DTSCB Privacy Policy

This Privacy Policy, which is provided pursuant to Articles 13 and 14 of Regulation EU n. 2016/679 (General Data Protection Regulation – “GDPR”), describes the processing of your personal data carried out by DTS Circle Bank & Statutory Trust – commercially named DTSCB (“DTSCB” or “we”, “us”, “our”) when you use our Payment Service platform or browse / interact with our website www.dtscb.com (“Website”).

Protection and privacy of your personal data are our priority. Please read the following carefully to understand our views and practices regarding your personal data and how we will process it.

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Address: 111 Buckingham Palace Road – Office 3.39 – London UK
E-mail: info@dtscb.com

Indirizzo: Kathleen Court Trip il Kappucini, Flat 1 - Zabbar – MALTA
Indirizzo: e-mail office@dtsmail.tech

Website navigation data - Cookies While navigating and interacting with our Website, DTSCB and/or its partners collect navigation data (with your permission whenever it is mandatory by applicable law): i. technical information including: IP address, information on the device, operating system, browser and software you use; ii. information on the navigation on the Website including: URL of pages browsed and the activities carried out on these pages, (e.g. products viewed and eventually purchased), date and time of access, duration of access and clickstream. This information is collected to ensure the best functioning, management, and maintenance of the Website as well as the in order to ensure you a safe experience on the Website and to ascertain the liability in case of any breach or unlawful access. In addition, we analyse these information -also as aggregated data- in order to obtain statistics on the performance of the Website. Furthermore, with your permission with the acceptance of the specific cookie policy, we will process your navigation data in order to find products/services you prefer and to show you pertinent advertisements or interactive function of this Website. You are completely free to provide your navigation data. However, the refusal to provide for the information necessary information may make the access and the navigation on Website as well as connected activities impossible. We will store these data as long as they are necessary for the purpose for which they are collected. Navigation data are collected with the use of cookies. In order to understand how cookies work in particular or how to enable or disable them, please see our Cookie Policy.

The Website may allow links to other websites or internet resources operated by third parties, also for advertising purposes. With regard to privacy protection instruments and the processing of personal data collected by such websites (including social network, if applicable), please refer to the relevant privacy policies. DTSCB cannot in any way be held responsible for the processing of personal data carried out by such websites or third party pages.

DTSCB provides experiences on social network platforms that enable online sharing and collaboration among users who have registered to use them. We may collect information you provide by interacting with us via social network, such as photographs, opinions and any personal data that you make available. In addition, when you visit a DTSCB’s page on a social network, whether by clicking on a social network link button or browsing directly through social network pages (including advertisements), the social network operator may share certain information about you with DTSCB. In particular: i. Your actions, such as: viewing and interacting with our social page and any content posted on it (including shares, reactions, comments), clicks and private e-mail communications on our social page; ii. Information about those actions, the people who carry out those actions and the browsers/apps used for them. iii.

If you contact us for support, we will process any data you decide to share to enable us to respond to your request for assistance. In addition, if you contact us by phone, upon you giving consent, we will record the phone call and process any data referred therin for internal business quality purposes and to improve our customer care.

By filling the form on our Website to create your account and get a card and – subsequently, by using our service, you will provide us with the following data: Name and surname, place and date of birth, e-mail address, country, postal address, telephone number, details on your being (or not) a PEP, ID documents, social security number, financial, assets and earnings data, bank account details, transactional information, User ID.

DTSCB may process data relating to criminal convictions, offences and related security or prevention measures applied to users which apply to become a Payment Service customer as it is necessary in order to comply with legal obligations to which DTSCB is subject, particularly in relation to anti-money laundering and preventing the financing of terrorism. Kommentar [P4I1]: Per favore mettete un Hyperlink a Cookiebot per evitare di creare un documentto apposito come suggerito dal legale incaricato. Therefore, upon registration for our services, we stard a due diligence process on you, which which may imply the provision of these type of data from publicly accessible sources of proven reliability and authority, as well as from providers of specialised databases.

Through the analysis of your online transactions, as well as your interaction with social networks, upon your consent, we will analyse your habits and preferences in order to profile you as a consumer and provide you targeted advertising, as well as to produce analytical reports of aggregated data which we then use for marketing and statistical purposes and pass on to partners and third parties for their own marketing purposes, subject to your consent.

DTSCB Payment Services are not directed to individuals under the age of eighteen (18). Therefore, if a user fills forms on our Website or contacts DTSCB with regard to the Payment Service, we assume he/she is at least 18 years old. On the basis of this premise, any consent to data processing given by the user on our Website shall be deemed valid. In any case, any consent given on our Website by a person under sixteen (16) years of age shall in any event be deemed invalid. If you, as the legal representative or guardian of a minor, are giving consent to the processing of personal data on behalf of a child under eighteen (18) years of age then please be aware that minors need specific protection with regard to their personal data, as they may be less aware of the risks, consequences and safeguards concerned, and also of their rights in relation to the processing of personal data for the purposes of using these services. In such event, you assume any responsibility connected thereto. By accepting this privacy policy, on behalf of a minor, you are giving permission for their data to be used for the purposes described above and DTSCB will not be held responsible in any way.

Personal data will only be processed by employees and collaborators of DTSCB and its European representative expressly authorised by DTSCB to process them.

Your personal data may be disclosed to and processed by third parties acting as data controllers such as, by way of example:  public authorities, supervisory authorities, control bodies, law enforcement agencies, and, in general, public or private parties (such as legal advisors, accountants, auditors) where necessary for the exercise or protection of our rights, as well as to comply with legal obligations;  public or private third parties – as the case may be – in the context of extraordinary operations, including M&A operations, transfer of company assets and other transactions, for legitimate interests of DTSCB, to the extent permitted by applicable law;  private third parties (including broker you indicate us, as well as DTSCB’s partners or affiliates) for the performance of the Payment Services and/or for purposes under this Privacy Policy;  private third parties (including DTSCB’s partners or affiliates), for their own direct marketing purposes, subject to your prior consent thereto.

The data may be processed, on behalf of the data controller, by third parties acting as data processors, who are given appropriate operating instructions, such as:  Service providers (including IT developers and programmers, cloud providers, email providers, marketing companies),  Advisors,  Accountants,  IT developers and programmers Such data processors have been selected among professionals who guarantee the implementation of appropriate technical and organizational measures, so that the processing is always carried out in compliance with applicable legislation and ensuring the protection of data subjects’ rights. The updated list containing the data processors is available by sending a written communication to the data controller or an e-mail to privacypolicy@dtscb.com

You can obtain access to your personal data and relevant copy, as well as their erasure, the rectification of inaccurate or incomplete data, or the limitation of the processing of your personal data according to Article 18 of GDPR; You also have the right to object to the processing of your personal data at any time in relation to your particular situation. Right to object to the processing of personal data for direct marketing purposes is absolute and can be exercised at any time (Article 21 of GDPR). If the processing of your personal data is based on consent, you have the right to withdraw your consent at any time (Article 7 of GDPR). If the conditions for the right to data portability under Article 20 of the GDPR are met, you have the right to receive in a structured format, commonly used and readable by automatic device the personal data you provided us and, where technically feasible, to the secure transmission of your personal data to another data controller. In order to protect your rights and your personal data, anytime, you may decide to file a complaint to the competent supervisory authority (in particular, in the EU State where you usually reside or work or in the State where any alledged violation of your data has been committed). You can execrise you rights by writing to the data controller by mail, at the above address, or by e-mail at the following e-mail address: compliance@dtscb.com. It is understood that, where your request is made by electronic means, the information will be provided in a commonly used electronic format.

This Privacy Policy is constantly updated. For this reason, we indicate the date of the latest update at the head of this Privacy Policy. In case you have already provided your personal data to DTSCB, you will be informed about any substantial change with the appropriate means with a view to ensuring full transparency of the processing and full and adequate protection of your rights. However, we invite you to constantly check the Privacy Policy to be informed on its updates.