Ecommbx Limited Privacy Statement

Last updated 25/09/2020

Ecommbx Ltd (referred to as ‘we’, ‘us’, ‘our’ or ‘the Company’) offers its customers products and services relating to electronic money. During the course of our business relationship, we collect and process personal data. In particular the personal data which is processed by us is that of natural persons who are our customers, contractors, business affiliates and/or visitors to our website as well as personal data of any other individuals including but not limited to authorised representatives, employees, directors, beneficial owners and shareholders of our customers, contractors and/or business affiliates, being legal entities. As a result, the Company is committed to protecting the privacy and handling of data in an open and transparent manner.

For the purposes of this privacy statement,

‘personal data’ means any information relating to an identified or identifiable natural person (“data subject”); an identifiable 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;

“processing” means any operation or set of operations which is performed on personal data, whether or not by automated means, such as collection, recording, storage, use, disclosure, erasure or destruction.

“business relationship” means our commercial and/or business and/or other relationship with you including, but not limited to, provision of our services to you or vice versa and the various transactions entered into between us and you from time to time.

This Privacy Statement provides an overview of how the Company processes your personal data in order to be in compliance with the provisions of the Processing of Personal Data and for the Free Movement of such Data of 2018 (Law 125(I)/2018) (hereinafter the “Law”) as amended and/or replaced from time to time, the provisions of Regulation (EU) 2016/679 (hereinafter the “EU Regulation’’) and any other legal and/or regulatory requirements.

Purpose of this Privacy Statement:

This Statement aims to provide you with information about the processing of your personal data when establishing a business relationship with us. Additionally, the purpose of this Statement is to inform you inter alia, of your data protection rights under the current legislative and regulatory framework.

Who we are:

ECOMMBX Ltd, is an Electronic Money Institution incorporated in 2016 in the Republic of Cyprus under the registration number HE354749. We are fully authorised and licensed by the Central Bank of Cyprus with license No. to provide services on a professional basis within the framework of the relevant Law (No. 86(I) of 2004) and the corresponding Directive (2009/110/EC) of the European Parliament and of the European Council for issuing of e-money also known as an Electronic Money Institution.

We are a data controller in respect of your personal data. This means that we are responsible for determining the purposes and means of the processing of such personal data.

If you have any questions or require additional details on how we use your personal information, you can contact our Data Protection Officer at: and/or (+357 22270349)

Our Principles

When we process your personal data, such data is:

(i) Processed lawfully, fairly and in a transparent manner in respect to the data subject (‘lawfulness, fairness and transparency’);

This means that we provide information to you in respect of the processing of your personal data (transparency), the processing matches the description given to you (fairness), and that it is based on at least one of the lawful basis set out in the GDPR (lawfulness).

(ii) Collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes; (‘purpose limitation’);

This means that we specify exactly what personal data is collected for, the purpose of use and limit the processing of personal data to only what is necessary to meet the relevant purpose.

( iii) Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (‘data minimisation’);

This means that we do not process any personal data over and above what is required.

(iv) Accurate and, where necessary, kept up to date; every reasonable step is taken to ensure that personal data that are inaccurate, having regard to the purposes for which they are processed, are erased or rectified without delay (‘accuracy’);

This means that we have in place processes for identifying and addressing out-of-date, incorrect or unnecessary personal data.

(v) Kept in a form which permits identification of data subjects only for the period necessary for the purposes for which their personal data are processed (‘storage limitation’);

This means that we store personal data only for the max required period and delete them right after in such a way that limits or prevents identification of the data subject.

(vi) Processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (‘integrity and confidentiality’).

Personal data we process and collection of personal information:

We process personal data that we receive from you in the context of our business relationship. We collect and process different types of personal data received from data subjects themselves, or their representatives, or our website, in the context of our business relationship. We may also collect and process personal data which we lawfully obtain from other entities of our Group, or public authorities, client introducers, or publicly available sources (such as the Cyprus Registrar of Companies and the media) lawfully obtained and permitted to process.

Such personal data may include, amongst others:

* Government issued identifiers and other Identification data, such as passport, identification card, social insurance number, tax identification number;

* Contact information such name, surname, address (including proof of address e.g. utility bill), telephone, fax number, e-mail address and country of residence)

* Personal characteristics such as date of birth and country/place of birth, nationality;

* Economic Data such as bank account number/details, data on transactions, financial information including origin of wealth, tax income, earnings);

* Communication data such as name, surname, email, postal address (including proof of address e.g. utility bill), telephone number, tax number and country of residence);

* Functions and powers of relevant representative(s);

* Employment and occupation information(including but not limited to CV, professional memberships, job title and responsibilities, professional qualifications;

* Data from payment transactions and payment services; and

* Data relating to telephone communications with you, which may be recorded in compliance with legal requirements.

We do not process, without your explicit consent (and/or where the processing is necessary for the establishment, exercise or defence of legal claims relevant to us), personal data revealing racial or ethnic origin, political option, religious or philosophical beliefs, trade union membership, genetic data, data concerning health or data concerning a natural person’s sex life or sexual orientation, referred to as special categories of personal data in the EU Regulation.

If during the course of our business relationship there is a change in your personal data, you must ensure that the above details (as and where applicable) are updated by contacting us as soon as practically possible.

Once our business relationship has ended and the period for maintaining your personal data has lapsed (see data retention paragraph below ), the Company may proceed with the pseudonymisation, of such personal data for the purposes of maintaining an archive for historical, statistical and research purposes.

Children’s data

We do not provide any services to children however certain transactions may be related to such. We may collect personal data in relation to children who are under the age of fourteen (14) only if we have obtained the explicit consent from their parents’ or legal guardian’s or unless otherwise permitted by law.

Purposes of processing your personal data

We will process your personal data (as and where applicable) for the following purposes;

(a) Meeting our obligations under our business relationship and/or agreement entered into between us, including inter alia in relation to the provision of our (financial) services;

(b) Customer acceptance and onboarding procedures, customer communication, customer relationship purposes;

(c) Maintaining and developing our business with our customers, the carrying out of surveys and direct marketing (including via our website);

(d) Operation, management and control of the affairs of our business and its purposes;

(e) Maintaining our IT systems, including our human capital, administrative and management systems, processes and policies;

(f) Maintaining and developing our business relationship with you;

(g) Complying with any requirement of law and/or regulation (e.g. KYC requirements under the Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007, as amended) and/or competent authority or professional body (where applicable);

(h) Developing verification procedures and processes, anti-money laundering controls etc.

Legal basis of processing your personal data

Your personal data are processed in compliance with the provisions of the EU Regulation, the applicable local legislation as amended and/or replaced from time to time as well as any other relevant legislation.

Your personal data are only used for the purpose for which we collected it, unless there are reasonable ground for using them for any other reason which is compatible with the original purpose. We process your personal data for the purposes mentioned above on the following basis:

(a) Processing is necessary for compliance with a legal obligation such as anti-money laundering or regulatory requirements for the Central Bank of Cyprus.

(b) Processing is necessary for entering or performance of contractual obligations which you have entered with us .

(c) Processing is necessary for the purposes of the legitimate interests pursued by us . This may include preventing crimes, fraud and money laundering activities, actions to manage our business and further develop our services, direct marketing, risk management, initiate legal claims and preparing a defence in the event of litigation, disclosing information to other data recipients such as our service providers, auditors and technology providers and/or to comply with obligations or internal policy requirements of our business, and/or to monitor and improve our relationships with you and/or to keep our internal records and/or to monitor communication to/from you using our systems and/or to protect the integrity of our IT systems.

(d) Based on your consent. Insofar as you have granted us specific consent for processing (other than for the reasons out hereinabove), then the lawfulness of processing is based on your consent. In case consent is relied solely upon to achieve a lawful basis of processing of your personal data, you have the right to revoke your consent at any time by contacting us.

Data retention:

The Company retains personal data for as long as there is a business relationship with customers. Once the business relationship is ended, personal data are kept up to ten (10) years or as required under applicable law. Your personal data may be retained for longer periods for the purposes of our legitimate interests in case of any legal process commencing prior to the completion of the 10-year period.

For prospective business relationships the Company shall keep personal data for six (6) months from the date of notification of the rejection or from the date of withdrawal of the customers application. Such data may be kept in an identifiable form for the purposes of re-assessing the (acceptance of the) business relationship or in an anonymized form for the statistical/development purposes.

Who we disclose your personal data to:

Your personal data may be shared with organisations and bodies including but not limited to:

(a) Independent advisors, auditors and accountants, lawyers, tax advisors, valuators, consultants, credit reference and fraud prevention agencies and other professional advisors (as shall be engaged from time to time).

(b) Public and/or regulatory and/or supervisory authorities such as Central Bank of Cyprus, Tax authorities, law enforcement authorities, courts and tribunals.

(c) Our IT service providers and other companies who assist us with the effective operation of our business by providing technological expertise, file storage and record management, logistic services and solutions and other subcontractors.

(d) Companies or individuals you ask us to share your personal data with.

(e) Persons acting on behalf of beneficial owners/shareholders of our clients/contractors being legal entities, including and not limited to payment recipients, beneficiaries, account nominees, intermediary, correspondent and agent banks.

(f) Legal or natural persons with which we have contracted for the provision of services, who are bound by confidentiality and data protection obligations according to the applicable data protection framework.

(g) Other member companies and/or entities of the group of companies which we belong to.

(h) Regulatory and public authorities.

(i) Banks and/or other licensed financial institutions based in Cyprus or abroad for facilitating the execution of transactions and any other services you request.

Your information may also be shared in case the Company’s structure alters or if we choose to transfer, sell part of our business or seek to merge with other companies.

Data transfer to Third Countries or International Organisations

Your data may be transferred in countries outside the European Economic Area to a recipient (i) who is in a country which provides an adequate level of protection for personal data or (ii) under appropriate safeguards pursuant to the provisions of applicable data protection laws (e.g. under an agreement in the form of standard data protection clauses adopted by the European Commission), the form of which is available at . In some (occasional) cases we may carry out such transfers where (a) we have obtained the explicit consent from the relevant data subject in respect of the proposed transfer, provided that the data subject has been informed of the possible risks of such transfer (due to the absence of an adequacy decision and appropriate safeguards); (b) the transfer is necessary for the performance of a contract between the data subject and us, or (c) the transfer is necessary for the performance of a contract concluded in the interest of the data subject between us and another person or (d) the transfer is necessary for the establishment exercise or defence of legal claims.

Automated decision-making, including profiling

We do not take decisions solely on the basis of automated processing. However, some of your personal data may be processed by automatic means in order to evaluate certain of your personal aspects, in the following cases:

* Carrying out data evaluations, which may include payment transactions, in the context of anti-money laundering and anti-terrorism financing measures. These evaluations are carried out to protect you.

* Marketing of services and products of the Company, as long as you have consented.


Your personal data will be used for direct marketing purposes where you have explicitly consented to do so, or when such processing is necessary for the purposes of the legitimate interests pursued by us. Where we rely on such legitimate interest, you have the right to object at any time to such processing of data. In such a case we shall no longer process such data for direct marketing purposes.

Your Personal Data Rights

The following are the rights you have pursuant to the provisions of the EU Regulation and any other relevant legislation:

(a) Right to access - you have the right to request a copy of the information that we hold about you.

You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. Such additional information includes inter-alia, details of the purposes of the processing, the categories of personal data concerned and the categories of recipients of the personal data. The right to obtain a copy of your data shall not adversely affect the rights and freedoms of others.

(b) Right to rectification. You have the right to request rectification of inaccurate or incomplete personal data concerning you.

You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(c) Right to erasure (‘’right to be forgotten’’). You have the right to request erasure of personal data, where one of the following grounds applies:

* Personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

* You withdraw your consent on which the processing is based and where there is no other legal ground for the processing;

* You object to the processing and there are no overriding legitimate grounds for the processing, or you object to processing for direct marketing purposes;

* Personal data have been unlawfully processed;

* Personal data have to be erased for compliance with a legal obligation.

The above shall not apply where processing is necessary (i) for exercising the right of freedom of expression and information; (ii) for compliance with a legal obligation which requires processing by a law to which we are subject; and (iii) for reasons of public interest; or for the establishment, exercise or defense of legal claims.

(d) Right to restriction of processing. You have the right to obtain restriction of processing where one of the following applies:

* The accuracy of the personal data is contested for a period enabling us to verify the accuracy of the personal data.

* The processing is unlawful, and you oppose the erasure of such data and you request the restriction of their use instead.

* We no longer need the personal data for the purposes of processing, but you require their retention for the establishment, exercise or defence of legal claims.

* You have objected to processing on the grounds of our legitimate interests, until we verify whether the grounds on which we process your information override your rights and freedoms.

Where processing has been restricted on the basis of the above, we will continue to store your personal data. However, we will only otherwise process it (i) with your consent; (ii) for the establishment, exercise or defense of legal claims; (iii) for the protection of the rights of another natural or legal person; or (iv) for reasons of important public interest.

(e) Right to portability. You have the right to receive the personal data that you have provided us in a structured, commonly used and machine-readable format and you have the right to transmit those data to another organization and/or request that we do it for you, provided that:

* The processing is based on your consent, or for the performance of our contractual obligations, or at you’re your request for the purposes of entering in a contractual relationship with us.

* Processing is carried out by automated means.

(f) Right to object. You have the right to object to the processing of your personal data, at any time and for reasons related to your particular situation where the legal basis on which the processing activity is based on our legitimate interests. Should you exercise this right, we will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where you have objected to processing for direct marketing purposes we shall no longer process your personal data for such purposes.

(g) Right to withdraw consent. Where the processing is based on your written consent you have the right to withdraw consent at any time.

To the extent that the legal basis for our processing of your personal data is consent (as and where applicable), you have the right to withdraw that consent at any time such withdrawal will not affect the lawfulness of processing before the withdrawal.

(h) Right to lodge a complaint. You can contact us for any personal data related matters in the details mentioned above. In case you are not satisfied or still have concerns you may file a complaint with the Office of the Commissioner for Personal Data Protection. You can find out on their website how to submit a complaint.
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Data Security

We process personal data which is adequate, relevant and limited to what is necessary in relation to purposes mentioned above and we have taken adequate organizational, technical and administrative measures in order to safeguard and reasonably protect your personal data against loss, misuse disclosure, alteration and unauthorized access. Such measures include firewalls, encryption, access restriction and authorization controls. We are devoted in protecting your personal data; however, security cannot be absolutely guaranteed against threats. As soon as we become aware of any data breach that may cause a disadvantage to you, you will be notified without undue delay.

Further Information

Further information and/or queries and/or requests regarding the processing of your personal data and any of your rights (where applicable) in respect of your personal data, can be requested by contacting us in writing as follows:

By e-mail:

By post: 27 Pindarou Street, Alpha Business Centre, 3rd floor, 301 Office Block A, 1060, Nicosia, Cyprus

Changes to this Privacy Statement

This Privacy Statement may be modified from time to time so as to be in compliance with legal regulations. You will be notified appropriately when any changes are made (as and where applicable). The revised Privacy Statement will be available on our website and we highly recommend that you review this Privacy Statement to be informed on the way we protect and process your personal data.

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