CHEQs Inc.  ("us", "we", or "our") operates the Cheqs.com website and platform (the "Service"). This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the service. By using the service, you agree to the collection and use of information in accordance with this policy.

What kind of data is processed?

We collect several different types of information for various purposes to provide and improve our service to you.

Personal Data

While using our service, we ask you to provide us with certain personally identifiable information that can be used to contact or identify you ("Personal Data"). Personally identifiable information may include, but is not limited to:

• Email address
• First name and Last name
• Country
• Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.

Usage Data

We collect information on how the service is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our service and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our services. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our service.

For more information about cookies, see our cookie policy.

For what purpose is the data collected?

We uses the collected data for various purposes:

• To provide and maintain our service
• To notify you about changes to our Service
• To provide customer support
• To gather analysis or valuable information so that we can improve our service
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Duration of Processing

We will keep your personal data:

• for as long as necessary to achieve the original purpose we collected it for
• in line with relevant laws

We are required to keep certain personal data for specified time periods by KYC, anti-money laundering laws. These time periods vary from country to country. CHEQs has to ensure we comply with these requirements.

We may keep your personal data for a longer time period because of a potential or ongoing court claim, or for another legal reason.

How do we protect your information?

We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy. We are committed to protecting your personal information against unauthorized use or disclosure.

Disclosure to Third Parties

We use a select number of trusted external service providers for certain technical data analysis, processing and/or storage offerings. These service providers are carefully selected and meet high data protection and security standards. We only share information with them that is required for the services.

Under certain circumstances, CHEQs Global Ltd may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

CHEQs Global Ltd may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of CHEQs Global Ltd
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Your Rights

Your rights associated with the Services are described below. Please note these rights may only be available to you in specific regions, countries or states based on where you reside. In certain cases, we may be prevented from allowing you to exercise these rights but we will inform you if that is the case when you seek to exercise the rights.

You have the following rights associated with the processing of your Personal Information:

• Right to Access or Right to Know. You have the right to obtain access to the Personal Information we hold about you and to request certain information about our processing. You have the right to receive an explanation of (i) why we process your Personal Information, (ii) the categories of Personal Information we have about you, (iii) who we share your Personal Information with, (iv) how long we store your Personal Information and (v) who we received your Personal Information from if it was not collected from you directly. We will also inform you about your privacy rights. 
• Right to Rectification or Correction. You have the right to correct, update or complete any Personal Information we hold about you that is inaccurate or incomplete. Please note that we may rectify or remove incomplete or inaccurate information, at any time and at our own discretion.
• Right to Erasure or Deletion. You may request to have your Personal Information anonymized, erased, or deleted, as appropriate. In this case, if there is no overriding legitimate interest or requirement to continue processing your Personal Information, we will erase your data.
• Right to Object to Processing. You have the right to object to our processing of your Personal Information where we are relying on a legitimate interest or if we are processing your Personal Information for direct marketing purposes.
• Right to Restrict Processing. You have a right in certain circumstances to stop us processing your Personal Information other than for storage purposes.
• Right to Portability. You have the right to receive, in a structured, commonly used, and machine-readable format, Personal Information that we hold about you, if we process it based on our contract with you, or with your consent, or to request that we transfer such Personal Information to a third party.
• Right to Withdraw Consent. You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge. We will apply your preferences going forward. This will not affect the lawfulness of the processing before you withdraw your consent.
• Right to Lodge a Complaint. You may lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where you believe an incident took place.
• Right Against Discrimination. We will not discriminate against you for exercising your rights.
• Right to Opt-Out of Targeted Advertising, Sale or Sharing. You can ask us to stop using your Personal Information for targeted advertising when required by law.

Please note that, prior to any response to the exercise of such rights, we may require you to verify your identity. In addition, we may have valid legal reasons to refuse your request and will inform you if that is the case. Note that applicable laws contain certain exceptions and limitations to each of these rights. Subject to certain restrictions, you can ask an agent to exercise your rights for you. If you have an agent exercising your rights, that person must provide to us your written authorization allowing them to make such a request on your behalf. We reserve the right to deny the agent’s request if we are not reasonably able to confirm proper authorization and/or verify your identity as the requestor. You further agree that CHEQs Global Ltd shall not be held liable with respect to any loss and/or damage to your Personal Data if you choose to withdraw consent.

You may exercise these rights by contacting us by email at: dpo@cheqs.com

Who We Share Personal Information With 

In order to provide the Services, we must share your Personal Information in certain cases. This includes sharing your Personal Information with our Service Providers and the other third parties listed in this section. We do not sell your Personal Information.

We may disclose Personal Information about you under the following circumstances:

Service Providers. We work with third parties for the purpose of providing Services such as hosting, maintenance, network management, cybersecurity, and support. These third parties may have access to or process your Personal Information as part of providing those services to us. For example:

We use cloud service providers who we rely on for data storage, disaster recovery and to perform our obligations to you.

We use service providers of business communication tools.

We use service providers who manage the networks for the operation of the Services and to improve latency for our users.

We use service providers to help us prevent malicious actors from threatening the Services and to comply with legal obligations, such as preventing individuals from sanctioned territories, or sanctioned individuals, from accessing the Services.

Legal. Personal information about you may be disclosed to law enforcement agencies, regulatory bodies, public authorities or pursuant to the exercise of legal proceedings if we are legally required to do so, or if we believe, in good faith, that such disclosure is necessary to comply with a legal obligation or request, to enforce our terms and conditions, to prevent or resolve security or technical issues, or to protect the rights, property or safety of Cheqs Global Ltd, our Users, a third party, or the public.

Strategic Business Partners. Where you have provided your consent, we may share your Personal Information with our strategic business partners in limited circumstances, for example for marketing and advertising purposes.

Third Party Platforms (as defined below). Your Personal Information may be disclosed to Third Party Platforms where you have requested to interact with a third-party service or platform.

Third Party Links and Websites

The Services enable you to interact with certain third-party services, or third-party platforms (such as on- or off-ramp features) (collectively "Third Party Platforms"). However, this Privacy Policy does not address, and we are not responsible for, the privacy practices of any third parties, including but not limited to those that operate websites to which the Services links. The inclusion of a link on the Services does not imply that we or our affiliates endorse the practices of the linked website. Your use of such Third Party Platforms and those Third Party Platforms' use of your Personal Information is subject to their respective terms of use and Privacy Policy (if any) and is not subject to this Privacy Policy.

Children's Privacy

We do not knowingly collect personally identifiable information from anyone under the age of 13. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us on dpo@cheqs.com. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Change of Ownership

In the event of a change in ownership, or a merger with, acquisition by, or transfer or sale of all or a portion of our assets to another entity, we reserve the right to transfer all your Personal Information to that entity. We will use reasonable efforts to notify you of a transfer to an unaffiliated third party (by a posting on our homepage, or by email to the email address that you provided to us, as chosen by us at our discretion).

Changes to Our Privacy Policy 

We reserve the right to amend this Privacy Policy at any time to reflect changes in the law, our data collection, use or sharing practices or advances in technology. We will make the revised Privacy Policy accessible throughout the Services. You should review this Privacy Policy periodically. The “Date of Last Revision" included at the beginning of this Privacy Policy will indicate when it was last updated.

By continuing to access or use the Services, you are confirming you have read and understand the latest version of this Privacy Policy.

Complaints

If you wish to lodge a complaint about how we process your Personal Information, please contact us by email dpo@cheqs.com. We will endeavor to respond to your complaint as soon as possible. You may also lodge a claim with the applicable supervisory authority.

Contact Us

If you have any questions or comments about this Privacy Policy, or if you would like to exercise your rights with respect to your Personal Information, please contact us by dpo@cheqs.com.

 

Supplemental Privacy Policy

(EU, Turkey, Switzerland, and the United Kingdom (EEA+))

This Supplemental Privacy Policy applies to you only if you are a natural living person and you are located in the European Union, a European Free Trade Association country, Turkey, Switzerland, or the United Kingdom (“EEA+”). If you are located in the EEA+ and engage with the Services, Cheqs Global Ltd is the data controller with regard to the provision of the Services.

This Supplemental Privacy Policy provides supplemental notices that are unique to the EEA+ region.

1. Legal Bases for the Processing of Personal Information

In accordance with our legal requirements in this region, we are required to identify and inform you of the legal basis that we use for the processing of your Personal Information. In this section, we provide you with information about the legal bases we rely on when processing your Personal Information.

 

If you are located in EEA+ our legal basis for processing your Personal Information is described in this section. Please note that more than one legal basis may exist for the processing of your Personal Information:

 

• Consent. This is the case where you have consented to the use of your Personal Information.

• Contract.

The performance of the contract is used as the legal basis for the processing of your Personal Information for the purpose of providing the Services to you. For example, we need your Personal Information to provide you with our Services, to perform our obligations associated with our contract with you, such as to create and secure your account, to respond to your inquiries or to take steps that you request prior to signing up for the Services.

• Legitimate Interest.

We have a legitimate business interest in processing your Personal Information to provide the Services to our Customers. We only rely on legitimate interest as a legal basis when the legitimate interests do not override your fundamental rights and freedoms associated with privacy and data protection on balance. We ensure we comply with any requests you make to exercise your associated rights. The processing of your Personal Information where legitimate interests are used as the legal basis for the processing of your Personal Information may include the following purposes: to communicate with you, to optimize our Services, for compliance, fraud, and safety purposes and to provide the Services.

• Legal Obligation.

We may have a legal obligation to process your Personal Information, for example, to comply with tax and accounting obligations (which may include anti-money laundering (AML) laws and know-your-customer (KYC) requirements). We may process your Personal Information when necessary to establish, exercise, or defend legal claims.

2. Data Protection Officer

CHEQs Global Ltd. Data Protection Officer can be reached at: dpo@cheqs.com

3. International Data Transfers

As we provide an international service, we may need to transfer your personal data outside of the EEA + to help us provide our services to keep to global legal and regulatory requirements, and to provide ongoing support services.

We may send your personal data outside of the EEA + to:

- keep to global legal and regulatory requirements

- provide ongoing support services

- fraud prevention agencies or law enforcement authorities

- enable us to provide you with products or services you have requested

If we transfer your personal data to another country that doesn’t offer a standard of data protection

equivalent to the EEA +, we will make sure that your personal data is sufficiently protected. For example, we’ll make sure that a contract with strict data protection safeguards is in place before we transfer your personal data. In some cases, you may be entitled to ask us for a copy of this contract.

If you would like more information, please contact us by sending an email to dpo@cheqs.com

4. Complaints

You have the right to contact the appropriate supervisory authority at any time to lodge a complaint regarding the processing of your data. The list of EU supervisory authorities is located here. All other supervisory authorities can be located via a search for their website homepage.