Privacy Policy

to the Website features and services provided to you when you visit our Website, portals or our payment gateway our customers may use on their websites;
when you apply to use and/or use Sebes products and services, as well as when you request changes to the services you are using;
to your use of software including terminals, mobile and desktop applications provided by Sebes; and to email, other electronic messages including SMS, telephone, web chat, website/portal and other communications between you and Sebes.

an individual’s identification data, such as name, surname, personal identity number, date and place of birth, identification document data (such as passport copy, ID card, photo, short video of individual and selfie) or another document containing personal data;
an individual’s contact details (postal address, phone, email, Skype name, IP address, communication language with the customer, etc.);
data on tax residency (for example, nationality, country of residence, tax residence, taxpayer number, social insurance number);
data of related persons (for example, representatives and authorised persons of customer, employees, heirs, guarantors and other related persons of customers);
financial and wealth origin data such as accounts, income, ownership, transactions, commitments, data on the customer’s counterparties and personal activities (information on accounts, payments made, agreement and invoice copies, information on business activities, origin of funds, certificates of income, loans and other liabilities, information on accounts with other credit institutions);
professional data such as education or professional career (for example, information on salary, previous places of employment, education etc.);
audio / visual data (for example, records of phone conversations of Sebes and customers, records of surveillance cameras placed in objects belonging to Sebes and areas adjacent to them), communication data collected when the customer visits Sebes, or communicates with Sebes, email and other communications data obtained from visiting our Website.

Technical information, including the Internet protocol (IP) address used to connect your computer or device to the Internet, your login information, browser type and version, equipment type, time zone setting, browser plug-in types and versions, operating system platform, frequency and length of visits, and what links you click on;

search your and your customers records at fraud prevention agencies and KYC (Know Your Customer) and AML (Anti Money Laundering) service providers to fulfil our legal and contractual obligations.
may also collect information about you from public sources for AML reasons or market research. This includes official public records, like commercial registers and information published by the press or on social media.
collect and hold data on research that makes it possible to conduct customer research activities in relation to the prevention of money laundering and terrorist financing and to ensure compliance with international sanctions and whether the individual is a politically exposed person;
collect and hold data obtained when following regulatory requirements, such as data protection, AML, arising from requests for information from public authorities, the tax administration, investigative authorities, including the police, courts, sworn notaries and bailiffs;
collect and hold data from, third parties like business partners, banks and other financial institutions, merchants, subcontractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, government lists and databases, social media sites (including posting made by or about you or us), credit reference and fraud prevention agencies.

Collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;
Used lawfully, fairly and in a transparent way;
Relevant to the purposes we have informed you about and limited only to those purposes;
Accurate and kept up to date;
Maintained only for as long as necessary for the purposes we have informed you about;
Kept securely and protected against unauthorized or unlawful processing and against loss or destruction using appropriate technical and organizational measures.

compliance with legal acts;
identification, due diligence and monitoring of individuals;
performance of a contract;
provision of services;
management of relationship with clients, partners and other related persons;
ensuring physical and information security;
protection of Sebes’ and clients’ interests;
risk management;
personnel management;
commercial communications, promoted marketing campaigns and similar activities;
satisfaction of clients’ claims.

your consent to the Personal data processing;
conclusion and performance of the contract with you or your customer;
fulfilment of legal obligations under applicable legislation;
our legitimate interests.

members of management bodies, employees, representatives, authorised persons of Sebes;
internet/computer software services providers, companies specializing in IT and marketing services;
IT infrastructure services providers;
customer support services providers and helpdesk services providers;
public institutions, public officials, investigatory authorities, courts, prosecutor’s office, subjects of operational activities, orphans’ courts, notaries, law enforcement officials, judicial and investigatory authorities of other member states and foreign countries, tax authorities, arbitration courts, out-of-court dispute resolution bodies;
financial and payments market participants (global financial messaging infrastructures, correspondent banks, insurance companies, payment systems, payment service providers and technical and non-technical processors, agency companies, business partners of Sebes or clients, financial service intermediaries etc.);
companies that carry out KYC/AML database checks and fraud database checks;
Sebes’ cooperation partners, agents, suppliers and service providers, auditors, financial management and legal advisors;
Video surveillance/security services provider/s;
Other persons connected with the provision of our services.

the European Commission says the country or organisation has adequate data protection, or
we’ve agreed to standard data protection clauses approved by the European Commission with the organisation.

keeping Personal data up to date;
storing and destroying it securely;
not collecting or retaining excessive amounts of data;
protecting Personal data from loss, misuse, unauthorised access and disclosure and by ensuring that appropriate technical and organizational measures are in place to protect personal data.

your Personal data may be processed on the basis of your consent or some other legitimate basis;
to receive information on the processing of Personal data performed by Sebes and exercise your rights;
to receive a confirmation if your Personal data are not processed;
to access your Personal data and receive information on the purpose and legal basis of data processing, category of data, recipient of data, storage period, information on other sources of data if Personal data are obtained from third parties, and guarantees, if the data have been sent to a third party or international organisation;
to receive information on whether the provision of Personal data is related to the law or an a contract, whether the provision of data is a precondition for the conclusion of a contract, as well as information that the subject is required to provide Personal data, and consequences in case such data are not provided;
to be informed about a new purpose of data processing in advance;
to object to data processing and withdraw your consent to data processing;
to request rectification of data if data are incorrect;
to data portability;
to request erasure of data if this does not contradict laws of the Republic of Cyprus and EU laws.

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Title: Privacy Policy - SEBES TECHNOLOGY

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