Who are we?
We are Fingopay, (trading name of Sthaler Limited). Our registered office is located at 4 Riverview, Walnut Tree Close, Guildford, GU1 4UX. You can contact us by email at email@example.com and by telephone on +44 (0) 20318 91460. We specialize in high tech payment solutions. We provide a unique biometric technology that enables you to use the pattern of veins in your fingers to pay for items.
What does this Policy cover?
At Fingopay we take your personal data seriously. This policy:
- sets out the types of personal data that we collect about you
- explains how and why we collect and use your personal data
- explains how long we keep your personal data for
- explains when, why and with who we will share your personal data;
- sets out the legal basis we have for using your personal data;
- explains the effect of refusing to provide the personal data requested;
- explains the different rights and choices you have when it comes to your personal data; and
- explains how we may contact you and how you can contact us.
What personal data do we collect about you?
The personal data we collect about you includes: name, number, date of birth, email, password, bank card details (including image),information and receipts of purchases made by you through Fingopay.
We also collect and store information about you that is not directly referable to you and from which you cannot be identified (this includes aggregated and anonymized information and information learnt about you through your use of the Fingopay solution (“Generic Information”)
We collect sensitive personal data about you, in the form of your biometric finger vein template. As the Fingopay services cannot be provided without this, by registering for the Fingopay services you are giving your explicit consent to the collection of this sensitive personal data.
Where do we collect personal data about you from?
The following are the different sources we may collect personal data about you from:
- Directly from you. This is information you provide when registering for the Fingopay identity and payment solution, including your biometric finger vein template.
- The merchant (or other operator) where you register or use the Fingopay service from.
How and why we use your personal data?
We use your personal data to be able to verify your identity, register you on the Fingopay application and provide you with the services of the Fingopay biometric identity and payment solution. This includes live services to facilitate payment, as well as loyalty and promotional schemes.
Where we use your sensitive personal data in the form of your biometric finger vein template, we use this to confirm your identity and facilitate you making a payment with the Fingopay biometric identity and payment solution.
How long do we keep your personal data for?
We keep your information for the duration of your use of the Fingopay biometric identity and payment solution. If you cease to be a Fingopay user we will delete all information we hold on you within 120 days from the date of termination, save for Generic Information, information which is reasonable for us to retain in order to operate or perform our services and such other data as we are required by law to retain.
Who do we share your personal data with?
Your personal data may be shared with the merchant (or other operator) at which you register or use the Fingopay payment solution.
What legal basis do we have for using your information?
We rely on our processing being necessary to perform a contract with you, as the information provided is necessary to provide you with the services of the Fingopay identity and payment solution.
We only collect personal data from you, and further process this for marketing, where you have given your explicit consent to receive our Fingopay notifications, deals, special offers, and other information via email, sms and social media.
What happens if you do not provide us with the information we request or ask that we stop processing your information?
If you do not provide the personal data necessary, or withdraw your consent for the processing of your personal data, we will not be able to provide you with access to the Fingopay biometric identity and payment solution.
Do we transfer your data outside the EEA?
To better provide you with the services of the Fingopay biometric identity and payment solution we may transfer your personal data to partners in countries outside the EEA. These countries privacy laws may be different from those in your home country. Where we transfer data to a country which has not been deemed to provide adequate data protection standards we always have approved model clauses in place to protect your personal data.]
How will we contact you?
We may contact you by phone, email or through the Fingopay app. If you prefer a particular contact means over another please just let us know.
How can you contact us?
If you are unhappy with how we’ve handled your information, or have further questions on the processing of your personal data, contact [us OR our Data Protection Officer] here: [4 Riverview, Walnut Tree Close, Guildford, GU1 4UX], ([firstname.lastname@example.org]).