Privacy Policy

At ETERBASE a.s., (“ETERBASE” or Controller) we take the privacy of those we do business with very seriously and we are committed to protecting the privacy of all our clients and business partners. Data protection is of a particularly high priority for us. The use of the ETERBASE website is possible without any indication of personal data; however if a data subject wants to use ETERBASE services via our website, processing of personal data will become necessary. If the processing of personal data is necessary and there is no statutory basis for such processing, we generally obtain consent from the data subject.

The processing of personal data, such as the name, address, e-mail address, or telephone number of a data subject shall always be in line with the Law on Legal Protection of Personal Data of the Republic of Slovakia, other applicable laws and legal acts, as well as the legal acts of the European Union and in accordance with the country-specific data protection regulations applicable to ETERBASE.

ETERBASE values your trust and by means of this privacy policy, ETERBASE would like to inform you of the nature, scope, and purpose of the personal data we collect, use and process. Furthermore, you are informed, by means of this data protection declaration, of the rights to which you are entitled. ETERBASE has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed.

Please read the following carefully to understand our practices regarding personal data and how ETERBASE will process it.

Definitions

The privacy policy (hereinafter referred to as: “Policy”) of ETERBASE is based on the terms used by the European legislator for the adoption of the General Data Protection Regulation (GDPR). In this Policy, unless it is expressly provided otherwise, or the context otherwise required, the following terms shall have the meaning set forth below:

“Data Controller” (also ”ETERBASE”, “we”, “our”, “us”) means ETERBASE a.s., a company organized and validly existing under the laws of the Republic of Slovakia, which determines the purposes and means of the processing of personal data.

“Data Subject” (also “you”, “your”) means any natural person identified or directly or indirectly identifiable on the basis of Personal Data.

“Data Processing” means the performance of technical tasks related to data management regardless of the method, means and place of application.

“Data Processor” means a natural or legal person or organization without legal personality performing Data Processing on the basis of a contract concluded with the Data Controller.

“Data Transmission” means granting access for specified third persons to data.

“Data Management” means any operation or set of operations performed by the Data Controller on data, in particular collection, record, organization, storage, alteration, usage, query, transmission, disclosure, alignment, combination, deletion and erasure of data irrespective of the means thereof.

“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.

“Consent” of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.

Purpose of personal data processing

ETERBASE processes personal data to perform operations as a payment services provider including by not limited to:

  1. Provision of payment services;
  2. Conclusion and execution of the agreements concluded;
  3. Meeting the requirements of the Law on Prevention of Money Laundering and Terrorist Financing;
  4. Customer identification;
  5. Other legal and predeterminate goals which are set before the collecting personal data;
  6. Customer relationship management and development;

We also may use personal data for direct marketing (in other words – customers relationship management and development) purposes and to promote new services that may be of interest to you. This may be by post, telephone or email. You may at any time withdraw your consent to the processing of your personal data for the purposes of the direct marketing by sending to us the notice regarding your refusal of receiving the offers of direct marketing.

Information collected

The type of personal information ETERBASE collects depends on the Accounts opened or services requested. It may include:

Representatives of clients (legal entities) (members of the client’s management bodies and other representatives (for example, employees) who are authorized to represent the client in relations with the data controller acting according to corporate documents): personal identification number, identity document details, workplace, e-mail address, gender, position title, surname, nationality, telephone number, first name, photo, signature, bank account information (bank name and bank account number), monetary transaction or transaction date, amount, currency, the data on the recipient of the funds (natural person’s name, date of birth, personal identification number or other unique character sequence assigned to this person for identifying the person; the legal entity’s name, legal form, address, code, if any);

Beneficiaries of clients (legal entities) (natural persons who directly or indirectly own or control a legal unit, having a sufficient number of shares or voting rights, including through bearer share management): personal identification code, identity document, gender, surname, nationality, first name, photo, signature, the number of shares held, the voting rights or the share capital held, the date of the monetary transaction or transaction, the amount, the currency in which the monetary transaction was carried out, the data on the beneficiary (natural person’s name, surname, date of birth , personal code or other unique character assigned to this person to identify the person; the legal entity’s name, legal form, address, code, if any).

In general, ETERBASE obtains personal information from the following sources:

To the extent that applicable law requires express consent or “optin” for the collection and use of personal information, ETERBASE will maintain processes and procedures to ensure such information is collected with express consent.

The data subject may decline to submit Personal Data through ETERBASE services, in which case ETERBASE is not obliged to provide certain services to the client. The client may update or correct his/her personal information and email preferences at any time by emailing at support@eterbase.com.

Cookies

What are cookies?

Cookies are small text files which can be sent to browser when you visit websites and saved to your device (computer or other device with Internet access, i.e. smartphone or tablet). Cookies are saved in the folder for files of your browser. Cookies usually contain the name of the website they come from and the date of origin. Upon your next visit the browser loads cookies again and sends this information back to the website which originally created cookies. Cookies we use do not harm your computer.

Using cookies

By using the websites operated by Eterbase you give your consent to using cookies in compliance with your browser settings. If you visit our websites, acceptance of cookies is allowed in your browser, you do not change your browser settings and continue visiting our websites we consider it as accepting our conditions for using cookies.

Why are we using cookies? 

Cookies are used to optimally create and constantly improve the quality of our services, adjust them to your interests and needs and improve their structure and contents. Eterbase does not use data obtained by using cookies to contact users by mail, e-mail or telephone.

How cookies make our website safer and easier to use?

We use cookies to safeguard your privacy when you’re browsing our websites. We also use them to let you use secure online application and contact forms. If you leave a secure session window open when logged in, we use cookies to enhance your security by prompting you to end (or automatically ending) your secure session. Finally, we use ‘analytics’ cookies to help us make our website better for those who visit it regularly. They help us work out what users like and don’t like and how we can improve things for you.

How to change settings of cookies?

Majority of browsers has been originally set to automatically accept cookies. These settings can be changed by blocking cookies or by a notification in case cookies are to be sent to your device. Instructions for changing cookies are available in the option “Help” of every browser. If you use different devices to access websites (e.g. computer, smartphone, tablet), we recommend you to adjust every browser on each of them to your preferences regarding cookies.

Collection of general data and information

The ETERBASE website collects a series of general data and information when a data subject or automated system calls up the website. This general data and information are stored in the server log files. Collected may be the browser types and versions used, the operating system used by the accessing system, the website from which an accessing system reaches our website (so-called referrers), the sub-websites, the date and time of access to the website, an Internet protocol address (IP address), the Internet service provider of the accessing system, and any other similar data and information that may be used in the event of attacks on our information technology systems.

When using these general data and information, ETERBASE does not draw any conclusions about the data subject. Rather, this information is needed to deliver the content of our website correctly, optimize the content of our website, ensure the long-term viability of our information technology systems and website technology, and provide law enforcement authorities with the information necessary for criminal prosecution in case of a cyber-attack. Therefore, ETERBASE analyses anonymously collected data and information statistically, with the aim of increasing the data protection and data security of our company, and to ensure an optimal level of protection for the personal data we process. The anonymous data of the server log files are stored separately from all personal data provided by a data subject.

The right to access to information and correction of personal data

In accordance with statutory regulations on data protection, you have the right to access the Personal Data relating to you and which has been collected or disclosed by us and the right to have such personal data rectified in case such personal data is inaccurate or incomplete. You have the right:

In this respect, you may receive a copy of the Personal Data that we hold on file. For any further copies, we reserve the right to charge a reasonable fee based on administrative costs. To exercise this right, please contact us as indicated in this Policy.

Eterbase undertakes that all other rights of data subject as described in applicable laws are guaranteed for you as data subject.

Use of Information Collected

As we collect, store and process various types of personal data, we feel that it is essential to make clear the purposes for such operations.

ETERBASE uses information collected for a variety of reasons, including, without limitation, opening, maintaining and servicing Accounts, completing and administering transactions, analysing Accounts and transaction information, managing its client relationships, preventing fraud and abuse, and as otherwise permitted or required by law. The personal data entered by the data subject are collected and stored exclusively for internal use by ETERBASE, and for its own purposes. ETERBASE may request transfer to one or more data processors that also uses personal data for an internal purpose which is attributable to the controller.

By registering for services on the website of ETERBASE, the IP address, date and time of the registration are also stored. This data is stored with the aim to prevent the misuse of our services, to secure the data controller, and, if necessary, to make it possible to investigate committed offenses.

The registration of the data subject, with the voluntary indication of personal data, is intended to enable the controller to offer the data subject services that may only be offered to registered clients.

The record of communication

For evidence purposes, all communications with you relating to business transactions or any commercial communications may be recorded. Recordings will be kept for a limited period of time (but not longer than required or permitted by applicable law, notably with respect to legal prescription periods) and may serve as evidence in case of a dispute over any commercial transactions or any other commercial communications with you as well as it required to be kept according to our internal procedures and policies and to comply with applicable law and regulations.

Amendment, deletion and destroying of Data

As a registered client, you can view your personal data stored by us at any time in the front-office area of your ETERBASE account or you can connect with our support team at support@eterbase.com for further information. You can request editing or deletion of these data from our database if your Personal Data have changed, or if you decide to stop using our services, without limitations, by contacting us at support@eterbase.com .

You understand and accept that the deletion of your ETERBASE account does not mean the immediate deletion of all your personal data stored by us. We will retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. The data retention period shall be 10 years after the end of the business relationship between data controller and data subject.

Sharing of Information

ETERBASE may share personal data with third-party data processors under contract only in the ways that are described in this Policy. ETERBASE may disclose some or all of your personal information to our agents, service providers or certain financial institutions for the purposes of opening, maintaining and servicing accounts, processing requested transactions, fraud prevention, validation of user credentials, secure data storage or to perform business support functions on ETERBASE’s behalf, including compliance and similar services. ETERBASE ensures that these data processors only use personal data in connection with the services they perform for ETERBASE. Some of the data processors may be located in foreign countries in locations inside of the European Union and European Economic Area. We do not sell your personal data to third parties.

ETERBASE may transmit personal data if the applicable legal provisions so require, or when such action is necessary to comply with any laws, such as to comply with a subpoena, or similar legal process, authorities’ or court’s orders, for the protection of our rights and interests, to protect your safety or the safety of others or to investigate fraud.

If ETERBASE becomes involved in a merger, acquisition or any form of sale of some or all its business or assets, ETERBASE may disclose personal data to third parties in connection with the evaluation of the transaction. The surviving company, or the acquiring company in the case of a sale of the business or assets, would have access to your personal data which would continue to be subject to this privacy statement.

You understand and accept that ETERBASE, our website and our services may contain or implement applications, APIs, tokens, extensions, etc. that may be necessary for the operations of our services or allow you to interface with or link to or from various websites and services provided by trustworthy third parties. These companies are authorized to use your personal information only as necessary to provide these services to us.

Data Security

ETERBASE utilizes physical, electronic, organizational and procedural security measures to protect against loss, misuse, and alteration of information under our data management. ETERBASE offers industry–standard practices and security measures to safeguard and secure the personal information we collect.

When you use our services, we encrypt all and every transmission of information using Secure Socket Layer technology (SSL). We follow generally accepted standards, and we usually go beyond the standards to protect the personal information submitted to us, both during transmission and one we receive it. We never collect or store your authentication keys and passwords in an unencrypted or invertible form. Our employees are bound by internal information security policies and are required to keep information secure. If you have any questions about security on our site, you can contact us at support@eterbase.com.

Privacy practices of third parties

Our site includes links to other websites whose privacy practices may differ from those of ETERBASE. If you submit personal data to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit. ETERBASE is not responsible for the content or information practices employed by other third party websites that are linked to or from our website. These links are provided as pointers to information on services that may be useful to ETERBASE Clients.

Changes to this Policy

As every high-quality service, ETERBASE constantly improves its services in effort to keep our clients satisfied. But these improvements necessarily mean changes. Due to the on-going changes in the law and technology, data practices will change from time to time. Thus, ETERBASE reserves the right to alter or modify this Policy when it is necessary. Your privacy will not be reduced without your consent. If you are concerned about how your information is collected, stored, used or disclosed, you should periodically check back at this page.

Contact possibility via the website

The website of ETERBASE contains information that enables a quick electronic contact to ETERBASE, as well as direct communication with us, which also includes a general address of the so-called electronic mail (e-mail address). If you contact ETERBASE by e-mail or via a contact form, the personal data transmitted by you are automatically stored. Such personal data transmitted on a voluntary basis by you to ETERBASE are stored for the purpose of contacting you. There is no transfer of this personal data to third parties.

You are entitled to enquire adjustment or deletion of your stored personal data. Furthermore, if you have questions about this Policy or want to know further information or explanation about the data we store about you, please contact us by email at support@eterbase.com.

ETERBASE a.s.