The controller of personal data that we collect, process and use is Fexserv Financial Services Ltd (C18400) of Alpine House, Naxxar Road, San Gwann, Malta (“Fexserv”), registered with the Registrar of Companies in Malta, Fexserv is a licensed Financial Institution in Malta and regulated by the Malta Financial Services Authority (MFSA).
We have developed this policy because we want you to feel confident about the privacy and security of your personal information. Please read it carefully.
We are bound, in accordance with the laws of Malta and European Directives, to observe secrecy and confidentiality with regards to all information which you give to us about you (“Secret Information”). However, we are permitted, in terms of the laws of Malta, to disclose Secret Information under certain circumstances, including where we are required to do so in terms of law or where ordered to do so by a court order.
- if this is required for the purpose of fulfilling any specific request that you may make to us;
- if we are to provide information if required by governmental bodies, agencies or regulators, however exclusively under proper authority;
- where these third parties form part of the same group as Fexerv or are affiliated entities;
- where these third parties are our professional advisers (including but not limited to financial, legal, management and other advisers as might be engaged from time to time);to any of our professional advisers (including but not limited to financial, legal, management and other advisers as might be engaged from time to time ), or to any of our group entities or affiliated entities, or to any consultants (including market research entities, advertising agencies) or to any person who may otherwise enter into contractual relations with Fexserv in relation to the business relationship with you;
- to any person to whom we have outsourced any activities or services of Fexserv, including any material and/or non-material activities and/or services of Fexserv;
- when the information is required to be disclosed or is requested in the course of a due diligence exercise;
- when the information is required in the normal course of business with institutions or other persons who are normally bound by similar obligations of secrecy.
3. Processing your Data
We store and process your data, including personal data in terms of the Data Protection Act (Chapter 440 of the Laws of Malta), to the extent that this is necessary for the appropriate conduct of our business relations and conforms to the applicable statutory provisions. We only record information which serves to fulfil our duties and we do this solely within the scope of the service provided to you. In providing our services we collect, process and store data relating to you from other banks and other professionals.
Your personal data will not be stored for a time period exceeding the necessary term to the purpose of their collection, according to applicable law.
4. Why we Collect your Data
Information about you may be put onto Fexserv’s database and used, analysed and assessed by Fexserv to provide you with a better service. We only collect information that we believe to be relevant and required to better conduct our business and to provide our customers with better services and products. Data collected typically includes:
- Name and surname;
- Date of birth;
- Country of Residence;
- A copy of the identification document provided and any other visual data collected during the registration process;
- Issuing country of identification document provided;
- Number of identification document provided;
- Expiry date of identification document provided;
- Mobile phone and fixed line number;
- Email addresses;
- Residential or reference addresses; and
- Details (including value, date, type, location, etc.) on all transactions processed through Fexserv or any of its products/services.
We use the information that we collect about you in the following ways and for the following purposes:
- for the provision of information or other services in relation to any specific requests that you may make to us, and to give you statements;
- according to law, we may be required from time to time to disclose your information to Governmental bodies, agencies or our Regulators or recognised external authorities, but we will only do so under proper authority;
- for internal assessment and analysis;
- for research and statistics;
- for the detection and prevention of fraud and any other illegal acts or criminal activity which Fexserv is bound to report and in line with our anti-money laundering policy;
- to develop and improve Fexserv’s products and services; and
- to check your identity and address.
When vetting applications, we may search the Electoral Register and carry out identity checks. We may also request information on you from credit reference agencies, and use any of this information for identification purposes, debt tracing and the prevention of money laundering. The records will also be used for statistical analysis about credit, insurance and fraud.
5. Third Party Access to your information
Personal Data may be transferred outside the European Union in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) and Commission Decision of 20 December 2001 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequate protection of Personal Data provided by the Canadian Personal Information Protection and Electronic Documents Act (notified under document number C(2001) 4539).
6. Direct Marketing
We may use your contact details and process your personal data to inform you of relevant opportunities, events and products that may be of interest to you. We may carry out direct marketing in order to inform you, by mail, telephone, email or other electronic means, about other products and services provided by Fexserv, its subsidiaries, affiliates, associates, agents and by carefully selected third parties and for research purposes. Should you not wish to be contacted for marketing purposes, you should inform us accordingly by sending a written request to this effect (by sending it to firstname.lastname@example.org or by sending a letter to the address indicated above).
We may require to contract third party companies to carry out bulk mailing or marketing campaigns on Fexserv’s behalf, in which case we would be required to provide them with your contact details excluding personal financial information. Such third party companies will be required to comply with all provisions of law including data protection when using such information.
7. Your Rights
You have the right to write to us and enquire what personal information we hold on you. If it is proved that the information held is inaccurate, we will make the necessary amendments. Under Data Protection legislation, you can ask in writing for a copy of the personal records we hold about you. You also have the right to request rectification, blocking or erasing of such personal data that has not been processed in accordance with such legislation. You have the right to request a copy of the personal data that we hold about you and to have any inaccuracies corrected. You may also change your preference as regards direct marketing by sending a request through our general customer support service using the contact channels described in the General Terms & Conditions.
All reasonable efforts are made to keep customers’ information up-to-date. It is important that you inform us in writing of any changes to your personal information. Whilst we may periodically request you to re-confirm the information, you shall inform us immediately if such information is no longer correct and needs to be updated. Please address any such changes in writing to Fexserv Financial Services Ltd, Alpine House, Naxxar Road, San Gwann, Malta.
8. Cookies and Web Technology
Similar to other websites, our website utilizes a standard technology called ‘cookies’. A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer’s (or other device’s) browser from a website’s server and is stored on your computer’s (or other device’s) hard drive. Cookies allow a website to remember things like your preferences or whether you have logged in, and they allow us to tailor our website to your interests. Information supplied by cookies can also help us to analyze your use of our website and help us to provide you with a better user experience.
We currently use one type of cookies being Essential Cookies for the internet service. These are session cookies that expire at the end of the session (that is, once you log-out of the mobile device or internet service) or when the browser is closed. The cookies we use are: JSESSIONID, for both the private Website and the Console. If you block or refuse these cookies then you might not be able to log in or use the internet service.
We currently do not use Non-Essential Cookies.
Whilst we take measures to ensure that your personal data cannot be intercepted by third parties, please note that when using our website, data is transported over an open network (the internet) which is accessible to third parties and which cannot be regarded as a secure environment. We may transmit or store any data provided by you when using our website outside your country of residence. In such cases, we will make every effort to secure an appropriate standard of protection for your data, including those relating to client confidentiality and data protection, but it is possible that data may be relayed to a country in which the prevailing standards of data protection are lower than in your country of domicile. We accept no responsibility or liability for the security of your data during transmission via the internet. We would like to draw your attention to the fact that you can communicate with us by other means whenever you consider it appropriate on data protection grounds.
We may monitor and record your telephone calls with us in order to ensure that your instructions are accurately carried out, to help us to continually improve our service and to improve security.
10. Links to other websites
Our Website may contain links to websites operated by third parties. When connecting to such other websites you will no longer be subject to this Policy but to the privacy and data protection policy of the other website. We are not responsible for the privacy and data protection practices of these other websites and we encourage you to read the privacy and data protection statements of each website you visit, which may collect personal information.
11. Changes to this Policy