Last update: 01-April-2021

NOTICE:

We are aware of the judgment of the Court of Justice of the European Union from the 16th of July 2020. We are currently investigating the implications of the case for the transfer of personal data to the United States of America. We value your privacy dearly and we will do our utmost to find a suitable solution. When the dust has cleared regarding the judgment and when we have found a suitable solution, we will inform you. In the meantime, if you have any questions, please don’t hesitate and contact us at [email protected].

1. Introduction

At Apochi.com, we really care about your privacy. This means we will never sell or rent your personal data to third parties without your permission. In this Privacy & Cookie Statement, you can read what data we collect and how we use it.

The data controller for the processing of your personal data is Apochi B.V., registered at the Dutch Chamber of Commerce KvK-number 57893446. Our address is John Fernhouthof 16, 1087ED Amsterdam, The Netherlands.

To make sure Apochi.com only processes personal data in line with the relevant laws and regulations, Apochi.com has appointed a Data Protection Officer (DPO). If you have any questions about the processing of personal data after reading our Privacy & Cookie Statement, you can contact our DPO via [email protected] . If you want to cancel your Apochi.com account or have any other questions about your Apochi.com account, please contact our support via [email protected].

2. What data does Apochi.com collect

By using Apochi.com, we can collect and process the following personal data:

Personal information: First- and last name; date, country, and place of birth; nationality; gender
Contact and address details: Residential address; telephone number; email address
Device data (such as type of device, operating system, IP-addresses and advertising ID’s);
Cookies and usage data on how you use our products and services;
Correspondence with Apochi.com and support data (telephone, chat conversations, and email);
Additional documentation related;

Use of the app, websites, and other services

While using our app, websites, and other services, we can collect and use the following personal data:

Uploaded images/content;
Device data of added devices and API keys;
Added aliases (telephone numbers and email addresses);
Financial and banking data, product subscriptions, and transaction history;
Cookies and usage data on how you use our products and services;
Marketing data (statistics related to our marketing campaigns and data to measure this);
Correspondence with Apochi.com and support data (telephone, chat conversations, and email);
Activity on Apochi.com Together.

3. What is the lawful basis for the processing of my personal data?

Apochi.com processes your personal data in accordance with the relevant laws and regulations based on several legal grounds.

Legal requirements

We process your personal data to comply with our legal obligations, for example, to verify your identity and to be able to share certain data with governmental institutions.

Contract performance

To keep our agreement with you and to provide our services in a well and secure manner, we process your personal data. For example, we need your contact information to keep you informed about relevant developments, and we store correspondence data to improve our customer service.

Consent

Because we value your privacy and we want you to have a choice, we will ask for your explicit consent for various features.

Legitimate interests

We can also process certain data when we have a legitimate interest to do so, for example, to prevent and combat misuse, fraud, and crimes, to analyses the use of our products and services for the purpose of improving them, for information and system security purposes or for offering you a better user experience.

4. For what purposes does Apochi.com use my personal data?

We use your personal data to:

Comply with our legal obligations;
Execute agreements with our users, for example for processing payments, production of Apochi.com cards, securing Apochi.com accounts, identification purposes, and customer support;
Learn more about the use of our products and services so we can improve them;
Carry out and personalize (targeted) marketing activities through different channels and measure their effectiveness, based on your personal circumstances and use of our products and services;
Conduct analyses for statistical, strategic, and scientific purposes;
Prevent and combat misuse, fraud, and crimes;
Ensure the safety and integrity of the financial sector, Apochi.com, and our users;
Training and coaching purposes;
Improve our current and future products.

5. Does Apochi.com share my personal data with third parties?

To be able to provide our services, we share certain personal data with third parties. We keep the sharing to a minimum and ensure that these third parties will handle your personal data with the same care as we do. This means, among other things, that we sign Data Processing Agreements and that we use the standard contractual clauses adopted by the European Commission for personal data protection.

We may share your information:

To companies within our corporate family and our corporate affiliates who have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Statement.
With third-party vendors who provide services or functions on our behalf, including credit card processing, business analytics, customer service, marketing, distribution of surveys or sweepstake programs, and fraud prevention. We may also authorize third-party vendors to collect information on our behalf, including as necessary to operate features of the Site or to facilitate the delivery of online advertising tailored to your interests. Third-party vendors have access to and may collect information only as needed to perform their functions and are not permitted to share or use the information for any other purpose. They are also required to follow the same data security practices that we adhere to.
When we believe it is appropriate to investigate, prevent or take action regarding illegal or suspected illegal activities; or to protect and defend the rights, property, or safety of our company, the Site, our
In connection with a corporate transaction, such as a divestiture, merger, consolidation or asset sale, or in the unlikely event of bankruptcy.
With your consent.

Other than as set forth above, you will be notified when personal information about you will be shared with third parties, and you will have an opportunity to choose not to have us share such information.

We also may share aggregate or anonymous information with third parties, including advertisers and investors. This information does not contain any personal information and is used to develop content and services we hope you will find of interest.

Some third parties are located mainly in the EU. A data processing agreement has been signed with each of them. If they are located outside the EU, the standard contractual clauses provided by the European Commission have been signed.

Governmental institutions

To comply with laws and regulations we can share data with the concerned institutions. For example, the Tax Authorities can request financial data and we can share data with the Dutch Central Bank for participating in the Deposit Guarantee Scheme. Next to this, Apochi.com can have a statutory or legal obligation to share personal data with investigating authorities to prevent and combat misuse, fraud, and crimes.

To help protect the banking system and to assist you in filing your tax returns, we also share your tax information number and the description of your sub-accounts with the Tax Authorities.

6. How long does Apochi.com store my data?

We only keep your data for the time necessary to fulfill the purpose of collection. We are legally obliged to retain certain data for a minimum of 7 to 10 years after ending the customer relationship.

We are able to store personal data for longer periods with a valid legal ground, or when the data is sufficiently (for example) pseudonymized or anonymized.

7. What are my rights and choices?

You have certain rights and choices with respect to your personal information, as described below:

– You can control our use of certain cookies by following the guidance in our Cookie Statement.

– If you no longer wish to receive marketing and promotional emails, you may unsubscribe by clicking the ‘unsubscribe’ link in the email. You can also contact us by telephone or send us an email at [email protected]. Please note that if you choose to unsubscribe from or opt-out of marketing emails, we may still send you important transactional and account-related messages from which you will not be able to unsubscribe

– If we are processing your personal information on the basis of consent, you may withdraw that consent at any time by contacting us. Withdrawing your consent will not affect the lawfulness of any processing that occurred before you withdrew consent and it will not affect our processing of your personal information that is conducted in reliance on a legal basis other than consent.

8. Changes to the Privacy & Cookie Statement

We are always improving and expanding our products and services. This might cause our data processing to change. When we change something, we will adjust our Privacy & Cookie Statement accordingly. You can always find the latest version on our website.

9. Complaints

When you have a complaint about the data processing by Apochi.com, you can contact our Data Protection Officer via [email protected].

Cookies

1. What are cookies?

Cookies are small data text files and can be stored on your computer’s hard drive (if your web browser permits) when you use or visit our products, services, ads, and websites. This website uses cookies for the following general purposes:

To help us recognize your browser as a previous visitor and save and remember any preferences that may have been set while your browser was visiting our site.

To help measure and research the effectiveness of website features and offerings, advertisements, and email communications (by determining which emails you open and act upon).

2. Why does Apochi.com use cookies?

We use cookies to:

– Provide basic functionalities of our products and services;

– Improve the usability of our products and services;

– Show you personalized ads across the web and analyses their effectiveness;

– Learn more about the use of our products and services by conducting analyses for statistical, strategic, and scientific purposes; and manage customer relationships.

We can combine the data gathered from cookies with other data we have about you, to learn more about your personal customer journey, your use of our products and services and to improve our (personalized) marketing as described in this Privacy & Cookie Statement.

3. Google Analytics – Google Tag Manager

We have configured Google Analytics in accordance with the guidelines for privacy-friendly use from the Dutch Data Protection Authority (‘Handleiding privacyvriendelijk instellen van Google Analytics’). This means we’ve signed a data processing agreement with Google, anonymize IP-addresses and have disabled data sharing where possible. Additionally, Google allows you to opt-out for their analytics cookies via https://tools.google.com/dlpage/gaoptout.

4. Hotjar Limited analytics

We use Hotjar (St Julian’s Business Centre 3, Elia Zammit Street 1000, Malta, Europe) for gathering analytics and analysing the use of our products and services. We have configured Hotjar for privacy friendly use, meaning we’ve signed a data processing agreement with Hotjar, anonymize IP-addresses and have disabled data sharing where possible. Hotjar honours ‘Do Not Track’ browser settings and additionally allows you to opt-out of their cookies via https://www.hotjar.com/legal/compliance/opt-out.

5. How can I block and delete cookies?

In addition to the measures as described in this statement, if you can easily block and remove all cookies on your device via the privacy settings of your web browser.

If you want to prevent new cookies from being placed on your device, you can block the use of cookies via the privacy settings of your web browser. You can choose to block all cookies or only cookies from specific websites. Please note that blocking cookies will not automatically remove cookies that are already stored on your device.

Please be aware that by blocking and/or deleting cookies, our websites (and possibly other websites) might not function properly. With every new session, new cookies will be placed unless you have blocked the use of cookies.

The Help portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.

This site may also use web beacons (also known as clear gifs, pixel tags, or Web bugs), which are tiny graphics with a unique identifier, similar in function to cookies, that are placed in the code of a web page. We use web beacons to monitor the traffic patterns of users from one page within our sites to another, to deliver or communicate with cookies, to understand whether you have come to our site from an online advertisement displayed on a third-party website, and to improve site performance. We also may allow our service providers to use web beacons to track the visitor traffic and actions on our site. This helps us measure the effectiveness of our content and other offerings.

If you have any questions about our use of cookies or other technologies, please contact us at [email protected].