Privacy Policy
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RIV Technologies FZE is committed to providing the highest level of protection regarding processing its clients' personal data based on applicable data protection laws and regulations. This Privacy Policy explains the policies and practices that RIV Technologies FZE, a company incorporated under the laws of UAE with headquarters in Office 613, Floor 03, The Offices 3 – One Central, Dubai World Trade Center ("RIV Technologies", "we" or "us") has developed and adopted to safeguard personal data and to comply with applicable data protection laws.
Personal data comprises all the information RIV Technologies collects and processes about you that can identify you directly or indirectly through our mobile app (the "App"), including information received from third parties.
Collection of Personal Information
RIV Technologies collects information directly from you when you create an account on our App, call or e-mail us, or otherwise provide information directly to us.
More specifically, the personal data RIV Technologies collects or processes about you may include:
(i) Identifying information: including your name, date of birth, place of birth, nationality, country of residence, country of tax domicile, passport number, residency permit details, tax identification details, passport details, and photo;
(ii) Our interactions with you: including any records of phone calls between you and RIV Technologies and logs of related information, including your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls;
(iii) Contact information: including postal address, telephone number, e-mail address, and mobile number;
(iv) Financial information: including information about your financial circumstances, details of personal assets, bank account numbers, spending, income, and credit bureau reports from relevant authorities;
(v) Professional information: including details of your employer, your education and career history, and business interests;
(vi) Derivative data: information our servers automatically collect when you access the App, such as your native actions that are integral to the App, including liking, re-blogging, or replying to a post, as well as other interactions with the App and other users via server log files;
(vii) Geo-location information: To provide location-based services, we may request access or permission to track location-based information from your mobile device, either continuously or while you are using the App. If you wish to change our access or permissions, you may do so in your device's settings;
(viii) Mobile device access: we may request access or permission to access certain features from your mobile device, including your mobile device's storage. If you wish to change our access or permissions, you may do so in your device's settings;
(ix) Mobile device data: Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide;
(x) Push notifications: we may send push notifications regarding your account or the App. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
We will only collect and use personal information necessary for the purposes for which it is to be used.
Use of Personal Information
By providing your personal data, you agree that, where it is permitted by local law or where you have agreed to receive these communications from us, we may use the information:
(i) to provide products and services, including effecting payments, transactions, and completing instructions or requests;
(ii) to conduct market research and surveys to improve our products and services;
(iii) to respond to your requests;
(iv) to improve our level of service;
(v) to improve the content of our communications;
(vi) to provide you with tips, helpful information, product news, and updates;
(vii) to notify you of our new products and services;
(viii) for marketing and promotion purposes, conducted with or without the support of third parties engaged by RIV Technologies;
(ix) to comply with applicable local or foreign law, regulation, policy, voluntary codes, directive, judgment, or court order, as well as any request by any authority, regulator (including the Dubai Virtual Assets Regulatory Authority) or enforcement agency or body;
(x) to comply with Know Your Customer and Anti-Money Laundering laws and regulations. More in detail, to provide fiat on-ramp and off-ramp services through third parties. In this regard, any customer data relevant for Know Your Customer and Anti-Money Laundering purposes may and will be shared with Mercuryo (https://mercuryo.io), our third-party on-off ramp provider, with other third parties as decided by Mercuryo, and with SUMSUB (https://sumsub.com), and more in general with any other provider that offers such types of services;
(xi) to establish, exercise, or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice concerning such legal proceedings;
(xii) to prevent, detect, investigate, and prosecute crime (including but not limited to money laundering, terrorism, fraud, and other financial crimes) in any jurisdiction, identity verification, government sanctions screening, and due diligence checks;
(xiii) for other purposes that may be detailed on the App.
Processing Principles
In using your personal data, we follow the following principles:
• Processing application forms for products and services, including assessing clients' suitability and performing necessary checks and risk assessments in connection with our non-custodial wallet support services for the purchase of tokens based on distributed ledger technologies ("DLT").
• RIV Technologies will only collect personal data about you that is necessary for one or more of our legitimate business purposes or is required by law. In addition, RIV Technologies will only collect personal data by lawful and fair means and not in an unreasonably intrusive manner.
• When RIV Technologies collects your personal data, we will take reasonable steps to advise you of what personal data we are collecting, the purposes for which we are collecting the information, and will use such information only for stated primary or related secondary purposes.
• RIV Technologies will advise you of the organizations (or types of organizations) to which we may normally disclose that personal data, and we will provide you with contact information in the event you would like access to your personal data we hold about you or need to update your personal data or preferences.
Disclosure of Personal Information
RIV Technologies may use third parties to provide services to us which may require disclosure of your personal data to such third parties. If we allow a third party to have access to your personal data, they will only be permitted access for purposes that are consistent with this Privacy Policy and will be required to protect your personal data in accordance with all applicable data protection laws.
We may disclose personal information to third-party service providers and IT providers to support our services or as part of client support services. These providers are contractually bound to protect the privacy and security of our clients' personal information and to comply with the laws and regulations of the United Arab Emirates. We will not disclose personal information to other third parties without obtaining the prior consent of the individual concerned, unless required or permitted by law.
In certain circumstances, we may be called upon to release your personal data in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal data that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in illegal or harmful behavior to individuals or the personal data we are responsible for.
Additionally, if you contact us regarding your experience using our App, we may use the information you provide in submitting complaint or adverse event reports.
Eventually, only with your consent, RIV Technologies may transfer personal data to third parties including the transfer of data from one country to another and may include transfers to a country where the laws provide different protection from your country. In such cases, we will take appropriate measures to ensure adequate data protection under applicable data protection laws such as the General Data Protection Regulation ("GDPR") and the laws and regulations of the United Arab Emirates. However, we will take steps to ensure that your personal information is treated securely and under this Privacy Policy and the laws and regulations of the United Arab Emirates.
Registration and Newsletter
To use our services, you must register and sign up for our newsletter. By registering and signing up, you agree to provide accurate and complete information about yourself, and to update such information if it changes. You also agree to receive e-mails and other communications from us regarding our services, including updates, promotions, and other information.
Monitoring
To the extent permitted by law, we may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
Your Rights
Subject to applicable law, you may be entitled to invoke a data subject's right in relation to your personal data being processed by RIV Technologies. The rights that you can invoke as a data subject may include:
1. Right of Access You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, ask us for copies of your personal information without charge. Please note that we may charge a reasonable fee based on administrative costs for any further copies requested or reject any additional requests that are reasonably deemed to be excessively repetitive.
2. Right to Rectification You have the right to obtain from RIV Technologies without undue delay the rectification of inaccurate personal data concerning you.
3. Right to Request Erasure Subject to compliance with the applicable mandatory retention periods, you have the right to request from RIV Technologies the erasure of personal data concerning you where (a) the personal data is no longer necessary for RIV Technologies' business operations (including offering you the financial services or products), (b) you withdraw your consent to the processing of your personal data, or (c) there is no other ground for the processing.
4. Right to Restriction of Processing You have the right to obtain from RIV Technologies restriction of processing where one of the following applies: (i) you contest the accuracy of your personal data (in such a case, the restriction will be for a period enabling RIV Technologies to verify the accuracy of said data); (ii) the processing is unlawful; (iii) you object that the processing is in violation of the agreed purpose(s) with RIV Technologies (in such a case, the restriction will be for a period enabling RIV Technologies to verify the agreed purpose(s) of the processing and whether RIV Technologies is in violation of said purpose(s)). You may request RIV Technologies to continue keeping your personal data after fulfillment of the processing purposes if such data is necessary for the establishment, exercise, or defense of legal proceedings. Notwithstanding the provisions of this clause 4, we may nevertheless proceed with processing your personal data without your consent if the processing is: (i) limited to storing personal data; (ii) necessary to initiate, defend, or claim rights in legal proceedings, or is related to judicial procedures; (iii) necessary to protect the rights of third parties in accordance with applicable law; or (iv) necessary to protect the public interest.
5. Right to Transfer Data You have the right to: (i) obtain your personal data in a machine-readable and automated manner where the processing is based on your consent or is necessary for the fulfillment of a contractual obligation; (ii) request the transfer of your personal data to another service provider whenever that is technically feasible.
6. Right to Object to the Processing You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you. RIV Technologies shall no longer process said personal data except where such personal data is required for business operations related to the App or services offered to you. Any future withdrawal of consent will not affect the lawfulness of personal data processing prior to such withdrawal or any subsequent processing related to RIV Technologies' business operations. Such right can be exercised when your personal data is processed for direct marketing purposes, for the purpose of conducting statistical surveys, or if the processing is in violation of your personal data rights in accordance with applicable law.
Security
The security and confidentiality of your personal data are important to us and RIV Technologies has invested significant resources to protect the safekeeping and confidentiality of your personal data. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure. When using external service providers acting as processors, we require that they adhere to the same standards as RIV Technologies.
Social Media
RIV Technologies operates channels, pages, and accounts on some social media sites to inform, assist, and engage with customers. RIV Technologies monitors and records comments and posts made on these channels about RIV Technologies to improve its products and services.
Please note that you must not communicate to RIV Technologies through such social media sites the following types of information:
(i) confidential personal data, including any information regarding your financial situation, bank account details, transactions, etc.; (ii) sensitive personal data, including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data to uniquely identify a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offenses and national identification number; (iii) excessive, inappropriate, offensive, or insulting information towards individuals.
RIV Technologies is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. RIV Technologies is only responsible for its own use of the personal data received through such sites.
Storage of Personal Information
Your personal data is archived on the company's own cloud services provided by DigitalOcean Holdings, Inc. We take reasonable steps to protect the personal information we hold from misuse, interference, and loss, as well as unauthorized access, modification, or disclosure. We will retain personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law.
Updates to this Privacy Policy
We will only use personal data in the manner described in the Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time (for example, due to changes in data protection laws) by posting revisions to this website. We will take adequate and reasonable action to obtain your consent if required, as a result of any such change.
Contact Us
If you have any questions or concerns about our Privacy Policy or to exercise your rights, please contact our Data Protection Officer at dpo@riv-technologies.com.
Personal data comprises all the information RIV Technologies collects and processes about you that can identify you directly or indirectly through our mobile app (the "App"), including information received from third parties.
Collection of Personal Information
RIV Technologies collects information directly from you when you create an account on our App, call or e-mail us, or otherwise provide information directly to us.
More specifically, the personal data RIV Technologies collects or processes about you may include:
(i) Identifying information: including your name, date of birth, place of birth, nationality, country of residence, country of tax domicile, passport number, residency permit details, tax identification details, passport details, and photo;
(ii) Our interactions with you: including any records of phone calls between you and RIV Technologies and logs of related information, including your phone number, time and date of calls and messages, duration of calls, routing information, and types of calls;
(iii) Contact information: including postal address, telephone number, e-mail address, and mobile number;
(iv) Financial information: including information about your financial circumstances, details of personal assets, bank account numbers, spending, income, and credit bureau reports from relevant authorities;
(v) Professional information: including details of your employer, your education and career history, and business interests;
(vi) Derivative data: information our servers automatically collect when you access the App, such as your native actions that are integral to the App, including liking, re-blogging, or replying to a post, as well as other interactions with the App and other users via server log files;
(vii) Geo-location information: To provide location-based services, we may request access or permission to track location-based information from your mobile device, either continuously or while you are using the App. If you wish to change our access or permissions, you may do so in your device's settings;
(viii) Mobile device access: we may request access or permission to access certain features from your mobile device, including your mobile device's storage. If you wish to change our access or permissions, you may do so in your device's settings;
(ix) Mobile device data: Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide;
(x) Push notifications: we may send push notifications regarding your account or the App. If you wish to opt out from receiving these types of communications, you may turn them off in your device's settings.
We will only collect and use personal information necessary for the purposes for which it is to be used.
Use of Personal Information
By providing your personal data, you agree that, where it is permitted by local law or where you have agreed to receive these communications from us, we may use the information:
(i) to provide products and services, including effecting payments, transactions, and completing instructions or requests;
(ii) to conduct market research and surveys to improve our products and services;
(iii) to respond to your requests;
(iv) to improve our level of service;
(v) to improve the content of our communications;
(vi) to provide you with tips, helpful information, product news, and updates;
(vii) to notify you of our new products and services;
(viii) for marketing and promotion purposes, conducted with or without the support of third parties engaged by RIV Technologies;
(ix) to comply with applicable local or foreign law, regulation, policy, voluntary codes, directive, judgment, or court order, as well as any request by any authority, regulator (including the Dubai Virtual Assets Regulatory Authority) or enforcement agency or body;
(x) to comply with Know Your Customer and Anti-Money Laundering laws and regulations. More in detail, to provide fiat on-ramp and off-ramp services through third parties. In this regard, any customer data relevant for Know Your Customer and Anti-Money Laundering purposes may and will be shared with Mercuryo (https://mercuryo.io), our third-party on-off ramp provider, with other third parties as decided by Mercuryo, and with SUMSUB (https://sumsub.com), and more in general with any other provider that offers such types of services;
(xi) to establish, exercise, or defend legal rights in connection with legal proceedings (including any prospective legal proceedings) and seeking professional or legal advice concerning such legal proceedings;
(xii) to prevent, detect, investigate, and prosecute crime (including but not limited to money laundering, terrorism, fraud, and other financial crimes) in any jurisdiction, identity verification, government sanctions screening, and due diligence checks;
(xiii) for other purposes that may be detailed on the App.
Processing Principles
In using your personal data, we follow the following principles:
• Processing application forms for products and services, including assessing clients' suitability and performing necessary checks and risk assessments in connection with our non-custodial wallet support services for the purchase of tokens based on distributed ledger technologies ("DLT").
• RIV Technologies will only collect personal data about you that is necessary for one or more of our legitimate business purposes or is required by law. In addition, RIV Technologies will only collect personal data by lawful and fair means and not in an unreasonably intrusive manner.
• When RIV Technologies collects your personal data, we will take reasonable steps to advise you of what personal data we are collecting, the purposes for which we are collecting the information, and will use such information only for stated primary or related secondary purposes.
• RIV Technologies will advise you of the organizations (or types of organizations) to which we may normally disclose that personal data, and we will provide you with contact information in the event you would like access to your personal data we hold about you or need to update your personal data or preferences.
Disclosure of Personal Information
RIV Technologies may use third parties to provide services to us which may require disclosure of your personal data to such third parties. If we allow a third party to have access to your personal data, they will only be permitted access for purposes that are consistent with this Privacy Policy and will be required to protect your personal data in accordance with all applicable data protection laws.
We may disclose personal information to third-party service providers and IT providers to support our services or as part of client support services. These providers are contractually bound to protect the privacy and security of our clients' personal information and to comply with the laws and regulations of the United Arab Emirates. We will not disclose personal information to other third parties without obtaining the prior consent of the individual concerned, unless required or permitted by law.
In certain circumstances, we may be called upon to release your personal data in response to a court order, subpoena, search warrant, law, or regulation. We plan to cooperate in responding to such requests, taking appropriate measures to ensure that the requester understands the sensitive nature of the personal data that they may receive. We also reserve the right to cooperate with law enforcement authorities in investigating and prosecuting users who violate our rules or engage in illegal or harmful behavior to individuals or the personal data we are responsible for.
Additionally, if you contact us regarding your experience using our App, we may use the information you provide in submitting complaint or adverse event reports.
Eventually, only with your consent, RIV Technologies may transfer personal data to third parties including the transfer of data from one country to another and may include transfers to a country where the laws provide different protection from your country. In such cases, we will take appropriate measures to ensure adequate data protection under applicable data protection laws such as the General Data Protection Regulation ("GDPR") and the laws and regulations of the United Arab Emirates. However, we will take steps to ensure that your personal information is treated securely and under this Privacy Policy and the laws and regulations of the United Arab Emirates.
Registration and Newsletter
To use our services, you must register and sign up for our newsletter. By registering and signing up, you agree to provide accurate and complete information about yourself, and to update such information if it changes. You also agree to receive e-mails and other communications from us regarding our services, including updates, promotions, and other information.
Monitoring
To the extent permitted by law, we may record and monitor your communications with us to ensure compliance with our legal and regulatory obligations and our internal policies. This may include the recording of telephone conversations.
Your Rights
Subject to applicable law, you may be entitled to invoke a data subject's right in relation to your personal data being processed by RIV Technologies. The rights that you can invoke as a data subject may include:
1. Right of Access You have the right to obtain from us confirmation as to whether or not personal data concerning you is being processed, and, where that is the case, ask us for copies of your personal information without charge. Please note that we may charge a reasonable fee based on administrative costs for any further copies requested or reject any additional requests that are reasonably deemed to be excessively repetitive.
2. Right to Rectification You have the right to obtain from RIV Technologies without undue delay the rectification of inaccurate personal data concerning you.
3. Right to Request Erasure Subject to compliance with the applicable mandatory retention periods, you have the right to request from RIV Technologies the erasure of personal data concerning you where (a) the personal data is no longer necessary for RIV Technologies' business operations (including offering you the financial services or products), (b) you withdraw your consent to the processing of your personal data, or (c) there is no other ground for the processing.
4. Right to Restriction of Processing You have the right to obtain from RIV Technologies restriction of processing where one of the following applies: (i) you contest the accuracy of your personal data (in such a case, the restriction will be for a period enabling RIV Technologies to verify the accuracy of said data); (ii) the processing is unlawful; (iii) you object that the processing is in violation of the agreed purpose(s) with RIV Technologies (in such a case, the restriction will be for a period enabling RIV Technologies to verify the agreed purpose(s) of the processing and whether RIV Technologies is in violation of said purpose(s)). You may request RIV Technologies to continue keeping your personal data after fulfillment of the processing purposes if such data is necessary for the establishment, exercise, or defense of legal proceedings. Notwithstanding the provisions of this clause 4, we may nevertheless proceed with processing your personal data without your consent if the processing is: (i) limited to storing personal data; (ii) necessary to initiate, defend, or claim rights in legal proceedings, or is related to judicial procedures; (iii) necessary to protect the rights of third parties in accordance with applicable law; or (iv) necessary to protect the public interest.
5. Right to Transfer Data You have the right to: (i) obtain your personal data in a machine-readable and automated manner where the processing is based on your consent or is necessary for the fulfillment of a contractual obligation; (ii) request the transfer of your personal data to another service provider whenever that is technically feasible.
6. Right to Object to the Processing You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning you. RIV Technologies shall no longer process said personal data except where such personal data is required for business operations related to the App or services offered to you. Any future withdrawal of consent will not affect the lawfulness of personal data processing prior to such withdrawal or any subsequent processing related to RIV Technologies' business operations. Such right can be exercised when your personal data is processed for direct marketing purposes, for the purpose of conducting statistical surveys, or if the processing is in violation of your personal data rights in accordance with applicable law.
Security
The security and confidentiality of your personal data are important to us and RIV Technologies has invested significant resources to protect the safekeeping and confidentiality of your personal data. Regardless of where your personal information is transferred or stored, we take all steps reasonably necessary to ensure that personal data is kept secure. When using external service providers acting as processors, we require that they adhere to the same standards as RIV Technologies.
Social Media
RIV Technologies operates channels, pages, and accounts on some social media sites to inform, assist, and engage with customers. RIV Technologies monitors and records comments and posts made on these channels about RIV Technologies to improve its products and services.
Please note that you must not communicate to RIV Technologies through such social media sites the following types of information:
(i) confidential personal data, including any information regarding your financial situation, bank account details, transactions, etc.; (ii) sensitive personal data, including (i) special categories of personal data meaning any information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and the processing of genetic data, biometric data to uniquely identify a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation and (ii) other sensitive personal data such as criminal convictions and offenses and national identification number; (iii) excessive, inappropriate, offensive, or insulting information towards individuals.
RIV Technologies is not responsible for any information posted on those sites other than the information posted by its employees on its behalf. RIV Technologies is only responsible for its own use of the personal data received through such sites.
Storage of Personal Information
Your personal data is archived on the company's own cloud services provided by DigitalOcean Holdings, Inc. We take reasonable steps to protect the personal information we hold from misuse, interference, and loss, as well as unauthorized access, modification, or disclosure. We will retain personal information only for as long as necessary to fulfill the purposes for which it was collected or as required by law.
Updates to this Privacy Policy
We will only use personal data in the manner described in the Privacy Policy in effect when the information was collected from you. However, we reserve the right to change the terms of this Privacy Policy at any time (for example, due to changes in data protection laws) by posting revisions to this website. We will take adequate and reasonable action to obtain your consent if required, as a result of any such change.
Contact Us
If you have any questions or concerns about our Privacy Policy or to exercise your rights, please contact our Data Protection Officer at dpo@riv-technologies.com.