Introduction
Snowball Studio Ltd. as owner and operator of the Liquiditas Platform (hereafter referred to as the “Company”, “we” or “us), will act as the Data Controller in processing your personal data and/or personal data relating to individuals connected to your business in accordance with the Data Protection Act, Chapter 586 of the laws of Malta and which implements and further specifies the relevant provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, better known as the General Data Protection Regulation (hereafter referred to as the “Regulation” or “GDPR”).
“You” or “your” shall mean you, any client of Snowball Studio Ltd. and any authorised person to operate the business relationship with Snowball Studio Ltd. or deal with us on your behalf.
This privacy policy (the “Policy”) explains how we collect, retain, process, share and transfer personal data about you and individuals connected to your business, and your respective rights under the Regulation.
Information we collect
The information collected by Snowball Studio Ltd. includes information that you provide to us, information that we generate about you and information collected from other sources.
When you enter into a business relationship with Liquiditas., we will collect Personal Data as necessary to offer and fulfil the products and services you request. Depending on the product or service you request, we require you to provide us with your personal details or personal data relating to individuals connected to your business, including:
name, gender, date and place of birth; contact details such as address, email address, landline and mobile numbers; and information concerning your identity such as photo ID, passport information, National Insurance number, Tax identification number, National ID card, tax residency and nationality.
The information that Snowball Studio Ltd. generates about you include:
- your financial information, your account(s) number(s) and history, transactions records, payments into your account including Company details;
- information we use to identify and authenticate you and individuals connected to your business;
- your credit risk rating and transactional behaviour;
- due diligence checks, sanctions and anti-money laundering checks and information that we need to support our regulatory obligations for the detection of any suspicious and unusual activity;
- records of correspondence and other communications with you, including emails.
- Other sources of information collected from third parties include information received from Credit Reference Agencies, the Central Credit Register by the Central Bank of Malta, other reference databases and any publicly available sources of information.
Purpose and legal basis for processing your personal data
The Company uses your information for the following purposes:
- The provision of our service to you, including the access to the online portal through which we will manage the services being offered to you;
- The Company will process your information which is necessary for the performance of an agreement to which you are a party or in order to take steps at your request to entering into an agreement;
- The prevention and detection of crime including, fraud, tax evasion, terrorist financing and money laundering through our ongoing monitoring, mitigation and risk management, customer due diligence, name screening, transaction screening and customer risk assessments. This processing is necessary for compliance with legal obligations to which the Company is subject and for the purpose of the Company’s legitimate interest.
- Credit risk management – The Company has a legitimate interest in conducting a risk assessment prior to providing credit and on an ongoing basis thereafter;
- The protection of the Company’s legal rights and interests such as debt collection, enforcing or protecting the Company’s assets; court action; managing complaints or disputes. The Company has a legitimate interest to take action against you or other persons, in the case of joint borrowers or persons who give a guarantee or other security for your obligations to the Company.
- Marketing – For the Company to use your information to provide you with information about its products and services, and also products and services from other relevant third parties. The Company will always make sure that it obtains your consent before processing your information for marketing purposes. Furthermore, you will be granted the option to withdraw your consent for the processing of your information for marketing purposes at any time.
Disclosure of your personal data
The Company will share your information with others where it is lawful to do so including where the Company or any third party:
- needs it in order to provide you with the product or service;
- has a public or legal obligation to do so for the detection and prevention of fraud, tax evasion and financial crime;
- in connection with regulatory reporting, litigation or asserting or defending its legal rights and interests;
- under a legitimate interest to manage risk, including financial crime risk, verify your identity; or has obtained your consent to share it.
Specifically, the Company may share your information for the above purposes with others including:
- credit reference agencies and debt recovery agents;
- law enforcement, government, tax authorities, courts, dispute resolution bodies, our regulators, auditors and any party appointed or requested by our regulators to carry out investigations or audits of our activities;
- the Central Bank of Malta in order to update the Central Credit Register maintained by the Central Bank of Malta;
- other third parties involved in any disputes, including disputed transactions;
- fraud prevention agencies who will also use it to detect and prevent fraud and other financial crime and to verify your identity;
- anyone who you provided instructions or power of attorney or operates any of your accounts or service on your behalf.
Retention of information
In accordance with the Company’s Data Retention Policy, your personal data will be retained for a period of five years from the end of our business relationship or for a longer period when required by a competent authority. Your account and transaction data will be retained by the Company for a period of ten years to comply with fiscal legal requirements.
Your rights
You have a number of rights in relation to the personal data that the Company holds about you. These rights include:
- the right to access information the Company holds about you and to obtain information about how the Company processes it;
- the right to withdraw at any time your consent without affecting the lawfulness of processing based on such consent before its withdrawal;
- where applicable, the right to receive certain information you have provided to the Company in an electronic format and/or request the Company to transmit it to a third party;
- the right to request the Company to rectify your information if it is inaccurate or incomplete;
- the right to request in certain circumstances the Company to erase your personal data, unless this is necessary for compliance with a legal obligation to which the Company is subject to or for the establishment, exercise or defense of a legal claim;
- in certain circumstances the right to obtain from the Company restriction to your personal data; and
- the right to object at any time to processing of your personal data for direct marketing purposes and to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similar significant effects to you, unless such decision is necessary for entering into, or performance of the agreement between you and the Company.
You can exercise your rights at any time by contacting us directly.
Likewise, if you have any questions about this Privacy Policy or our data protection practices, please contact our Data Protection Officer.
Cookies
Cookies are small text files that are stored on your device, sent from the website you visit, and our website uses them to enable the basic operation of the site, but also to improve your experience while using it. Snowball Studio Limited, as the owner of Liquiditas, respects your privacy and protects your personal data in accordance with the General Data Protection Regulation 2016/679 of the European Union. Cookies are used in accordance with all positive legal regulations and they are a legal instrument in the processing of information through a filter for privacy security when using websites.
Carefully read this Policy which describes the types of cookies we use on the website to be informed of all the details about the use of cookies, as well as the information and data used for various purposes.
Cookies perform essential functions on the web and some of them are necessary for the functioning of the website, while others refer to the adjustment of the content of the website, such as review of statistics on website, visits or targeted advertising, etc.
Types of cookies we use:
- Basic cookies – these cookies provide improved functionality and personalization capabilities;
- Operational cookies – enable proper display of the website and its features. These cookies are mandatory because they are essential for the proper presentation of the contents of the website. They are posted by us (website name) or by third parties whose services are included on our pages;
- Analytical cookies – these cookies allow us to understand how people use our site or how well it performs its functions. The information we receive is anonymous and aggregated;
- Marketing cookies – allow us to publish our announcements, on our pages or on other web pages and social networks in a way that is tailored to your interests considering your previous visit to our website.
Our website usually uses first-party cookies and persistent cookies that are controlled by us and save the search when the user turns off the browser to maintain the status. These cookies enable the basic operation of the website and are all necessary to continue using our website, as well as additional cookies that you can choose to turn on or off, with a description as previously stated.
The use of indirect cookies or third-party cookies is possible to obtain standard access information and visitor behavior details without identifying the visitors to our website.
The information contained in the cookies is not used for personal identification.
You can delete all cookies that are already on your device, and you can customize most browsers to prevent cookies. If you do this, you may need to manually adjust your preferences each time you visit a website, and some services and functionality may also not work.
Most of the websites provide user control over the placement and approval of the types of cookies, except the essential cookies. If you decide to customize the cookies and disable their functionality it is possible to change the functionality of the website and your user experience. Also depending on the browser settings, if you disable the essential cookies, you may not have access to the website.
Complaints
You have also the right to raise complaints or concerns about the Company’s use or processing of your personal information with the body regulating data protection in your country. In Malta, this is the Office of the Information and Data Protection Commissioner (details are available at https://idpc.org.mt/raise-a-concern/
How we keep your personal data secure
We store your personal information on secure servers that are managed by us and maintained by our service providers. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.