This Privacy Policy depicts your privacy rights in terms of gathering, use, storing, sharing, and protecting your personal data (hereinafter – Personal data), as well as the scope of processed Personal Data, the purposes, sources, recipients and other important aspects of data processing by registering, accessing, or using Cosmos Finance (Brit FX Limited), Suite 12, Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY and Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, CanadaV6B2Z4 (hereinafter – the Company or we) products, services, solutions, features, and technologies. If you do not agree, you should stop accessing our website https://www.cosmosfinance.com (hereinafter – Website), or our services immediately and refrain from further access and use of them. We respect the privacy of every individual who visits our Website.
We use and process your personal data in accordance with this Privacy Policy and in compliance with the applicable legal acts such as:
When writing “you”, we refer to you as a potential, existing, former client of the Company, our client’s employee or other related party such as beneficial owner, authorized representatives, business partners, other associated parties or a user of our Website.
We process your personal data with the following principles:
If you are a potential client, or register with us as a client, we will ask you for information about yourself. The categories of personal data that we may collect about you are as follows:
| Type of information | Personal data |
| Basic Personal Data | Name, surname, job title etc. |
| Identification information and other background verification data (your or your representative’s, ultimate beneficiary owner’s of legal entities) | (your or your representative’s, ultimate beneficiary owner’s of legal entities) name, surname, personal identity code, date of birth, address, nationality, gender, passport or ID card copy, evidence of beneficial ownership or the source of funds, number of shares held, voting rights or share capital part, title, visually scanned or photographed image of your face or image that you provide through a mobile application or camera, video and audio recordings for identification, telephone conversations to comply with client due diligence/”know your client”/anti-money laundering laws and collected as part of our client acceptance and ongoing monitoring procedures. |
| Financial data | Transactional data (e.g. beneficiary details, date, time, amount and currency which was used, name/IP address of sender and receiver), accounts, amount of transactions, income, location, etc. |
| Information related to legal requirements | Data resulting from enquiries made by the authorities, data that enables us to perform anti-money laundering requirements and ensure the compliance with international sanctions, including the purpose of the business relationship and whether you are a politically exposed person and other data that is required to be processed by us in order to comply with the legal obligation to “know your client”. |
| Contact data | Registered/actual place of residence, phone number, email address etc. |
| Special category data | Biometrical data, i.e. physical, or behavioral characteristics resulting from specific technical processing used during remote identification which confirms the unique identification of a person, e.g. facial images. We do not process special category data related to your health, ethnicity, or religious or political beliefs unless required by law or in specific circumstances where, for example, you reveal such data while using services (e.g. in payments details). |
| Any other Personal Data related to you that you may provide |
Your personal data is processed in accordance with the purposes and legal basis indicated in the table below.
The definitions from the table above are understood as follows:
Legitimate Interest: The interest of ours as a business in conducting and managing our services to enable us to provide to you and offer the most secure experience.
Contract performance: Processing your Personal Data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Legal Obligation: Processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
Consent: Your consent shall mean any freely given, specific, informed and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify your agreement to the processing of personal data relating to you. We can request from you a consent for processing when we do not have another legal basis for processing of your data.
| Purpose | Legal basis | Categories of Personal Data |
| Conclusion of the contract or for performance of measures at your request prior to the conclusion of the contract (to get to know, identify and verify our clients) | Contract performance | Basic Personal Data; Identification and other background verification data; Contact Data; Other Personal Data needed (in order to identify the possibility of providing services). |
| For the fulfilment of a contract concluded with you, including but not limited to provision of services of issuance, distribution and redemption of electronic money and provision of payment services | Contract performance | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| Verification of your identity, prevention of money laundering and fraud, control and reporting obligations, for example: Know Your Customer requirements, Preventing, detecting, and investigating money laundering, terrorist financing, and fraud, sanctions screening; risk management obligations Reporting to tax authorities, police authorities, enforcements authorities, supervisory authorities Bookkeeping regulations, Other obligations related to service or product specific legislations | Complying with legal obligations applicable to us | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing our services. |
| For remote identification of your personal identity (matching the photo image or video records of your face point that you provide through a mobile app or camera with your ID document) | Your consent | Special category data, i.e. biometrical data |
| To prevent, limit and investigate any misuse or unlawful use or disturbance of the services or to establish, exercising and defend legal claims | Legitimate interests | Basic Personal Data; Identification and other background verification data; Financial data; Information related to legal requirements; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| To ensure adequate provisions of the services, the safety of information within the Services, as well as to improve, develop and maintain applications, technical systems and IT-infrastructure or our legitimate business interests , such as enabling us to improve and deliver a better and more personalized service. | Legitimate interests | Basic Personal Data; Contact Data; Other Personal Data provided to us by or on behalf of you or generated by us in the course of providing services. |
| To provide an answer when you contact us through our website or other communication measures | Contract performance | Basic Personal Data; Contact Data; Other Personal Data provided to us by you. |
| Direct marketing | Your consent | Basic Personal Data; Contact Data; Other Personal Data provided to us by you. |
We collect information you provide directly to us. For example, when becoming a new client (if you have entered into or seek to enter into an agreement with us). The Company also collects information which you provide to us, such as messages that you have sent to us, by access and use of our website or mobile application, by setting up an account with us, when you subscribe to our electronic publications (e.g. newsletters).
Personal Data that we may collect from third parties:
In order to make your identity verification, we are using several tools/solutions provided by our partners.
We are using the “Jumio”. The solution matches the photo image or video records of your face point that you provide through a mobile app or camera with your ID document. For more information on “Jumio” please read its privacy policy:
https://www.jumio.com/privacy-center/privacy-notices/online-services-notice/
“Jumio” solution is used for comparing live photographic data or video record of yourself and your ID card/passport, to comply with legal obligations.
The result of the face similarity (match or mismatch) will be retained for as long as it is necessary to carry out verification and for the period required by anti-money laundering laws.
We ensure that the checks disclosed above are a process of comparing data acquired at the time of the verification, i.e. this is a one-time user authorization.
Your provided data is not created, recorded and stored. It is not possible to regenerate the raw data from retained information. These processes shall allow us to verify you more precisely and will make the process quicker and easier to execute.
Using “Jumio” services, personal data is used for your identification since “Jumio” verifies the identity of the person in the identity document and the person captured in the photo.
If you do not feel comfortable with these identification methods disclosed above, you may contact us by email at cco@cosmosfinance.com for an alternative way to identify yourself.
You as a data subject shall have the rights in respect of Personal Data that we hold on you. You have the following rights for your Personal Data that we have about you:
For Complaints regarding the services of Cosmos Finance:
You can contact us via email complaints@cosmosfinance.com or by personally appearing at our registered office address at Suite 12, Ground Floor Offices The Belmont, Middleton Road, Manchester, England, M8 4JY or by ordinary mail sent to our registered address.
For Canda , Sreda Money Ltd,422 Richards Street, Suite 170 Vancouver, BC, Canada
V6B2Z4
We ask you to clearly disclose your name, surname, contact details and the relevant information, which you should indicate why you reasonably feel that we may process your personal data by violating GDPR or other applicable legal acts.
Your requests addressed to “Cosmos Finance”, shall be fulfilled or fulfilment of your requests shall be refused by specifying the reasons for such refusal within 30 (thirty) calendar days from the date of submission of the request meeting our internal rules and GDPR. The afore-mentioned time frame may be extended for 30 (thirty) calendar days by giving a prior notice to you if the request is related to a great scope of Personal Data or other simultaneously examined requests. A response to you will be provided in a form of your choosing as the requester. We, after examining the complaint, report the results and actions taken to satisfy your complaint, or provide relevant information on what further actions you may take if your complaint was not satisfied.
However, please be informed that if you believe that the Personal Data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation You may lodge a complaint to relevant authorities.
For complaints regarding Cosmos Finance Payments Europe services: you may address the State Data Protection Inspectorate with a claim regarding the processing of your Personal Data if you believe that the Personal Data is processed in a way that violates your rights and legitimate interests stipulated by applicable legislation. You may apply in accordance with the procedures for handling complaints that are established by State Authorities,For complaints regarding “Cosmos Finance” you may address the UK data protection regulator, the Information Commissioner’s Office (ICO) which may be found by this link: https://ico.org.uk/make-a-complaint/
We will retain your data for a statutory period, following the principle of limitation of the length of the storage.
We may use your data for as long as reasonably necessary for the limited purpose of providing our services to you.
The terms of retention of the personal data for the purposes of the processing of the personal data as defined in this Privacy Policy are following:
In the cases when the terms of data keeping are indicated in the legislative regulations, the legislative regulations are applied.
Your Personal Data might be stored longer if:
In some cases, we may use automated decision-making which refers to a decision taken solely on the basis of automated processing of your Personal Data.
Automated decision-making refers to the processing using, for example, a software code or an algorithm, which does not require human intervention.
We may use forms of automated decision making on processing your Personal Data for some services and products. You can request a manual review of the accuracy of an automated decision in case you are not satisfied with it.
We may transfer your Personal Data in accordance with the principles of confidentiality to the following categories of recipients:
– between the companies belonging to Cosmos Finance;
– our business partners, agents or intermediaries who are a necessary part of the provision of our products and services, as well as, card organizations (such as VISA or MasterCard) – in connection with our payment services;
– governmental bodies and/or supervisory authorities (in accordance with the requirements and obligations under the provisions of legal acts concerning anti-money laundering, fraud prevention, counter terrorist financing), credit, financial, payment and/or other electronic money institutions;
– pre-trial investigation institutions, the State Tax Inspectorate, ICO;
– lawyers, bailiffs, auditors etc.;
– service providers, who make your identity verification by using their IT solutions;
– companies providing services for money laundering, politically exposed persons and terrorist financing check-up and other fraud and crime prevention purposes and/ or companies providing similar services;
– external service providers (that provide such services as, for example, system development and/or improvement, audit services);
– beneficiaries of transaction funds receiving the information in payment statements together with the funds of the transaction;
– other entities that have a legitimate interest or the Personal Data may be shared with them under the contract which is concluded between you and us;
– other entities under an agreement with us.
For the purpose to provide you our services we can engage third-party service providers outside the European Economic Area (hereinafter – EEA). The transfer of Personal Data may be considered as needed in such situations as, e.g.:
– in order to conclude the contract between you and us and/or to fulfill the obligations under such contract;
– in cases indicated in laws and regulations for protection of our lawful interests, e.g. in order to bring proceedings in court/other governmental bodies;
– in order to fulfill legal requirements or in order to realize public interest.
As well, in other case your Personal Data is transferred outside the EEA, we will take all steps to ensure that your data is treated securely and in accordance with this Privacy Policy and we will ensure that it is protected and transferred in a manner consistent with the legal requirements applicable to the Personal Data. This can be done in a number of different ways, for example:
– the country to which we send the Personal Data, a territory or one or more specified sectors within that third country, or the international organization is approved by the European Commission as having an adequate level of protection;
– the recipient has signed standard data protection clauses which are approved by the European Commission;
– special permission has been obtained from a supervisory authority.
We may transfer Personal Data to a third country by taking other measures if it ensures appropriate safeguards as indicated in the GDPR.
From time to time we may offer to distribute news and other marketing content to individuals who have asked us to do so. We will do this via mailing lists.
You always have the chance to withdraw your consent once you give your consent for us, even before receiving your first email with our news or other marketing content. In cases when you do not object to the use of your e-mail for the marketing of our similar goods and services you are granted with clear, free of charge and easily realizable unsubscribe link in all emails from our mailing lists, so that you can remove your contact information at any time. We shall state in each notification sent by email that you are entitled to object to the processing of the personal data or refuse to receive notifications from us.
We will only contact you via your email address in the way which you have given your consent and we will only send you emails on topics as described during the mailing list signup, for instance, news about our products.
We will not share our mailing list subscribers with any other third party, other than as required for us to send emails to the mailing list.
We will only store email addresses in our mailing list.
In case you do not agree to receive these marketing emails offered by us, our business partners or third parties, this will not have any impact on the provision of services to you as the client.
We use cookies and other similar technologies to ensure the stable operations of our website, in order to adapt its content to your needs, to improve the features of our website and to manage advertising campaign based on the interests of our website audience.
For more information regarding cookies, please read our COOKIE POLICY.
The Company will take reasonable precautions to prevent the loss, misuse, accidental or unlawful destruction, modification, disclosure, unauthorized access alteration or any other unlawful handling of information you give us. Agents or contractors of us who have access to information which you give us in the course of providing services to Cosmos Finance are required to keep that information confidential and are not permitted to use it for any purpose other than to carry out the services which they are performing for Cosmos Finance.
The Company and any third-party service providers that may engage in the processing of Personal Data on our behalf (for the purposes indicated above) are also contractually obligated to respect the confidentiality of the Personal Data.
Cosmos Finance will maintain all applicable PCI DSS requirements to the extent proportionate to the cardholder data processed or transmitted on behalf of you, or to the extent that Cosmos Finance could impact the security of your cardholder data environment.
We regularly review this Privacy Policy and reserve the right to modify it at any time in accordance with applicable laws and regulations. Any changes and clarifications will take effect immediately upon their publication on our Website.
Please review this Privacy Policy from time to time to stay updated on any changes.
You may contact us by writing to us at cco@cosmosfinance.com or post us at our relevant registered office address.
Our data protection officer (hereinafter – DPO) continuously monitors our privacy compliance and communicates with us on data protection matters relevant to the provision of our services. You may contact our DPO regarding all issues relating to our company’s processing of your personal data and the exercise of your data protection rights by sending an e-mail to the address: cco@cosmosfinance.com
Privacy policy last modified on: 22nd April 2024
