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This Privacy Policy aims to give you information on what Personal Data we collect, use, store, process and share through your use of https://www.eurodollar.fi (the “Site”). The Site is operated by Rhinefield Technologies Limited incorporated and registered in Cyprus with company number 449890 whose registered office is at Athalassas, 176 3rd Fl., Flat/Office 301, 2025, Nicosia, Cyprus (“RTL”). RTL is part of the Eurodollar Group companies ("Eurodollar"). Use of the words “Eurodollar,” (“we,” “us,” or “our”) refer to any or all Eurodollar Group entities and their affiliates.
Eurodollar respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will inform you as to how we look after your Personal Data when you visit our website and tell you about your privacy rights and how the law protects you.
It is important that you read this Privacy Policy together with any other privacy notices or fair processing policy we may provide on specific occasions when we are collecting or processing Personal Data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and Privacy Policies and is not intended to override them. By continuing to use our Site, you agree to this Privacy Policy.
As used in this policy, “Personal Data” means any information relating to a living individual who can be identified directly from that information or indirectly in conjunction with other information which we may hold or have access to. “Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We process Personal Data to be able to provide and improve our products and services, as well as to comply with our legal obligations under the Danish Act on the Measures to Prevent Money Laundering and Financing of Terrorism.
We may collect the following categories of Personal Data from you:
Identification Data: first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender, nationality, identification numbers (tax ID, driver’s licence number, passport number), government-issued identity documents, images collected for identity verification.
Contact Data: residential address, billing address, telephone numbers, email address.
Correspondence Data: account opening information, customer support, information provided in correspondence.
Financial Data: bank account information, bank identifier codes, payment card details.
Location Data: information about location of your device.
Marketing and Communications Data: your communication preferences, your preferences in receiving marketing from us and our third parties.
Profile Data: username and password, purchases made by you, your interests, preferences, feedback and survey responses.
Technical Data: internet protocol (IP) address, domain name, hardware, system activity, login data, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Site.
Transaction Data: order activity, deposits, withdrawals, account balances, trading activity, amount, date, time, recipient.
Usage Data: information about how you use our Site, products and services.
Voluntary information: information which is collected from time to time (for example, through surveys) to enable us to improve our services or consider the wider needs of our users or potential users, or voluntary information that might be collected from you upon request and subject to your specific consent, for the purpose of provision of any of the services to you.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).
We may receive information about your convictions when we perform compliance checks in order to open your Eurodollar account and provide you access to our services. We conduct due diligence and anti-money laundering checks to prevent and detect fraudulent or unlawful acts and comply with our legal obligations.
Where we need to collect Personal Data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may have to cancel a service or restrict the account you have with us but we will notify you if this is the case at the time.
We use different methods to collect data from and about you including through:
Direct interactions. You may give us your Identity, Contact, Financial, Marketing, Location, Usage, Correspondence Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
apply for our products or services;
create an account on the Eurodollar Site;
provide information to verify your identity and meet our legal obligations;
subscribe to our service or publications;
request marketing to be sent to you;
enter a competition, promotion or survey; or
give us feedback or contact us.
Automated technologies or interactions. As you interact with our Site, we will automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our Cookie Policy for further information.
Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
Technical Data from analytics providers such as Google;
Contact, Financial and Transaction Data from providers of technical and payment services;
Identity and Contact Data from compliance and verification service providers; and
How we use your Personal Data
We will only use your Personal Data when the law allows us to. Most commonly, we will use your Personal Data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you to deliver our service.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to verify your identity, prevent fraud or unlawful activity, comply with a legal obligation.
We will never share, sell or rent your Personal Data to third parties. Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your Personal Data
We have set out below a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Note that we may process your Personal Data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table below.
With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
With your permission and/or where permitted by law, we may also use your Personal Data for marketing purposes, which may include contacting you by email with information, news, and offers on our products and services. You will not be sent any unlawful marketing or spam. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
We may use your Identification, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
We will get your express opt-in consent before we share your Personal Data with any third party outside of the Eurodollar group of companies for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to Personal Data provided to us as a result of your use of the services of Eurodollar. Opting out will not opt you out of receiving non-marketing information such as statements and account updates.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Site may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy https://eurodollar.fi/cookies-policy.
We will only use your Personal Data in accordance with the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your Personal Data with the parties set out below for the purposes set out in clause 6.
In order to deliver our services to you, we will need to share your Personal Data with third parties who provide us with tools and services including onboarding, professional advice, data storage, accounting, invoicing, advertising and marketing, IT, security and fraud detection, and communication channels.
In order to prevent, detect fraud and comply with our legal obligations, we will need to share your Personal Data with third party identification verification service providers. This may include credit searches, but we will ensure this does not have an adverse effect on your credit or credit score.
In order to verify and complete payment transactions, we will need to share your Personal Data with your bank based in the country where your bank account is held. We will share your account information with our banks so we can process payments associated with your Eurodollar account.
We may need to share your Personal Data with law enforcement agencies or government officials. We will only do this when we are required to do so by court order, formal request, specific regulation, or when we believe in good faith that sharing your Personal Data will prevent financial loss, physical harm, or we are obligated to report suspicious and illegal activities.
We may choose to sell, merge parts or transfer our business or our assets to third parties. We may acquire other businesses or merge with them. If such business change happens, the new owners may use your Personal Data in the same way as set out in this Privacy Policy.
By agreeing to this Privacy Policy, you consent to such sub-processors collecting and processing your Personal Data pursuant to the terms hereof.
We require all third parties to respect the security of your personal data and to treat it in accordance with applicable law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions.
We share your Personal Data within the Eurodollar Group.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules". Many of our external third parties are based outside the EEA so their processing of your Personal Data will involve a transfer of data outside the EEA. When transferring data across borders, we take measures to comply with applicable data protection laws related to such transfers.
If you are located in the European Economic Area (“EEA”), the UK, or Switzerland, we rely on the Standard Contractual Clauses (SCCs) to provide an adequate level of data protection for the transfer of your Personal Data from the EEA, the UK, or Switzerland, where the country of import is not deemed adequate under applicable law.
We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for Personal Data, we consider the amount, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorised use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. If you wish to exercise any of the rights set out above, please contact us.
to your Personal Data (commonly known as a "Data Subject Access Request"). This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your Personal Data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios:
If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Data to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month or in accordance with applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this privacy policy or in relation to the processing of your personal data, please contact us by emailing dataprotection@eurodollar.fi.
If you are a European Union resident and you believe that we have not adequately resolved your data protection query, you have the right to contact your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns so please contact us in the first instance.
Rhinefield Technologies Limited
Registration number: 449890
Address: Athalassas, 176 3rd Fl., Flat/Office 301, 2025, Nicosia, Cyprus
Email: dataprotection@eurodollar.fi
Website: https://www.eurodollar.fi/
Contacts of the Cyprus Office of the Commissioner for Personal Data Protection:
Address: kypranoros 15, Nicosia 1061, Cyprus
Tlf. +357 22818456
Email: commissioner@dataprotection.gov.cy
Website: https://www.dataprotection.gov.cy
We keep our privacy policy under regular review. This version was last updated on 8 April 2024. Historic versions can be obtained by contacting us. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.