL (EU), an interested person or a visitor to our website, we recognize and respect the integrity of your personality.

Who are we?

RYVYL (EU) is business company listed in the Commercial Register of the Registry Agency under UIC: 121554961, with registered office and management address at Sofia 1000, Triaditsa District, 2 Pozitano Square, “Perform Business Center”, tel: +35924373301, e-mail: office@ryvyl.eu. The company operates as a personal data controller in compliance with the provisions of the Personal Data Protection Act.

How can you contact the official in charge of personal data protection at RYVYL (EU)?

Address: Sofia 1000, Triaditsa District, 2 Pozitano Square, “Perform Business Center”

e-mail: dpo@ryvyl.eu

RYVYL (EU) respects the confidentiality of your personal data.

The protection of your personal information throughout the entire process of personal data processing and the security of all business data is an important issue for us. We process your personal data in confidentiality and in observance of the domestic and European statutory regulations.

What is personal data?

Any information or data that can either directly or indirectly identify an individual.

For example, your telephone number is an indirect identification, whereas direct identification is achieved when you provide a unique identifier such as PIN, Foreigner’s Personal Number, Customer’s Code, etc.

What type of personal data does RYVYL (EU) collect from you?

In order for RYVYL (EU)to be able to grant you an effective access to its products and services, it has to collect from you the following information:

•    Personal data that identifies you:

Name, surname, family name, PIN/Foreigner’s Personal Number, address, date of birth, identity card details, place of birth, nationality, telephone number, e-mail address, current photo, another identifier from a foreign country.

•    Data related to the performance of transactions:

Customer’s number, IBAN, payment orders, proceeds to a payment account, balance of payment account, as well as cash orders to other domestic and foreign accounts.

•    Financial state data:

Payments’ history, participation and/or ownership of company shares or securities, tax number, details of the RYVYL (EU) financial services and products used by you, information on income not related to employment.

•    Social and demographic information:

Related persons.

•    Data on your online conduct and preferences:

IP addresses, cookies, GPS coordinates, details about your visits to our website and the applications used by you, and information on the devices from which these visits are made – this helps us find out if you are still on our site or if you are using a mobile application.

•    Information about the interests and desires you share with us:

For example, through our website’s contact form or the portals for opinion sharing.

Information on the use of “cookies”

Our website uses cookies. To learn more, please visit Cookie policy.

What’s included in the processing of personal data?

The processing of personal data includes collecting, storing, destroying, transmitting, correcting, updating, deleting, destroying and performing all kinds of other activities with your personal data.

For what purposes and on what grounds does RYVYL (EU) collect and process personal data?

RYVYL (EU) processes your personal data in compliance with its statutory duties. Being an electronic money company, RYVYL (EU) should meet a number of regulatory requirements imposed by the Bulgarian legislation (the Payment Services and Payment Systems Act, the Law on the Measures Against Money Laundering, the Rules for the Application of the Law on the Measures Against Money Laundering), the European regulatory framework and ratified international acts. RYVYL (EU) is subject to supervision during which it could also process personal data.

Measures for your security

We process your personal data with the purpose of:

•    Preventing fraudulent actions / crimes (e.g. identity theft, computer hacking).

•    Guaranteeing IT security.

•    Using it in legal disputes.

We assure you that our processing of your personal data is carried out in full observance of the applicable European and domestic legislation related to the protection of personal data. We inform you that you may at any time object/withdraw your consent to the processing of your personal data for marketing goals.

RYVYL (EU) collects your data so as to fulfill its duties under the contracts concluded with you for the provision of services.

We collect your data so that you could use our products and services, and thus you enable us to inform you on everything associated with these products and services. This also applies to our pre-contractual relationships, i.e. upon your filing of an application/request for the use of a product of ours during the negotiating process. We may use your personal data to analyze and evaluate your needs in order to eventually offer you a product that is better than the one sought.

•    Further to our contractual duties, we also process your personal data during the performance of payment transactions.

•    We collect your personal data to check if there are any products and services that we could offer you.

•    We grant you access to our website and show you content which is relevant, personalized and restricted in accordance with the criteria set by you.

Furthermore, RYVYL (EU) collects personal data following the receipt of your exclusive, clear, free and unambiguous consent to the goals of processing.

Consent to the processing of your personal data is granted upon the submission of an application for a certain service or through your profile stored in our electronic banking system.

The consent provided by you may always be withdrawn either through your profile stored in our electronic banking system, or if you send us your application for consent revocation.

RYVYL (EU) is also entitled to process personal data in the case of a legal (legitimate) interest, unless this interest is less advantageous than the individual’s interests the said data is related to.

In what way do we process your personal data?

In order for RYVYL (EU) to be able to provide its products and services, it shall process (collect) the personal data provided by you in the following manner:

•    Upon your completion of applications, forms and declarations. The forms shall be provided by RYVYL (EU) and/or PSP employees;

•    Upon the sending from our website of online consent declarations;

•    Upon the sending of online consent declarations from your profile in the electronic banking system;

•    Upon the updating of data at your request and the issuance of an update form as a hard copy or an electronic document;

•    Upon the processing of information on your visits to the website of RYVYL (EU), including data on electronic banking;

•    Upon the processing of information about IP addresses, cookies, operational system, and browser type;

•    Upon the mailing of appropriate for you offers on RYVYL (EU) products and services.

How long do we store and process your data before destroying it?

The period for which your personal data is stored depends on the reasons for its processing.

•    For the purpose of pre-contractual relationships and researches in various data bases of individuals interested in products or services, the storage period shall be 1 /one/ year as from the submission of a request for products/services or information;

•    Where an agreement has been concluded, the reason for data processing is considered contractual, and the storage period shall be 6 /six/ years as from the date of contractual relationship termination, but not earlier than the expiry of the statutory grounds for the processing of data;

•    Provided there is a legitimate interest on the part of RYVYL (EU), the storage period shall last until the expiry of this right and/or interest;

•    For online employment applications filed through the website of RYVYL (EU), the personal data storage period shall be 1 /one/ year as from the date on which the application was sent.

To whom may we deliver the personal data provided by you?

RYVYL (EU) shall commit itself not to deliver your personal data to third parties without your explicit consent, unless this data is needed for the performance of assumed contractual and/or pre-contractual duties.

In order to fulfil its duties under contractual and/or pre-contractual relationships established with you, RYVYL (EU) could disclose your personal data to the following persons:

•    Companies providing hosting services related to RYVYL (EU) website;

•    Companies developing and supporting the website of RYVYL (EU);

•    Companies supporting RYVYL (EU)  business pages in the social media, etc.;

•    Public authorities, including the ones carrying out supervisory functions;

•    Domestic and foreign banking and financial institutions performing cash transactions;

•    Courts, prosecution office, police, investigators;

•    Lawyers and Notaries involved in insolvency proceedings;

•    Auditors;

•    Third parties – receivables’ collectors;

•    RYVYL (EU) counterparts such as IT, logistics, and telecommunication companies;

•    Other personal data controllers, who have taken necessary technical and organizational measures for the protection of personal data in countries in and outside EU/EEA.

RYVYL (EU) shall have the right to disclose and deliver your personal data to PSP provided there is a legitimate interest associated with the processing of the said data. This and any other type of delivery shall be carried out in strict observance of the confidentiality and security of your personal data.

Are there other cases in which we could share your personal data?

•    At the request of the individual who has provided the personal data subject to protection;

•    At the request of the competent authorities under the applicable legislation of the Republic of Bulgaria and the European Union.

In all of above cases, the persons to whom we submit your personal data, including foreign companies based in EU and EEA, have declared that they are providing an adequate level of personal data protection. In terms of companies located outside EU and EEA, in each particular case the respective company has guaranteed its provision of an adequate level of personal data protection in compliance with the requirements of the European legislation.

Automated decision making during personal data processing and profiling

In order to speed up the delivery of online services, we most often use the technical possibility for automated decision making in accordance with Art. 22 of the Regulation. We shall inform you if an automated processing of your personal data has been offered. The provisions of the Regulation shall fully apply to the processing of personal data, which includes “profiling” consisting of all kinds of automated processing of personal data for the assessment of personal aspects, particularly the analysis or forecasting of various aspects related to your economic state, health, personal preferences, interests, reliability or behavior. During the automated processing of your personal data we shall:

•    Use appropriate profiling procedures;

•    Apply relevant technical and organizational measures, and shall guarantee that the factors leading to personal data inaccuracies shall be remedied and the risk of errors shall be minimized;

•    Protect your personal data in a way that shall take into account the potential threats to your interests and rights and shall not generate an effect of discrimination based on race or ethnical origin, political views, religion or beliefs, membership in trade unions, genetic or health status, sexual orientation, or any similar effect.

We inform you of the following rights of yours related to the automated decision making/profiling:

•    The right to register your willingness to involve human intervention in the decision making process in each case of automated processing of the personal data submitted by you;

•    The right to express your opinion on a decision that has been taken automatically;

•    The right to get an automated decision explained by sending an application;

•    The right to appeal a decision taken by automated processing.

What are your rights in terms of the personal data provided?

Pursuant to the Bulgarian and European legislation, including EU Council Regulation № 2016/679 (General Data Protection Regulation – GDPR), you may exercise the following rights:

•    The right to access and obtain a copy of the personal data processed for you by RYVYL (EU);

•    The right to ask RYVYL (EU) to correct your personal data should you establish any inaccuracies or should the data require an update;

•    The right to ask for your personal data to be blocked or have its processing restricted in the cases provided for by the law and the Regulation;

•    The right to ask for your personal data to be obliterated (deleted) by RYVYL (EU) where such conditions have emerged;

•    The right to file an application for the transfer of your personal data into a structured and machine readable format for general use;

•    The right to submit a complaint or a request for the protection of your rights before the Personal Data Protection Committee, provided there are reasons for you to do that.

You can exercise all the rights at any given time during the processing of your personal data by sending a written application, signed by you, to the address of RYVYL (EU): Sofia, Pozitano 2, or by sending an e-mail to: dpo@ryvyl.eu.

Are you obliged to provide us with your personal data?

In order for us to provide our products and services, and in view of the established contractual relationships, we shall collect and process your personal data. We shall also process your data so that RYVYL (EU) could fulfill its statutory duties and in the event of the Company having a legal (legitimate) interest.

Should you refuse to voluntarily provide us with your personal data, RYVYL (EU) shall not be able to offer its products and services, and accordingly, it shall not enter into a contract with you or shall not proceed with the performance of a contract that has already been concluded.