Introduction
At SPENNX, your privacy is a top priority. We are deeply committed to protecting your personal data and using it responsibly. This Privacy Policy explains how we collect, use, store, and protect your personal data when you visit, use or download SPENNX Platform and/or other related services.
By creating an account in the SPENNX Platform and accepting the Terms & Conditions, you consent to SPENNX using, collecting, processing and storing your personal data necessary to provide you with the services of your choice. This Privacy Policy (the “Policy”) governs the collection, use, storage, and processing of your data.
This Policy applies to your use of all our services and products. Your personal information is stored in our business records only for as long as it is necessary to provide you with our services, and thereafter, only as required to comply with any applicable regulations.
Personal data shall mean any information relating to an individual who can be identified or is identifiable, directly or indirectly, based on that information. This may include names, contact details, identification number, location data, online identifiers or other characteristics specific to that individual.
We reserve the right to revise this Privacy Policy periodically to reflect changes in our practices, legal requirements, or service offerings. When we make significant changes, we will inform you through appropriate channels, such as email notifications or in-app alerts.
By continuing to use our products and services after any updates are made, you acknowledge and accept the revised Policy. If you do not agree with our policies or how your information is handled, you may choose to discontinue using our services.
Who We Are
SPENNX sp. z o.o. is a private limited liability company incorporated with KRS number 0000992289 with registered address at 73 Pańska Street, local 11, 00-834, Warsaw, Poland (hereinafter referred to as “SPENNX”).
For the purpose of how we use your personal data as you use the SPENNX Platform, products and services, in the ways described in this Policy, SPENNX is the data controller of your data. Personal information provided to, or collected by SpennX sp. z o.o.
SPENNX will at all times be available for data subjects to address any concerns or questions and/or allow them to exercise their rights under their local applicable data protection laws regarding their personal information.
Scope
This Policy governs all interactions with SPENNX website, SPENNX Platform, and any services offered through the SPENNX Platform. It applies to all visitors, users, and customers, including anyone who accesses or interacts with the SPENNX digital ecosystem.
The Policy outlines how we collect, use, share, and protect your personal data. It also extends to our partners and third-party service providers, who must comply with this Policy and the terms of our Data Processing Agreement (DPA) before they can access or process any of your information.
Data Processed
To deliver our services to you, we may collect your personal information that you provide to us while creating your SPENNX Account. The information we may collect about you will vary depending on how you interact and engage with us. Below, you can see the categories of personal data we may process to deliver our services:
- Personal identification information, such as name, date of birth, place of birth, nationality, gender, email, address, demographic information, and phone number. We may verify your address via utility bills or through an electronic address verification method.
- Supplemental identification information, such as government-issued identity documents, live photo images captured, passport, driver’s license, taxpayer identification number, source of income and employment information, including its status and history, Social Security Number, and Social Insurance Number (as applicable).
- Financial information, including but not limited to income/wealth verification documents or bank account statements.
- Credit references, credit analysis reports, where applicable.
- Information on your browser, IP address, device name and its unique identifier and type, software version, device language, timestamp, device time zone.
- Information on your behaviour on our website, including pages viewed, links clicked, keystrokes, and actions taken, including failure to verify the account or lack of transactions (dormant position), and customer activities carried out within the SPENNX Platform.
- Transaction information, including information related to the use of the SPENNX Platform, types of services requested, dates and times of such requests, payment methods, and other similar information.
- Location data, including user location searches.
- Communications data, including messages, comments, or file transmissions.
- Information about your internet connection, the equipment you use to access our resources, and usage details.
- Additional information required by SPENNX, in its sole discretion, to verify your identity, which may include capturing the image of your face in real time for facial recognition.
- Information related to beneficiaries to whom you may transfer funds.
We collect and further process this information when you download or use the SPENNX Platform, during the registration process, and when operating with your account. To comply with local laws, we may need to access some of your personal data from public sources, such as national identification authorities or credit reference bureaus, depending on your country of residence; by using the SPENNX Platform and its associated services, you expressly agree to such access.
Depending on your place of residence and the place of residence of account holders with whom you transact, your data may be shared or transferred to different third parties as it may be necessary for the provision of the used service or compliance with the laws of the relevant jurisdictions. In that case, we ensure the protection of your rights and that the application of, at least, the level of security we use for the processing is maintained by any third parties to whom we share or transfer your personal data.
Why we collect your data
We collect and use personal data only when we have one or more lawful grounds for doing so under applicable privacy laws. Such grounds may vary depending on where our users and/or customers are located, but generally include processing personal data:
- To provide our remittance services and features (e.g., sending/receiving funds).
- For the purpose of the legitimate interests of SPENNX or other parties.
- Comply with legal and regulatory obligations, including Anti-Money Laundering, Counter Terrorism Financing and Proliferation Financing Laws.
- Prevent fraud and maintain security.
- Improve and personalize your user experience.
- Respond to your inquiries and support requests.
- Perform audits, analysis, and reporting.
- With your consent.
We may also use cookies and similar technologies with your consent to understand usage patterns, improve services, and offer relevant marketing.
Purpose of the Processing
The reason we process your personal data is to enable you to use our services. We collect this data only when we have one or more lawful grounds for doing so under the applicable laws. Such grounds may vary depending on the place of residence of the user or beneficiary of our services.
We collect and process your data to:
- verify your identity, process and record your financial information;
- provide you with our remittance services and features, including but not limited to sending/receiving funds, issuing virtual cards, and processing transactions;
- realise transactions and maintain records of financial activity according to the applicable laws;
- ensure that transactions are performed smoothly, and provide troubleshooting services;
- improve and personalise your user experience, send non-marketing communications;
- provide services in collaboration with third-party service providers according to the contractual terms you have agreed to;
- respond to your inquiries and support requests;
- comply with legal and regulatory obligations, and respond to legitimate data requests issued by competent authorities, including those concerning Anti-Money Laundering, Counter Terrorism Financing and Proliferation Financing;
- prevent fraud, misrepresentations, errors, legal violations, and criminal activity, and maintain the security of our systems and those intertwined with ours; and
- perform and submit to mandatory audits, analysis, and reporting duties and industry best practices.
- We may also use cookies and similar technologies with your consent to understand usage patterns, improve services, and offer relevant information about our offerings.
- We also collect and process your transaction data according to our legitimate interest, especially to:
- ensure the security of our services, adhere to our internal procedures, and prevent fraud and other financial criminal activities;
- analyse the functionality of our services and the SPENNX Platform, and tailor them to your specific needs;
- send marketing communications; and
- perform statistical analyses.
Your rights regarding your data
We adhere to the requirements of all applicable data protection regulations and we will process any requests that stem from your rights (such as the right to access and rectify your data, right to be forgotten, right to data portability, right to object to automated decision making, right to restriction of data processing, right to refuse further data processing, right to information, and right to complain with the supervisory authority), in line with the corresponding laws and regulations we need to observe.
To exercise your rights (if applicable) and/or for any other questions about the handling of your personal information, please contact us at dpo@spennx.com
Sharing Information
We do not sell your personal data, nor do we share it with third parties for their direct marketing purposes without your explicit consent.
We may share your personal data with our trusted service providers, business partners, and affiliates solely to support the delivery of our services or perform data processing on our behalf. All such parties are required to comply fully with this Policy. Some of these third parties may be located outside your country of residence, and in such cases, your data may be subject to access by local authorities in those jurisdictions.
We may disclose your personal information to comply with legal obligations, respond to valid court orders, or protect our legal rights or those of others.
In the event of a company merger, acquisition, insolvency, receivership, or bankruptcy, your personal data may be transferred as part of the company’s assets.
Additionally, when another user enters your phone number for a transfer or request, your name may be visible to help confirm the identity of the recipient. This is to ensure the accuracy of transactions, as they are not reversible.
Data Retention and Deletion
We retain user profiles, transaction records, and personal information for as long as your account is active and, except as otherwise permitted or required by applicable law or regulation, only for as long as necessary to fulfil the purposes SPENNX collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.
In certain cases, we may retain specific information for safety, security, and fraud prevention purposes. For example, if a user account is deactivated due to misconduct or a security incident, we may keep information about that account to prevent that user from opening a new account in the future or to prevent further misuse.
You may request account deletion at any time. Upon receiving such a request, we will delete data not required for regulatory, tax, insurance, legal, or dispute resolution purposes. For instance, data such as location, device, and usage information may be retained for a minimum of five years for compliance and risk management.
If your account cannot be immediately deleted due to an outstanding balance or ongoing dispute, we will proceed with deletion once the issue is resolved. If you no longer want us to retain or use your personal data, or if you need to update or correct it, please contact us. We will make the necessary changes in accordance with applicable laws and our data management policies.
In some instances, we may anonymize your personal data so that it can no longer be linked to you. Once anonymized, this information may be used for legitimate business purposes without further notice or your consent. SPENNX reserves the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to the relevant user or its consent.
Data Security
We have implemented comprehensive security measures, technical, organizational, and procedural to safeguard your personal data from loss, unauthorized access, alteration, misuse, or disclosure. These measures include secure data encryption, strict access controls, regular security audits, and employee training on data protection best practices.
To further enhance data integrity, the transaction history on our SPENNX Platform is secured using blockchain technology. This ensures that all transactions are recorded in a transparent, tamper-proof manner, providing an immutable audit trail that reinforces trust and accountability in our systems.
Third-Party Links
The SPENNX Platform and our communications may contain links to websites operated by third parties. Please note that these external sites are not governed by this Policy. We strongly encourage you to review the privacy policies of any third-party sites you visit.
Phishing and Online Safety
Please stay alert to fraudulent emails, messages, or websites that may impersonate SPENNX. We will never request sensitive information (like your password or card details) via unsecured channels. If you suspect any suspicious communication, contact our customer support immediately.
Communication
By using our services, you consent to receive essential communications related to your account, transactions, or service updates via email, SMS, or phone.
We will only send you marketing communications if you have explicitly opted in. You may withdraw your consent to receive marketing messages at any time by contacting us through the channels provided.
If you have any questions regarding this Privacy Policy or our processing of personal data, or if you want to contact us regarding your data, please contact contact@spennx.com.
SPENNX sp. z o.o.
73 Panska Street, local 11,
00-834 Warsaw, Poland
E-mail: contact@spennx.com
We may update this Policy from time to time. Significant changes will be communicated to you through your preferred means of communication.
If you have questions about this Privacy Policy or how your data is handled, please reach out to our Data Protection Officer at dpo@spennx.com