Privacy Policy

Last Updated: September 28, 2022

We have developed this Privacy Policy to take care of your privacy and personal data protection. Our Privacy Policy is set out below and explains how we will process your personal information and data. Nothing in this Privacy Policy shall limit your statutory rights in relation to your personal data.

Please read this Privacy Policy carefully, as it becomes legally binding when you use Cino Services. For the full definition of the capitalized words here, check our Terms specified in the Cardholder Agreement. By providing personal data to us, you consent to our processing of your data in accordance with this policy and other agreements. If you do not agree to the terms set out in this Privacy Policy, please do not continue to use our Website, our App, Cino Account, Cino Services or another software.

If you have any questions or concerns about this privacy notice, or our practices with regards to your personal information, please contact us at support@getcino.com.

This Privacy Policy applies to all information collected through Cino Services including Cino Account, our Website and our App, as well as, any related services, sales, marketing or events.
1. Who Will Hold Your Information

Your Personal Data controller is Freerange Lamas OÜ, a company incorporated under the laws and regulations of the Republic of Estonia with the registry code 16488890 (hereinafter referred to as "Cino", "we", "us", or "our" as applicable). Cino is neither a bank nor a credit/financial institution defined in the Money Laundering and Terrorist Financing Prevention Act (“MLTFPA”) of the Republic of Estonia and doesn’t offer any banking services. The Cino Services are provided in cooperation with Checkout Ltd (checkout.com), hereinafter referred to as the “Acquirer”, an authorized electronic money institution licensed by the UK Financial Conduct Authority under number 900816, and Wallester AS (Reg. code 11812882), hereinafter referred to as the "Issuer", a company registered under laws and regulations of the Republic of Estonia, an official Visa Principal Member, and a PSP authorized by the Estonian Financial Supervision and Resolution Authority (Finantsinspektsioon). 
2. What Information We Collect

Information you provide:
Concerning your use of Cino Services, we may automatically collect the following information:

Information from other sources.
We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties and may receive information about you from them. These may include:
Information from social network service providers: 

When you log in to your Cino Account using your account (e.g. Apple, Google) we will receive relevant information that is necessary for us to provide you with Cino Services and authenticate your access. The social network will share access with us to certain information that you have stored with them, including your Full Name, profile image, and email address, under the social network's privacy policy. We use such information, along with any additional information you directly provide to us when registering or using Cino Services, to create your account and to communicate with you about the information and services that you request from us. You may also be able to specifically request that we have access to the sensitive information in your social network account, such as a contacts list. 

Information related to children: 

Cino Services are directed at adults aged 18 years and over and are not intended for children, thus, we don't collect data from this age group. Our verification process prevents Cino, the Issuer, and the Acquirer from collecting this data. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the relevant Cino Account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at support@getcino.com.

Cookies:
We use small files (so-called "cookies") and similar tracking technologies (like “web beacons” and “pixels”) to see how you use the Website and the App. We put them on your device when you visit our Website and use them to recognize you and store information during and between your visits and activity.With the help of cookies, we can provide you with a better browsing experience, improve the quality of Cino Services, and keep marketing costs down. Cookies allow us to simplify the process of logging in, and they show us where you might be having trouble with Cino Services. Without cookies, we would have no way to remember anything about you, such as whether you’re logged in. Most Web browsers are set to accept cookies by default. If you prefer, you can choose to set your browser to remove/reject cookies. If you choose to remove/reject cookies, this could affect certain features of Cino Services. 

3. The Way We Use Your Information

We will only use your personal data when the law allows us to. 

Most commonly, we will use your personal data in the following circumstances:
Other purposes:
Additionally:
4. Disclosure of Your Personal Information
5. Data Retention
6. Keeping Information Secure

Unfortunately, despite our best efforts, the transmission of data over the Internet cannot be guaranteed to be 100% secure. While we will use every reasonable means to ensure the security of the information you transmit to us, we cannot guarantee that such information will not be intercepted by third parties. We will, however, prosecute any unauthorized or fraudulent transactions to the fullest extent permitted by law. Although we will do our best to protect your personal information, the transmission of personal information to and from Cino Services is at your own risk. You should only access the Cino Account within a secure environment.
7. Privacy Rights
You have certain rights specified above under the data protection regulation concerning the information that we hold about you. 
8. Links to Other Web Resources

 Our Website and the App may, from time to time, contain links to and from the web resources of our partner networks, advertisers, and affiliates. If you follow a link to any of those web resources, please note that those web resources have their privacy policies and that we do not accept any responsibility or liability for those policies. Please check those policies before you submit any personal data to those web resources. 
9. Your Consent to This Privacy Policy

You acknowledge that this Privacy Policy is part of the Cardholder Agreement and agree that using our Website, our App, and Cino Services signifies your consent to this Privacy Policy and related terms of use provided above, is subject to all applicable laws, and is undertaken at your own risk.By submitting your information, you consent to the use of that information as set out in this Privacy Policy. To ensure that the most recent information about the processing of your personal data is always available to you, we will make sure that this Privacy Policy is reviewed and updated regularly. Therefore, we encourage you to read, from time to time, the latest version of the Privacy Policy on our Website (available at https://getcino.com/privacy-policy). 
10. Contact Details