Intus Financial Services Oy Ltd privacy policy

1. Introduction
   1. We are committed to safeguarding the privacy of our website https://intusbrokers.com/ visitors and service users.
   2. This policy applies where we are acting as a data controller with respect to the personal data of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.”Personal data” is defined in Article 4(1) of the GDPR:‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

      You can read more about the GDPR on https://ec.europa.eu/info/law/law-topic/data-protection/data-protection-eu_en.

   3. We use cookies on our website. Insofar as those cookies are not strictly necessary for the provision of our website and services, we will ask you to consent to our use of cookies when you first visit our website.
   4. Our website incorporates privacy controls which affect how we will process your personal data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information.
   5. In this policy, “we”, “us” and “our” refer to Intus Financial Services Oy Ltd (Intus Brokers), “website” refers to Intus Brokers’ website https://intusbrokers.com/.
2. Credit
   1. This document was created using a template from SEQ Legal (https://seqlegal.com/).
3. How we use your personal data
   1. In this Section 3 we have set out:
      1. the general categories of personal data that we may process;
      2. in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
      3. the purposes for which we may process personal data; and
      4. the legal bases of the processing.
   2. We may process the personal data that you provide during the use of our services (“service data“). The service data may include the data you submit through our application forms. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, communicating with you and preventing and detecting fraud. The legal basis for this processing are your consent, our legitimate interests, namely the proper administration of our website and business, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   3. We may process information contained in any enquiry you submit to us regarding our services (“enquiry data“). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is consent.
   4. We may process information relating to transactions, including purchases of services, that you enter into with us and/or through our website (“transaction data“). The transaction data may be processed for the purpose of supplying the purchased services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
   5. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). The notification data may be processed for the purpose of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   6. We may process information contained in or relating to any communication that you send to us (“correspondence data“). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
   7. We may process information contained in your bank statement or in your credit history (“financial data“). This data may include your bank transactions and records of your debts repayments. The source of this data is you and our credit information provider. This data may be processed for assessing your creditworthiness. The legal basis for this processing is consent, or the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
   8. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
   9. In addition to the specific purposes for which we may process your personal data set out in this Section 3, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.
   10. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
4. Providing your personal data to others
   1. Financial transactions relating to our website and services are handled by our payment services provider, AS SEB Pank. We will share transaction data with our payment services provider only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services provider’s privacy policies and practices at https://www.seb.ee.
   2. We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access only to the Personal Data necessary to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
      

      Service provider	Website	Description
      Zendesk	https://www.zendesk.com/	Real time user interaction and customer support
      Google Analytics	https://www.google.com/analytics/	Collect information about our website usage

   3. In addition to the specific disclosures of personal data set out in this Section 4, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
5. Transfer of personal data
   1. Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside Finland and choose to provide information to us, please note that we transfer the data, including personal data, to Finland and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
   2. Intus Brokers will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place, including the security of your data and other personal information.
6. Retaining and deleting personal data
   1. This Section 6 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
   2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
   3. We will retain your personal data as follows:
      1. service data, enquiry data, transaction data, notification data, correspondence data and financial data will be retained for a period of 60 months, or until deletion is requested by the person to whom the data refers.
   4. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
7. Amendments
   1. We may update this policy from time to time by publishing a new version on our website.
   2. You should check this page occasionally to ensure you are happy with any changes to this policy.
   3. We will notify you of significant changes to this policy by email.
8. Your rights
   1. In this Section 8, we have summarized the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regolatory authorities for a full explanation of these rights.
   2. Your principal rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.
   3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for compliance with a legal obligation; or for the establishment, exercise or defense of legal claims.
   6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defense of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defense of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defense of legal claims.
   8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   9. To the extent that the legal basis for our processing of your personal data is:
      1. consent; or
      2. that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,

      and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

   10. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
   11. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   12. You may exercise any of your rights in relation to your personal data by written notice to us via email at info@intusbrokers.com.
9. About cookies
   1. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
   2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
   3. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
10. Cookies that we use
    1. We use cookies for the following purposes:
       1. personalization – we use cookies to store information about your preferences and to personalize the website for you. Cookies used for this purpose are: _icl_current_language (to remember the current website language selection), popup_email_close and popup_email_send (to remember the newsletter popup status);
11. Cookies used by our service providers on our website
    1. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
    2. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. The collected data is anonymized. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. The relevant cookies are: _ga, _gat, _gid
    3. We use Zendesk Chat to interact with users in real time and provide them support. This service uses cookies to store Zopim Live Chat ID to identify the device during visits and to store user’s preference to disable the chat. You can view the privacy policy of this service provider at https://www.zendesk.com/company/customers-partners/#cookie-policy. The relevant cookies are: _zlcmid, _zprivacy.
12. Managing cookies
    1. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
       • https://support.google.com/chrome/answer/95647?hl=en (Chrome);
       • https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences (Firefox);
       • http://www.opera.com/help/tutorials/security/cookies/ (Opera);
       • https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer-delete-manage-cookies (Internet Explorer);
       • https://support.apple.com/kb/PH21411 (Safari); and
       • https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy (Edge).
    2. Blocking all cookies may have a negative impact upon the usability of many websites.
    3. If you block cookies, you may not be able to use all the features on our website.
13. Our details
    1. This website is owned and operated by Intus Brokers.
    2. We are registered in Finland under registration number 2750717-8, and our registered office is at Fredrikinkatu 61 A 6k, 00100 Helsinki.
    3. Our principal place of business is at Fredrikinkatu 61 A 6th floor, 00100 Helsinki, Finland.
    4. You can contact us:
       • by post, to the postal address given above;
       • using our website contact form;
       • by telephone, on the contact number published on our website; or
       • by email, using the email address published on our website.