Personal data collection:

Kyubex collects personally identifiable information about individuals, such as first name, last name, email address, phone number and other information voluntarily provided by users through the Website or Services. In addition, we may obtain publicly accessible data from third-party sources, such as public records or sources available online.

Purpose of processing:

We process users' personal data for the following purposes:

1. Providing our services and managing the user's account.
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2. Customise the user's experience and improve our services.
3. Communicate with users about services, updates and promotional offers.
4. Manage and process payments and transactions.
5. Prevent fraud and illegal activities.
6. Fulfill applicable legal and regulatory obligations.
7. Conduct market analysis and research to improve our services.

Sharing of personal data:

Kyubex may share personal data with third parties only for the following purposes:

1. Providing our services through technical service providers, IT security providers and other entities involved in the management of our services.
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2. To comply with legal obligations, governmental requests or in response to legal process.
3. For marketing and promotional purposes, subject to your prior consent.

Security of personal data

Kyubex takes technical and organisational security measures to protect your personal data from unauthorised access, loss or improper disclosure.

User Rights:

Users have the right to access, rectify, delete or restrict the processing of their personal data. They may also object to the processing or request data portability. To exercise these rights or for any other privacy-related request, users may contact us through the channels indicated in this Policy

Cookies and tracking technologies:

For more information on the use of cookies and tracking technologies, please see our Cookie Policy available on the Website.

Changes to the Privacy Policy:

We may make changes to this Privacy Policy. Users will be notified of relevant changes, and the last updated date will always be visible at the top of this page. In the event of any conflict between the English and other language versions of this Privacy Policy, the English version will prevail. If you have any questions about our privacy policy, please do not hesitate to contact us at . support@kyubex.com

Marketing Communications

1. Marketing e-mails
   In our marketing e-mails, we inform you about our offers on Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers). We may also ask you for your feedback or opinion via surveys. If you wish to receive marketing e-mails, you must provide us with your e-mail address. We will only send you marketing e-mails if you have expressly consented to this when opening your account, in accordance with the Data Protection Regulation. To ensure that we only send you the most relevant information in line with your personal interests, we will review and analyse your customer behaviour, including data on recent transactions, withdrawals, deposits, payments and invitations from friends. We will use this information to send you marketing emails, based on our legitimate interest within the meaning of Art. 6(1)(f) of the GDPR, to inform you about offers related to Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers), as well as related initiatives and to solicit your feedback or opinion via surveys. This data will only be used for sending marketing e-mails and will not be disclosed to third parties.
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2. Marketing push notifications
   In our marketing push notifications, we inform you about our offers on Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers). Push notifications are messages that you receive on your phone without a specific request and regardless of whether the App is open or not. We will only send you marketing push notifications if you have expressly given your consent when opening your account, in accordance with the Data Protection Regulation. To ensure that we only send you the most relevant information in line with your personal interests, we will review and analyse your customer behaviour, including data on recent transactions, withdrawals, deposits and invitations from friends. We will use this information to send you marketing push notifications, based on our legitimate interest within the meaning of Art. 6(1)(f) of the GDPR, to inform you about offers related to Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers), as well as related initiatives and to ask for your feedback or opinion via surveys.
3. Customer chat
   In our customer chat, we inform you about offers related to Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers), as well as related initiatives and to ask for your feedback or opinion via surveys. If you are in contact with a customer service agent, we will use your customer behaviour to send you marketing information via our customer chat, based on our legitimate interest within the meaning of Article 6(1)(f) of the GDPR.
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4. Email newsletter
   In our e-mail newsletter, we inform you about offers related to Kyubex financial products and services, their features and partnerships with third parties (discounts on third party products/services for Kyubex customers), as well as initiatives related to inviting friends. If you wish to receive the newsletter by e-mail, you must provide us with your e-mail address. We will only send you our newsletter if you have expressly given your consent when opening an account, in terms of the Data Protection Regulation. The processing of your data for sending our newsletter is based on your prior consent in accordance with Art. 6(1)(a) of the GDPR. You may revoke your consent to receive our newsletter by e-mail at any time. You can revoke your consent via a link in the newsletter e-mail.

For more information about our use of cookies and tracking technologies, please see our Cookie Policy available on the Website.

Your rights:

You have the following rights regarding your personal data:

1. Right to withdraw consent, pursuant to Article 7(3) of the GDPR: You have the right to withdraw your consent to the processing of your personal data at any time, with effect for the future. If you withdraw your consent, your personal data will no longer be processed, unless the further processing is based on a different legal basis (which excludes consent). The processing of your personal data continues to be justified until the date of your revocation.
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2. Right of access, pursuant to Art. 15 of the GDPR: This right enables you to request information about whether Kyubex is processing your personal data and about the particular processing of your personal data, at any time, together with a copy of the information processed. This right includes access to the document or obtaining copies of the documents.
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3. Right to rectification, pursuant to Art. 16 of the GDPR: You have the right to request rectification of your data if it is incomplete or inaccurate.
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4. Right to erasure, pursuant to GDPR art. 17: You have the right to request the deletion of your personal data if it is no longer necessary for the purposes for which it was originally collected or if you have noticed that it has been used unlawfully. Kyubex may refuse your request if the data is necessary to fulfil a legal obligation, for reasons of public interest or legal operations.
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5. Right to restrict processing, pursuant to Article 18 of the GDPR: You have the right to request the restriction of processing of your personal data when you contest the accuracy of your data, when you request the restriction of data because you believe the processing is unlawful or when the data is no longer necessary for the purposes for which it was collected, but Kyubex needs it for legal operations.
6. Right to object, pursuant to Art. 21 of the GDPR: This right allows you to object to the processing of your personal data at any time. This also includes profiling, if it is related to direct marketing purposes. If you object, your personal data will no longer be processed for this purpose. The processing of your personal data continues to be justified until the date of your objection.
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7. Data portability right, pursuant to Art. 20 of the GDPR: This right enables you to request Kyubex to provide your personal data in a structured, commonly used and machine-readable format, and to transmit your data to another data controller where the processing is based on consent or a contract and is carried out by automated means.
8. Right to lodge a complaint with a supervisory authority, pursuant to Art. 77 of the GDPR: You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data by Kyubex violates the GDPR.
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Exercising your rights of access, cancellation and objection to processing: You can exercise your rights of access, cancellation and objection to processing by using our web form. Please do not address requests via a third party platform that obliges us to respond to you via the same means, as we are unable to clearly identify you as a Kyubex customer. Instead, please use the above solutions to assert your rights before Kyubex. You can also exercise your right to object via our web form. Right to object to processing for direct marketing purposes, pursuant to Art. 21(2) of the GDPR: In some cases, we process your personal data for direct marketing purposes. You have the right to object to the processing of your personal data for direct marketing purposes at any time. This also applies to profiling, if it is related to direct marketing purposes. If you object to the processing of your personal data for direct marketing purposes, your personal data will no longer be processed for this purpose. The processing of your personal data continues to be justified until the date of your objection.

Deletion and retention periods:

We only store and process your personal data for as long as necessary to fulfil our obligations under the agreement with you or for as long as required by law. This means that if your data is no longer needed for legal or contractual obligations, it will be deleted. However, this rule does not apply in the case of limited processing necessary for the following purposes:

1. Compliance with regulatory and tax retention periods provided for by applicable laws and complementary legislation, including the following laws: Consolidated Banking Law, Anti-Money Laundering Law, Digital Administration Code, tax laws. Legal retention periods and documentation requirements include timeframes of up to twenty years. The applicable legal basis is Art. 17(3)(b) of the GDPR together with Art. 6(1)(c) of the GDPR.
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2. Preservation of supporting documents according to the timeframes provided for by law. According to the Italian Civil Code, these timeframes are generally between five and ten years, but in limited cases may extend longer. The applicable legal basis is Art. 17(3)(e) of the GDPR together with Art. 6(1)(f) of the GDPR.
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Furthermore, if your consent is the legal basis for the processing of your personal data, Kyubex will retain it until you revoke your consent or until your account is closed, whichever is later.