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:
You may provide us with information about yourself when you sign up to use Cino Services, e.g. when you provide us with personal details including your Full Name, phone number, and email address. This also includes information you provide through your continued use of Cino Services, your participation in discussion boards or other social media functions on our Website or App, through entering a competition, promotion or survey, and by reporting problems you experience using Cino Services. The additional information you provide us for security, identification, and verification purposes may include your citizenship, current residency status, valid address, financial information (including credit card, debit card, or bank account information), payment reason, geographical location, personal description, and photograph.
The content of your communications with us, which we collect via emails, direct messaging, telephone call recordings, online chat, and other possible means of communication.
In some cases, including when you perform high volume transactions, exceeding your Limit, or where we and/or the Issuer and/or the Acquirer need to comply with anti-money laundering regulations, we may also need more personal or identification information from you.
Please ensure that your personal data is current, complete, and accurate at all times, by logging onto your Cino Account and updating it whenever necessary or by contacting us via email at email@example.com.
Concerning your use of Cino Services, we may automatically collect the following information:
Details of the transactions you carry out using your Cino Card, including the geographic location from which the transaction originates, name and description of the merchant, payment methods used.
Technical information, including the internet protocol (IP) address used to connect your device to the internet, your login information, phone type, unique device identifiers, mobile network data as well as other data generated by a device's interaction with Cino Services, time zone setting, operating system, and platform.
Information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through, and from our Website or App (including date and time); pages you viewed or searched for; search requests, page response times, download errors, length of visits to certain pages, page interaction information (including scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to communicate us.
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:
The financial institution where you use the account as a Funding Source will provide us with your basic personal information, including your name and address, as well as your financial information, including your account details opened with that financial institution.
Business partners may provide us with your name and address, as well as financial information, including card payment information.
Advertising networks, analytics providers and search information providers may provide us with information about you, including confirming how you found our website.
Credit reference agencies do not provide us with any personal information about yourself, but we may use them to corroborate the relevance of the information you have provided to us.
Fraud prevention agencies may provide information that helps us to combat fraud and adjust our risk policy.
Information from social network service providers:
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 firstname.lastname@example.org. 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:
Where you have given us your consent to process your data.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we have a legal obligation to process your personal data to comply with laws, regulations, or court orders.
Where it is necessary to fulfill our obligations to provide you with Cino Services.
Where it is necessary to protect the vital interests of yourself or other individuals.
To administer and maintain Cino Accounts.
To provide Cino Services to you and ensure secure transaction processing.
To improve our Website and the App to ensure that Cino Services continues to be the most appropriate service for your needs and that content from our Website and/or the App is presented most effectively for you and your device.
To help us in our efforts to keep our webpage safe and secure.
To verify your identity and respond to any query that you may raise with us.
To send you emails from time to time regarding updates and changes to Cino Services and any technical, operational, administrative, and legal notices important to Cino Services that we consider essential.
To administer and process your registration for Cino Services.
We are obligated on selected measures against the legitimization of proceeds of crime and financing of terrorism to keep records about you and your transactions.
Access your account settings and update your preferences.
We may use your data to contact you for market research purposes and to provide you with information about Cino Services, offers, and promotions that may be of interest to you. If we do so, we will contact you by email. If you do not want us to use your data in this way, 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 via email at email@example.com. 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 Cino Account, to respond to service requests, or for other non-marketing purposes.
Your information may be used by us for research and statistical analysis and internal service monitoring.
We use certain processors in the general running of its business and to assist us in providing services to you, for dealing with various matters in connection with our Website and the App. A processor is a third-party service provider or a data processor engaged by us, who has or potentially will have access to or process personal data. If you would like to know a list of our processors who have or have had access to your data, please contact us at firstname.lastname@example.org.
The period of use of the personal data supplied by you will not be longer than we deem necessary.
Thedata protection legislation gives you the right to access the personal data that we have about you.
Unless there is a particular reason, we approve your requests regarding the disclosure of your information to third parties after checking that you, as an applicant, is the person concerned. Additionally, in case of inaccurate information that we know about, we will apply the necessary changes to it.
4. Disclosure of Your Personal Information
We may disclose your personal data if we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets and their advisers. If our business is sold your details will be passed on to the new owners of the business.
We are required by law to make a disclosure where we know or suspect that a transaction involves money laundering or terrorist financing. When we are required to disclose information concerning one of your transactions, we will not be able to inform you about the disclosure or our reasons for making it.
5. Data Retention
We will always delete data that is no longer required by relevant law or jurisdiction in which we operate. We do this automatically, so you don’t need to contact us to ask us to delete your data.
If any of the information that you have provided to us changes, for example, if you change your email address or other contact details, or if you wish to close your account with us, please update your account details in the App, alternatively, contact us via email at email@example.com.
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 are entitled to have access to your personal data. You may request by writing to us via email at firstname.lastname@example.org, details of your information which we hold and the purposes for which it is held. We will provide this information within 40 days of your request, subject to any routine processing continuing between that time and the time of response.
You are entitled to request that we stop using information about you for direct marketing (i.e. the communication to you (by whatever means) of any advertising or marketing material).
You are entitled to require us to ensure that no decision taken by or on behalf of us which significantly affects you is based solely on the automated processing of your information, to evaluate such matters as, for example, your creditworthiness, reliability, or conduct.
You are entitled to require a correction of errors in the personal information held about you. If we disagree that information is inaccurate you are entitled to apply to ask the court for an order that such erroneous information be rectified, blocked, destroyed, or erased.
You have certain rights specified above under the data protection regulation concerning the information that we hold about you.
If you are a resident in the EEA and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details by the following link: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
If you have questions or comments about your privacy rights, you may email us at email@example.com.
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.
10. Contact Details