Data Usage and Privacy Policy
This policy describes the information we process to support SALVE FINANCIAL HUB and other services, products, and features (abbreviated by SPF) offered by it. In addition, SALVE FINANCIAL HUB complies according to EU Regulation 2016/679 (General Data Protection Regulation) about the protection of personal data, to those who interact with our SPF in different ways.
A. What kinds of information do we collect?
A.1. Information and content you provide:
We collect the content, communications, and other information you – or through your profile – provide when you use our SPF, including when you sign up for an account, edit your profile, create content, send messages, upload documents, enter beneficiary information, communicate with us via available features such as helpdesk or do monetary transactions. This can include information in or about the content you provide. Our systems may automatically or manually process your activities to analyze context and what’s in them for the purposes described below.
A.1.1. Compliance and Risk check:
We collect from you (which, for the purposes of this section, refers to you and your business) information such as you declared while onboarding or edited and added once you became our official user, information of your beneficiaries, information, and documents you added in relation to the purpose of your monetary transactions (invoices, inspection letters, shipping information, or whatsoever)
A.1.2. Your profile information:
We collect from you (which, for the purposes of this section, refers to you and your business) identifying information such as your name, your business name and nature registry details, addresses, phone numbers, and e-mail. Depending upon the Services you request, we may collect additional Personal or related to your business information such as National ID, State ID, or Passport; your citizenship and military status; Tax ID, bank account and transaction information; information about your education, employment history, property; criminal offenses; credit history; credit score; credit report; dependent/beneficiary name(s); biometric information; and other personal identification numbers, scanned versions of your business’ legal documents.
A.1.3. Your usage:
We collect information about how you use our SPF; and the time, frequency, and duration of your activities. For example, we collect logs when you’re using and have last used our SPF, the contents you view, and the transactions you submit.
A.1.4. Information about transactions made on our SPF:
If you use our SPF for financial transactions, we collect information about the transaction. This includes payment information, such as your payee’s account and information; and billing, shipping, and contact details.
A.1.5. Device Information:
We collect information from and about the computers, tablets & phones, and other web-connected devices you use that integrate with our SPF, and we combine this information across different devices you use which includes:
A.1.5.1. Device attributes:
Information such as the operating system, hardware and software versions, signal strength, available storage space, browser type, app and file names and types, and plug-ins.
A.1.5.2. Device operations:
Information about operations and behaviors performed on the device, such as whether a window is foregrounded or backgrounded, or mouse movements (which can help distinguish humans from bots).
A.1.5.3. Identifiers:
Unique identifiers, device IDs, and other identifiers from accounts you use.
A.1.5.4. Data from device settings:
Information you allow us to receive through device settings you turn on, such as access to your GPS location, camera, or photos.
A.1.5.5. Network and connections:
Information such as the name of your mobile operator or ISP, language, time zone, mobile phone number, IP address, connection speed, and in some cases, information about other devices that are nearby or on your network.
A.1.5.6. Cookie data:
Data from cookies stored on your device, including cookie IDs and settings.
A.2. How do we use this information?
A.2.1. Provide, personalize, and improve our SPF:
We use the information to monitor how you use and interact with our SPF in order to enhance & improve our services and features.
A.2.2. Location-related information:
We use location-related information such as your current location, where your business is residing, and the businesses you are in connection with through our SPF to monitor any risk or breach.
A.2.3. Product research and development:
We use the information we have to develop, test, and improve our SPF, including by conducting surveys and research, and testing and troubleshooting new products and features.
A.2.4. Face recognition:
If we introduce face-recognition technology to your SALVE FINANCIAL HUB experience, we will let you know first, and you will have control over whether we use this technology for you.
A. 2.5. Promote safety, integrity, and security:
We use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our SPF, and promote safety and security on and off SALVE FINANCIAL HUB.
A.2.6. Communicate with you:
We use the information we have to send you marketing communications, communicate with you about our SPF, and let you know about our policies and terms. We also use your information to respond to you when you contact us.
A.3. How is this information shared?
A.3.1. Public information can be seen with your permission by clients using SALVE FINANCIAL HUB or through APIs related to the related Banks or Authorities you are communicating with through SALVE FINANCIAL HUB.
A.3.2. New owner:
If the ownership or control of all or part of our SPF or their assets changes, we may transfer your information to the new owner.
A.3.3. Sharing with Third-Party Partners:
We work with third-party partners who help us provide and improve our SPF but we don’t sell any of your information to anyone, and we never will. We also impose strict restrictions on how our partners can use and disclose the data we provide.
A.3.4. Vendors and service providers:
We provide information and content to vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our SPFs are used, providing customer service, facilitating payments, or conducting surveys.
A.3.5. Legal Inquiries:
To keep our transparency and assist legal and regulatory entities in fraud monitoring and prevention; compliance with applicable laws & regulations; protecting our and other’s businesses against illegal activity; and performing audits; we may deliver your information upon inquiries and requests received by authorities.
B. Can I manage or delete information about me and my business?
Once our service is available, we will be able to provide you with access to rectify and erase your data as long as it complies with the legal banking regulations and “REGULATION OF PAYMENT SERVICES AND THE ISSUE OF ELECTRONIC MONEY (PAYMENT INSTITUTES AND IMEL)” enforced by the Central Bank of San Marino. You will be able to learn more about the regulations affecting you, in your SALVE FINANCIAL HUB Settings, once the service is made available.
C. How do we respond to legal requests or prevent harm?
We access, preserve, and share your information with regulators, law enforcement, or others:
In response to a legal request (like an AML auditing warrant, search warrant, or court order Subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the country where SALVE FINANCIAL HUB has been registered, once we have a good-faith belief that the response is required by law in that jurisdiction and is consistent with internationally recognized standards.
When we have a good-faith belief it is necessary to: detect, prevent, and address fraud, unauthorized use of our SPF, violations of our terms or policies, or other harmful or illegal activity; to protect ourselves, you, or others, including as part of investigations or regulatory inquiries; or to prevent death or imminent bodily harm. To comply with our ethics and remain transparent and accountable to the law, we also retain all information from closed or suspended accounts – although not visible to the public – to be available for any future legal claims, auditing warrants, or court orders.
D. How will we notify you of changes to this policy?
We’ll notify you before we make changes to this policy and allow you to review the revised policy before you choose to continue using our SPF.