Privacy Policy

  1. 1. Our Privacy Policy
  1. 1.1. At Ein Fintech, we are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information. The terms set out should be read together with our Terms and Conditions.
  1. 1.2. By using the Service offered by Ein Fintech, you confirm that you accept the terms of this Privacy Policy and agree to be bound by them in your use of the Service. If you do not agree, please do not use the Service.
  1. 2. Data Controller (or Owner)
  1. 2.1. For the purposes of this Privacy Policy, the Data Controller is Vertendo s.r.l., via Simone Martini detto Memmi 22, Milano 20143
  1. 2.2.
  2. You may contact us at: [email protected]

  1. 3. Types of Data
  1. 3.1. Personal Data you give us
  1. 3.1.1. Ein collects the information you provide when you: correspond with us; fill in any forms; register to use the Ein platform; take part in online discussions, surveys or promotions; speak with a member of our customer support team; or contact us for other reasons.
  1. 3.1.2. Ein will, by itself or through third parties, may collect the following information: your name, address, and date of birth; your username, password and other registration information; your email address, phone number and details of the device you use (for example, your phone, computer or tablet); records of our discussions, if you contact us or we contact you; and any other information you provide to prove you are eligible to use our services.
  1. 3.2. Information we collect from other sources
  1. 3.2.1. Whenever you use our website or the Ein Platform, we collect the following information: information about your visit, including the links you have clicked on, through and from our site (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling and clicks), and methods used to browse away from the page; technical information, including the internet protocol (IP) address used to connect your computer to the internet, your log-in information, the browser type and version, the time-zone setting, the operating system and platform, the type of device you use, a unique device identifier (for example, your device identifier, number, or the mobile phone number used by the device), mobile network information.
  1. 3.2.2. In cases where, to provide our Service, personal data is to be collected from third parties who can be considered as autonomous data controllers, such as, for instance, likes on Facebook, Instagram, or Twitter put by the Users, we guarantee to process this Data exclusively for the fulfilment of contractual obligations related to our Service.
  1. 3.2.3. Other types of Personal Data collected may be described in other sections of this Privacy Policy.
  1. 3.2.4. Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.
  1. 3.3. Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
  1. 3.4. Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
  1. 3.5. Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
  2. 4. Mode and place of processing the Data
  1. 4.1. Methods of processing and data processor
  1. 4.1.1. The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Even where all precautions are adopted, we cannot guarantee complete security in all events.
  1. 4.1.2. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.
  1. 4.1.3. Google Cloud Services (GCS). GCS is an appointed Data Processor by Ein. GCS provides the processing service of the Data collected through the use of the Platform. The processing of data is carried out in respect of GCS Security Standards at all times. If personal data is transferred outside of the EEA, we always require that appropriate safeguards are in place to protect the information when it is processed.
  1. 4.2. Place
  1. 4.2.1. The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
  1. 4.2.2. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing such transferred Data, Users can check the section containing details about personal data processing.
  1. 4.2.3. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
  1. 4.2.4. If any such transfer occurs, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
  1. 4.3. Retention time
  1. 4.3.1. Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
  1. 4.3.2. Therefore:
    A) Personal Data collected for purposes related to a contract's performance between the Owner and the User shall be retained until such contract has been entirely performed.

    B) Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the Owner's legitimate interests within the relevant sections of this document or by contacting the Owner.
  1. 4.3.3. The Owner may be allowed to retain Personal Data for a more extended period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a more extended period whenever required to do so for the performance of a legal obligation or upon order of an authority.
  1. 4.3.4. Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the retention period's expiration.
  2. 5. Legal basis of processing
  1. 5.1. The Owner may process Personal Data relating to Users if one of the following applies:
    a) Users have given their consent for one or more specific purposes;

    b) Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

    c) Processing is necessary for compliance with a legal obligation to which the Owner is subject;

    d) Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

    e) Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
  1. 5.2. In any case, the Owner will gladly help clarify the specific legal basis that applies to the processing, mainly whether the provision of Personal Data is a statutory or contractual requirement or a requirement necessary to enter into a contract.


  1. 6. The purposes of processing
  1. 6.1. The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Contacting the User, Analytics and Managing data collection and online surveys.
  1. 6.2. Platform Services requires us to collaborate with various service providers (Issuers) to offer multiple options (Platform Products) for users to choose from. For each Platform Product offered on the Platform, each product's Issuer is the Data Controller, and GCS is our appointed Data Processor.
  1. 6.3. For each Platform Product you will be provided with the Issuer's Terms and Conditions, and Privacy Policy, before you are required to purchase any such products, and each Issuer will state the Data they need us to process if you buy any such products, in their Privacy Policy.
  2. 7. Other uses of the Data Collected
  1. 7.1. The Data we collect from Users are also used for the following purposes:
  1. 7.1.1. Registration. Through User registration or authentication, you give Ein your consent to be identified and access the Platform's services.
    Facebook Authentication (Facebook, Inc.). Facebook Authentication is a registration and authentication service provided by Facebook, Inc., related to the social network Facebook.
    Collected Data: Public Profile, Email, Friends, Date of Birth, Events, Location, likes and pictures, as specified in the Privacy Policy of Facebook.
  1. 7.1.2. Analytics. The services described in this section allow the Data Controller to control and analyze traffic data. The services also allow the tracking of the User's behaviour.
    Google Analytics Google Analytics is a web analysis service provided by Google LLC ("Google"). Google utilizes the Data collected to track and examine this application's use to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
    Data collected: different types of Personal Data, such as Usage Data, as specified in the Privacy Policy of Google.
  1. 7.1.3. Email and Contact Management. These services allow the managing of email contacts and other contacts used to communicate with the User. The services may also enable the collection of data concerning the date and time of display of the User's message.
    Sendgrid is an email management and storage service provided by Sendgrid.
    Data collected: Email, as specified in the Privacy Policy of Sendgrid.
    Typeform allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys to collect, save and reuse Data from any responding Users.
    The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form. These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
    Typeform (TYPEFORM S.L)
    Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
    Personal Data processed: email address.
    Place of processing: Spain – Privacy Policy.
  1. 7.1.4. Newsletter. By registering on the mailing list or for the newsletter, the User's email address will be added to the contact list of those who may receive email messages containing commercial or promotional information concerning this Application. Your email address might also be added to this list due to signing up for this Application or after making a purchase.
    Data collected: Email and Name.
  1. 7.1.5. Advertising. This type of services allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
    AdWords is a remarketing and behavioural targeting tool to advertise across websites provided by Google, Inc.
    Collected Data: Usage Data and various types of Data, as specified in the Privacy Policy of Google.
    Facebook Conversion is a tracking tool for ads on the social network Facebook provided by Facebook, Inc.
    Collected Data: Usage Data and various types of Data, as specified in the Privacy Policy of Facebook.
  2. 8. The rights of Users
  1. 8.1. Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
    a) Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to their Personal Data processing.
    b) Object to processing of their Data. Users have the right to object to their data processing if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
    c) Access their Data. Users have the right to learn if the Owner is processing data, obtaining disclosure regarding certain aspects of the processing, and obtaining a copy of the Data undergoing processing.
    d) Verify and seek rectification. Users have the right to verify their data's accuracy and ask for it to be updated or corrected.
    e) Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
    f) Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
    g) Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable. The data is processed by automated means and that the processing is based on the User's consent, on a contract that the User is part of or on pre-contractual obligations thereof.
    h) complain. Users have the right to bring a claim before their competent data protection authority.
  1. 8.2. Details about the right to object to processing
  1. 8.2.1. Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner. Users may object to such processing by providing a ground related to their particular situation to justify the objection.
  1. 8.2.2. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. Users may refer to this document's relevant sections to learn whether the Owner is processing Personal Data for direct marketing purposes.
  2. 9. How to exercise these rights
  1. 9.1. Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and addressed by the Owner as early as possible and always within one month.
  2. 10. Legal Action
  1. 10.1. Your Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of this App or related services.
  1. 10.2. You acknowledge to be aware that the Data Controller may be required to reveal personal data upon request of public authorities.
  2. 11. Additional information about User's Personal Data
  1. 11.1. In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
  2. 12. Information not contained in this policy
  1. 12.1. More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
  1. 13. Changes to this privacy policy
  1. 13.1. The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
  1. 13.2. Should the changes affect processing activities performed based on the User's consent, the Owner shall collect new consent from the User, where required.

Definitions:

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the information on the path followed within the Application with particular reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The Service provided by this Application as described in the relative terms and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables tracking users, for example, by accessing or storing information on the User's device.

Legal information

This privacy statement has been prepared based on multiple legislation provisions, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to this Application, if not stated otherwise within this document.