Privacy Policy of the Vaulter app

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Dear Clients, 

Please read the Privacy Policy carefully before becoming a user of our services (hereinafter: Service User). In the registration process on the Vaulter App, you agree to the Privacy Policy and confirm that you have read, and understood the conditions under which we process your personal data and accepted the Privacy Policy. 

Our company POWRS AB, org. no 559302-8045, Hammarbybacken 27, Stockholm, Sweden, together with our subsidiary company POWRS d.o.o., ID no 21761818, TAX no: 112890694, Kneza Mihaila Street 30, Belgrade, Serbia, mail: queries@vaulter.rs, offers service Vaulter in Serbia, especially with respect and protection of the privacy of each person.

 

POWRS d.o.o. operates as an information company service provider, and it is authorized and has been granted the rights to represent and commercially use the Vaulter Application on the territory of the Republic of Serbia (hereinafter Application).

This Privacy Policy Notice is an integral part of the Terms of Use and contains information about how POWRS d.o.o. processes your personal data in accordance with the Law on Personal Data Protection (“Official Gazette of the Republic of Serbia” No. 87/2018) (LPDP). 

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1. Who is the Privacy Policy Notice intended for?

The Privacy Policy Notice is intended for:

• Vaulter Application users,

• persons who otherwise interact with us.

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2. Our contact details

POWRS d.o.o. BELGRADE from Belgrade, 2 Balkanska St., reg. No.: 21761818, tax ID no.: 112890694, processes your personal data related to the use of the Application in the capacity of an operator and is responsible for the processing of your personal data.

• You can contact us via e-mail address: queries@vaulter.rs

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3. Person for personal data protection

Should You have any questions regarding personal data protection, You can contact the Powrs person for personal data protection via e-mail address: ljiljana.mikic@powrs.se

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4. What personal data does POWRS process, on what grounds, and for what purpose?

Personal data that we process depends on the type of interaction you establish with Powrs. To that end, we process personal data of the category of persons to whom the data refer, as follows:

• Application users,

• persons who otherwise interact with us.

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4.1. Personal data of Vaulter Application users 

When creating a user account or using the Application, we process personal data that You voluntarily share with us and personal data that we generate automatically. 
Powrs processes the Application user’s personal data as follows:

• User account data, including identification and contact data, credentials data (passwords, etc.), and user profile data for the purpose of:

  • Registration and use of the Application based on the execution of agreements with Application Users or taking actions at the request of the person to whom the data refer before entering into the agreement (Art. 12, par. 1, item 2, LDPD), and that: first name and family name, personal number, legal address, username and PIN, e-mail, phone number, face photo, user’s ID card back and front photo and bank account number.

  • Maintaining the required Application security level and prevention of frauds based on compliance with legal obligations.  

• Financial data for the purpose of sale and purchase and payment of the corresponding commission and fee for using the Application, based on execution of the agreement with members (Art. 12, par. 1, item 2, LDPD), compliance with the legal obligations (Art. 12, par. 1 item 3, LDPD) and our legitimate interest (Art. 12, par. 1, item 6, LDPD).

• Data on interaction with other users for the purpose of:

  • Implementation of sale and purchase, based on execution of the agreement with members (Art. 12, par. 1, item 2, LDPD),

  • Maintaining the required Application security level and prevention of frauds based on compliance with legal obligations.

• Data on interaction with Powrs (customer support for the purpose of providing customer support, based on execution of the agreement with members (Art. 12, par. 1, item 2, LDPD) and our legitimate interest (Art. 12, par. 1, LDPD).

• Contact information for the purpose of sending administrative messages (e.g., notices on changes to terms of use, privacy policy, etc.) based on execution of the agreement with members (Art. 12, par. 1, item 2, LDPD) and commercial messages, including personalized offers after your approval (Art. 12, par. 1, item 1, LDPD). You can cancel your previously given consent anytime by clicking “unsubscribe” at the bottom of the commercial message.  

• IP addresses and browser fingerprint (internet browser and device characteristics, operating system, language selection, URL address from which you access the Application, location data, information about the websites You visit, time of access, frequency, and duration of visit, links you access, etc.) for the purpose of fraud prevention, based on compliance with the legal obligations. 

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4.2. Personal data of the website visitors and persons otherwise interacting with us 

When visiting the Powrs website or non-user interaction with Powrs, Powrs processes personal data as follows:

• IP addresses and browser fingerprint (internet browser and device characteristics, operating system, language selection, URL address from which you access the Application, location data, information about the websites you visit, time of access, frequency, and duration of visit, links you access, etc.) for the purpose of fraud prevention, based compliance with the legal obligations and our legitimate interest (Art. 12 st. 1 item 6, LDPD).

• Data on interaction with Powrs (customer support) for the purpose of providing customer support, based on our legitimate interest (Art. 12 st. 1 item 6, LDPD).

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4.3. Use of cookies and scripts on the website 

Powrs d.o.o. uses cookies and scripts on their websites.
Cookies are small text files that are stored on your device when you visit our websites. There are different types of cookies used for different purposes on Powrs’ websites. Cookies are directly set by Powrs (first-party cookies) and third parties (third-party cookies).
The types of cookies we use are:

• Necessary cookies – they enable the basic functioning of the website, and the Application and, as such, are necessary for the functioning of our website.

• Statistics cookies – they enable us to analyze how the visitors use our websites for the purpose of improvement of the website functionality.     

• Functional cookies – they help us remember the choices you make and provide you with a better user experience (e.g., wish list, etc.).

• Marketing cookies – for the presentation of content and ads, including the ones customized to your interests. Marketing cookies are also used by other companies that Powrs cooperates with in order to show you ads related to products and services you are interested in. Use of these cookies requires your prior consent. 

• Secure cookies – enable secure and safe use of the website and the Application and provision of our services.   

 
5. Legitimate interest

In some cases, Powrs processes Your personal data based on a legitimate interest (Art. 12, par. 1, item 6, LDPD). We use this legal basis in situations where our legitimate interest prevails over Your interests and basic rights and freedoms. Our legitimate interest reflects in the maintenance of the required Vaulter Application safety level and prevention of fraud, as well as providing customer support services.    

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6. Manner of processing Your personal data 

Personal data processed by Powrs are disclosed to different data recipients for the purpose of transaction execution and processing or upon the request of the state authorities.  

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6.1. Data processors with whom we share Your personal data 

Data recipients with whom we share Your personal data are most often specific physical or legal entities that process your personal data in the capacity of a data processor based on the contractual relationship they have with Powrs and based on our instructions.
Our data processors are:

• Software solution licensing and maintenance companies used by Powrs in their operations (e.g., an identity verification company that provides Vaulter with the implementation of KYC procedures and solutions (Know Your Client) and AML TF (Anti-Money Laundering and Terrorism Financing).

• Hosting provider company whose servers we use to store data (e.g., payment services provider in Serbia assisting Vaulter users in accessing the payment system with a financial institution).

• Other external associates, we cooperate with (e.g., IT support, marketing agencies).

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6.2. Data operators with whom we share Your personal data 

Data recipients with whom we share Your personal data are also specific physical or legal entities with whom Powrs cooperates, who are also deemed operators (individual or common) regarding Your data processing, such as:

• Financial institution from Serbia (a bank or payment institution, or e-money institution authorized by the National bank of Serbia) as our partner for opening the escrow account, keeping the assets, and executing one-time payment transactions from this account to the end user of the assets. The financial  institution provides payment services to the User-customer that appears as an issuer of all payment orders,

• courier services,

• lawyers,

• advertisers (remarketing).

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6.3. Authorities 

In certain cases, we are obliged to share your personal data with the authorities. Thus, for example, Powrs has a legal obligation based on the appropriate judicial or administrative act to present any data on which basis detection or prosecution of perpetrators of criminal acts can be undertaken.

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7. Your personal data processing period 

We process Your personal data in the amount that is necessary to achieve the purpose of the processing or until the withdrawal of the consent (if the processing is based on consent), unless longer data processing is necessary due to a legal obligation (e.g., accounting obligation) or submission, exercise or defense of a legal claim.

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8. Your rights in terms of personal data

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8.1. Access right 

You are entitled to be informed about whether Powrs processes your personal data and, if yes, about the manner they process our personal data. The above information is contained in this Privacy Policy. This right also includes providing a copy of the personal data Powrs processes about You.

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8.2. Right to correction and supplement  

You are entitled to address Powrs with an application to change or supplement Your incorrect or incomplete personal data.

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8.3. Right to deletion of personal data 

You may contact us with a request to delete the personal data Powrs processes about You. Keep in mind, however, that this right is not always going to be applicable. For example, when Powrs processes personal data based on compliance with legal obligations, it shall not be obliged to act upon Your personal data deletion application. We also provide users with the possibility to decide whether they want to be deleted from the mailing lists that are used for marketing campaigns.

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8.4. Right to limitation of processing 

You are entitled to request us to limit your personal data processing if:

• You dispute the accuracy of personal data,

• Your personal data processing is illegal, and You ask us for limitation of use instead of data deletion,

          we no longer require personal data to achieve the purpose of processing, but you ask for them aiming to submit,                 

          exercise  or defend a legal claim,

• You file a complaint against processing, and an assessment is ongoing as to whether our legal interest in the processing prevails over Your interests.  

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8.5. Right to data portability 

You shall exercise the right to receive personal data that You previously provided to us in a structured, commonly used, and electronically readable form if:

• processing is based on consent or an agreement,

• processing is automatic.

This right also includes the right to have Your personal data directly transferred to another operator if this is technically feasible.

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8.6. Right to objection 

You may file an objection to the processing of Your personal data made by Powrs based on predominant interest (Art. 12 par. 1 item 6, LDPD).
In the case of filing an objection, the processing will be terminated unless there are legal reasons for the processing that overweight your interests, rights, or freedoms or are related to the submission, realization, or defense of a legal claim, which we will present to You. 
If You file an objection in terms of processing for the purposes of direct advertising, Your personal data certainly cannot be further processed for such purposes.

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8.7. Right to revocation of consent 

When processing of Your personal data is based on consent, You may revoke Your consent at any time via e-mail address queries@vaulter.rs or ljiljana.mikic@powrs.se. The revocation of consent shall not entail any consequences and shall not affect the permissibility of the processing that was carried out before the revocation.   

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8.8. The right to file a complaint to the Commissioner

If You believe that Powrs is processing Your personal data contrary to the provisions of the Law on Personal Data Protection, You can file a complaint at any time to the Commissioner for Information of Public Importance and Personal Data Protection, whose contact details are as follows:

• Commissioner for Information of Public Importance and Personal Data Protection

         Bulevar kralja Aleksandra 15, Belgrade, office@poverenik.rs, +381 (0)11 3408 900.

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Please note that filing a complaint to the Commissioner does not affect the possibility of protecting your rights by initiating appropriate court or administrative proceedings.