Privacy Policy

Privacy policy, Data usage and storage policy,

1. Information about us

The activities related to the collection, processing and storage of users ' personal information carried out by the Stacle group of companies (hereinafter referred to as Stacle) are governed by This document. Stacle has control over all information that we need in order to conduct our business ( including Information about our service and the services we offer to you).

For the purposes of this document, “We“,” us “or” our " means Stacle. Our company is registered at the address 6.20 World Trade Center, 6 Bayside Road, Gibraltar, postal code GX11 1AA and our private email address [email protected]. It is our principle to respect and adherence the rights of everyone to privacy and to protect their personal data. In this document, you can learn about the process of collecting and using personal information that we hold in connection with our business. For the purposes of this document, "Personal information" means information about an individual whose identity can be established in accordance with this information, or in combination with other information. This privacy statement may be subject to changes from time to time, and you will be notified and will be able to view the new document on our website. You can find out how we work with your personal information and control the process of its processing through our website.To learn more about our use of cookies, please read the Cookie Policy.

2. Information We Process

Your personal information will be collected and processed by us throughout our relationship with you. Our collection and processing of your personal information is limited to collecting and processing only the information that we need for certain purposes set out in this document.

Personal information includes:

  1. Personal information about you (first name, last name, date of birth, address, contacts);
  2. Financial information, including information about accounts and transactions, as well as the history of financial transactions;
  3. Products and services that we offer to you;
  4. Visual information (copies of passports or biometric images of the person in real time, etc.);
  5. Information about your activity on our website and other social networks, including information provided by you during registration, information about your Smart device, your geolocation, authentication security online and mobile applications, your search queries and websites you visit and so on.

In addition, we may request certain categories of information from you that we need in order to comply with financial security laws and ensure that our services are available to other customers.Privacy, Data Use and Retention Policy.

Certain types of personal information will be collected and processed by us only with your consent or, if we have the right to do so, in accordance with the law. Such information may include information related to the physical and psychological characteristics of the person, as well as biometric information about him, fingerprint, and so on.

This information is intended to prevent fraud and money laundering activities. We also have the right, within the limits of the law, to collect and process information about your criminal record and whether you are under investigation. This information is provided for the purposes of law enforcement and audits, and includes data on investigated and suspected financial crimes, including fraud, as well as information exchange with law enforcement and tax authorities.

3. The process of obtaining information

Personal information includes all information about your identity and your finances, as well as about your business (its owners, officers, beneficiaries, and transactions). We receive this information:

  1. From you, at the time of your registration or at our request;
  2. From third parties (other Stacle group companies, companies that you or we use, credit history, government agencies;
  3. Other financial institutions, to the extent permitted by law;
  4. Based on your use of our services (transactions with your accounts opened with us);
  5. From the device that you use to access our services (your geolocation data, phone number, image recognition, etc);
  6. Based on data collected from first-party and third-party cookies when you access our services, you will find more information in our Cookie policy; and
  7. From media sources and other publicly available sources (magazines, Newspapers, the register of voters, the register of legal entities, online search engines).

4. Your rights

It is important for us that you are aware of your rights with regard to the processing of your personal information.

Your rights and the cases in which you can use them are listed in table A. If you have not found an answer to questions about the use of your personal information here, or you intend to exercise your rights in relation to your personal information, or you want to leave a complaint with the data protection service, you can contact us at the email address [email protected]. If you do not accept our terms of collection, processing and use of your personal information, we will not be able to provide our services to you in any other way through the Stacle app.

You can send us an email [email protected] request to delete your personal information held by us if you stop using our services and close your account. However, Stacle will only satisfy your request based on the active use of your card, as the legislation on combating money laundering and terrorist financing requires to keep information about recent transactions with the account until a certain time.

5. Changes to how personal information is used

We may make changes to the way we use your personal information. Where this does not explicitly follow from the circumstances, you will be notified of such changes 30 days prior to their entry into force, from the time of notification until the date of entry into force of the changes, you can make any comments about this. Please note that your disapproval of any changes may cause us to no longer be able to provide our services to you through the Stacle app.

6. Ways to use and share your information with other Stacle group companies

We use and share your personal information strictly in accordance with the law. In addition, we may share your information with other Stacle companies for processing. It is important for us that you have a prior understanding of how we use your information, so we have set out in detail the purposes of using your information in the table - processing purposes.

7. Exchange of information with third parties

Usually we will not provide your information to anyone except the companies of the group Stacle, except for the following:

  1. You have given your consent;
  2. There is a need to provide their goods or services;
  3. This requires from us law enforcement, court, tax authorities, other state structures, or the law;
  4. If you need to return the funds to your account in error (unjust enrichment);
  5. If this information is necessary for the third parties, including our agents, subcontractors and other persons acting on our behalf for market analysis, benchmarking and correspondent banking services;
  6. If we have reasonable grounds to believe that you are a victim of an alleged financial crime or that the funds deposited in your account were obtained through criminal means, we may provide information about you to other financial institutions;
  7. this is required by the debt collection Agency;
  8. at the request of fraud prevention agencies or for credit history;
  9. at the request of any company that provides you with services or benefits ( insurance coverage, etc.);
  10. In case of need caused by the sale, reorganization, transfer, financing agreements or other transactions with the Namibia business or assets;
  11. For statistics or other data, but only in anonymous form;
  12. If necessary, called safeguarding our legitimate interests, the interests of third parties, for the purposes permitted by law and without prejudice to the purposes listed below.

Upon your request, we will transfer your information to a third party that provides you with account information or payment services. If a third-party provider, at your request, provides you with account information and payment services, you must understand that this third-party provider will have access to your personal information located in your account. The use and confidentiality of your information that you provide to third-party providers is governed by your agreement with them and their privacy policy.we are not responsible for the use of your personal information by third parties with your permission. If your account is used by other users who are authorized on our site, we may provide them with information about the use of this account by its original authorized user.

Please note that Stacle does not use or transmit your information for its own marketing purposes unless It has your consent to do so.

8. Transfer of information abroad

Your personal information may be transferred or collected by companies that are located outside of the territory of this jurisdiction. At the same time, we are confident that those institutions abroad where we transfer your information will treat it with the same degree of confidentiality as we do, and as required by applicable law. We share your personal information only to countries within the European economic area (which includes European Union countries plus Iceland, Liechtenstein and Norway) and in the following state:

  1. With the approval from the European Commission that this state or organization located within it will be properly to protect your information;
  2. The data protection Authority has given its permission to transfer your information to this state;
  3. With which we have an agreement (based on the model provisions proposed by the European Commission) that they will ensure the security of your information.

9. Marketing information

You will receive information from us from time to time about marketing updates, as you are a user of Stacle services. Marketing information includes information about products and services that we or other Stacle group companies provide that we believe may be useful to you. We provide this information by post or electronic communication (SMS, e-mail, etc.). You may opt out of sending marketing information by:

  • clicking the "Unsubscribe" button in any email that we have sent you for the purpose of a marketing alert;
  • write "stop" in any text marketing message that we have sent to you;
  • contact us at: [email protected].

10. Messages about your account

Messages about how your account works, as well as information about how we process your information, will be sent to you via email, text messages, and in-app notifications. Please let us know your current contact details and let us know if you have changed them. We may track and record any messages sent to us, to the extent permitted by law, for the purposes set out in Appendix I a-processing purposes.

11. Retention period of your information

By using our services and products, you acknowledge that we store records containing personal information about you. Such records may include customer accounts, as well as records of transactions with the account. As a rule, records are stored in electronic form, but they can also be stored on physical media. We use these records in order to improve our service and comply with the requirements of the law and any legal acts of the applicable law.

In addition, we use records as evidence that we are performing our duties. The speed of storing this or that information depends on its nature and other circumstances ( type of product, service, country of location, etc.).

The Stacle group of companies generally keeps records of customer accounts for six years after your use of Stacle services ends. Depending on business practices, legal or legal requirements, the retention period may be changed or canceled altogether if the information has a reduced risk. If you have not made any transactions using Stacle within six (6) months of opening your account, we may delete your account and data about You. We will keep records of your transactions until you send us a request to delete them, or they will be kept by us for the period established by law. In certain circumstances, we will retain information about you for longer than the prescribed period, especially when required by a court order or law enforcement agencies, or our other regulatory authorities in order to provide written evidence, if necessary. For more information about how we store and use your information, please contact: [email protected]

Appendix I – Your Rights

Rights Description

Access – you have the right to view your personal information that is available to us.

To get an extract of what information about you is in our possession, contact: [email protected] to get information about how to access information and documents about you that we need to submit to you, write [email protected]. Access to this information is only granted to the account holder, so you must provide us with proof of your identity and fill out a form to send us a request.

Correction-you have the right to correct errors and inaccuracies found in your personal information, as well as to update incomplete information about you.

If you find that the information you have provided to us about you contains any errors or inaccuracies, you have the right to request that we stop using it and correct the errors.

However, if the processing of your information is restricted due to your request, you may not be able to use Stacle services for a while, as your account will be suspended. For more information about your right to correct information errors, please contact us at: [email protected]. The right to correct errors and add-ons is granted only to the account owner, so you must provide us with proof of your identity, as well as fill out the form to send us a request.

Deletion - you may request that we destroy your personal information that we hold.

You have the right to request that we delete your personal information that we hold in the following cases:

  1. If the need to process your information has ceased, because the purposes for which it was requested have been suspended;
  2. We process your information in accordance with your permission, but we want to withdraw such agreement;
  3. Our Processing of your information is contrary to the law.

However, please keep in mind that deleting any information contained by us may cause us to suspend your account and other services of our company. For more information about your right to delete, please contact us at: [email protected]. The right to delete information is granted only to the account owner, so you must provide us with proof of your identity, as well as fill out the form to send us a request.

Limitation – you have a right to limit a processing of your private information by us.

You may request that we restrict the processing of your personal information in the following cases:

  1. The Information we hold about you is inaccurate;
  2. You no longer need to process this information because the purposes for which it was requested are no longer relevant, but you need this information to protect your legal rights;
  3. The Information we process is used illegally.

However, please keep in mind that restricting the processing of any information held by us may result in us being forced to suspend your account and other services of our company. For more information about your right to restrict the processing of information, please contact us at: [email protected]. The right to restrict the processing of information is granted only to the account holder, so you must provide us with proof of your identity, as well as fill out the form to send us a request.

Transfer-you have the right to transfer your information to the third party.

You have the right to receive your personal information, which is in our possession in a portable format, if you have given us permission to process your personal information, at our request, for the purpose of entering into an agreement with us. At your request, we may transfer your information directly to a third party if it is technically possible to do so. At the same time, please note that we are not responsible for ensuring the safety and security of your information that you have provided to third parties, as their use is governed by the agreement between you and this third party, as well as their own data privacy policy. You can obtain from us a copy of your personal information that is in our possession by contacting us email us at [email protected].

Objections - you have the right to object to the processing of your information.

If we do not have any arguments or grounds for processing your personal information and the processing of your information is not related to the investigation and protection of us and others from legal actions, you have the right to object to the processing of your personal information. Based on your request, we may restrict or stop processing your personal information, as well as delete it, depending on the circumstances.

However, please keep in mind that restricting the processing of any information held by us may result in us being forced to suspend your account and other services of our company.

Marketing - you have the right to make claims against direct marketing.

Revoke consent – you have the right to reject your permission.

If we need your permission to process your personal information, you have the right to reject your prior consent at any time. You will be informed of all our operations, and your permission is required.