Privacy

DCIC S.A., as Data Controller (in the following also called «DCIC», «we» or «us»), ensures the greatest attention to confidentiality, protection and security of personal data of the people it comes into contact with. The following information is intended to provide you with an overview of the processing of your personal data by DCIC and your rights under data protection legislation. Specifically, what information is processed and how it is used depends substantially on the services requested and/or agreed upon. The user of this website is encouraged to read in advance all of the sections of this document, where the website’s management procedures related the processing of users’ personal data are described. This also constitutes a privacy notice pursuant to EU Regulation 679/2016 (GDPR) provided to everyone who is interacting with DCIC’s web services accessible through the internet at the following address: https://www.decash.com. This privacy notice applies only to DCIC’s website and not to any other website the user could land on through links found on DCIC’s website. DCIC does not have any kind of control over those websites and over the procedures they put in place to guarantee data confidentiality and protection. Therefore, we strongly recommend reading privacy provisions of every entity you get in touch with before communicating personal information. Personal data DCIC might have access to are exclusively those provided by you while surfing the website through the optional, explicit and voluntary sending of the modules found on this website or of e-mails to the addresses on this website. Failure to provide the data might determine the impossibility for DCIC to provide the requested service. The processing of your personal data may be carried out through manual and telematic tools.

Data Controller

The Data Controller is DCIC S.A, with registered office in Bloc Office Hub, Fifth Floor, Santa Maria Business District, Panama City Republic of Panama - E-mail address: info@decash.com

What information we collect and use

We process personal data that we obtain from our customers as part of our business relationship. This data protection notice also applies to persons who do not have any business relationship with DCIC but whose information is processed by DCIC for other reasons (e.g., people who write to us or otherwise contact us, visitors to our websites, recipients of information and marketing communications, contact persons for our suppliers, buyers and other business partners, participants in contests, competitions and customer events, visitors to our locations). Data is collected and managed for the purposes and within the timeframe indicated below:

Why do we process your data? (Purpose of processing)

We always process your personal data for a specific purpose and only to the extent necessary to achieve that purpose. The main purposes of such data processing are as follows:

Negotiations and contracts

To confirm your identity and evaluate your application (including any need for personal guarantees or other collateral) and to perform compliance checks for legislative or regulatory requirements (e.g., compliance with anti-money laundering and fraud laws and regulations).

Managing Risk

• Processing of data to meet DCIC’s internal operational requirements for risk management, system or product development, and planning, insurance, audit, and administrative purposes.
• Processing of data to provide payment products and services and to ensure their proper functioning, e.g. by conducting appropriate identity checks and making deposits to and withdrawals from your account in accordance with your instructions and the terms of the product in question. The purposes of data processing depend primarily on the specific order. They may include demand analysis, advice and execution of transactions.

Managing our relationship with you

To deal with customer service issues and complaints regarding products and services provided by us and our business partners, to clarify where you are located if we can no longer reach you.

Measures to improve our products, services, technologies

Checking and updating our systems and processes, for market research purposes, to find out how we can improve our existing products and services or what other products and services we might offer.

Information & Direct Marketing

We process personal information to send you information and advertisements, including through push notifications, about products and services that we think may be of interest to you, including products and services offered by us or our business partners.

Events

We also process personal data when we hold events for clients (e.g., advertising events, sponsorship events, cultural and sporting events). Such data may include first and last names of participants and/or prospects, their mailing address and/or email address, and possibly other information, such as their date of birth, as circumstances dictate. We process this information for the purpose of executing customer events, but also so that we can contact you directly. For further information, please refer to the relevant conditions of participation. Each customer may opt out of receiving information (blocking of advertising messages) or revoke any previous consent given to the processing of data in the context of such customer events on a general level by sending DCIC a written request to this effect, including by e-mail (see information below on the right of objection).

Fulfilling legal obligations

Compliance with financial, anti-money laundering and tax legislation in relation to the recording and monitoring of communications, disclosure of data to tax, financial regulatory and other supervisory and/or national authorities and for the purposes of crime detection or prevention.

Analyses and statistics

To perform transaction and statistical analysis and similar analysis. As well as for other purposes of which you will be informed on a case-by-case basis. In specific cases, we will ask for your consent to process personal data for certain purposes such as transfer to third parties for their marketing purposes. Such consent must be given to us separately and can be revoked at any time.

Who will receive my data?

We will only disclose your personal information if we are required to do so to comply with our legal or regulatory obligations, for business or administrative reasons, or because you have asked us to do so. This is likely to include disclosure:

• inside the Company
• to third parties who process personal data on our behalf (IT system providers and other service providers)
• to any government, regulatory agency, enforcement or exchange agency, or court that requires it under applicable law or regulation.

In general, data might be accessed by natural and legal persons appointed as data processors, as well as authorized persons, who might have access only to such data as are necessary for the performance of their duties. Moreover, data might be communicated to third parties to comply with legal obligations. The list is available by contacting the data protection officer at the following e-mail address: info@decash.com

How long will my data be kept?

We retain your personal information as long as it is necessary for the purposes for which we collected it. In the case of contracts, we retain your personal data at least for the duration of our contractual relationship.
We also retain personal data whenever we have a legitimate interest in doing so. This may be the case, in particular, if we need personal data to exercise rights or defend against claims, for archiving purposes, to ensure IT security or as long as the statute of limitations on contractual or non-contractual claims is still running. For example, 10-year statutes of limitations normally apply, but there are also many cases where the statute of limitations is 5 years or even 1 year.
In addition, we retain your personal data for the applicable legal retention period, compliance with retention periods under tax or trade legislation or compliance with the 10-year retention period under money laundering legislation.
In certain cases we will ask for your consent if we wish to retain your personal data for a longer period.
Upon expiration of these periods, your data will be deleted or anonymized.

Data Subjects Rights

In accordance with articles from 15 to 21 of the Regulation (EU) 679/2016, data subject may exercise specific data protection rights set out in the list above:

• Right of access: right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and detailed information on the origin, the purposes, the categories of personal data concerned, the recipients and/or the transfer of data, and more;
• Right to rectification: right to obtain from the controller without undue delay the rectification of inaccurate personal data, as well as the right to have incomplete personal data completed, including by means of providing a supplementary statement;
• Right to erasure (“right to be forgotten”): right to obtain from the controller the erasure of personal data without undue delay when:
  1. 1. the personal data are no longer necessary in relation to the purposes for which they were processed;
  2. 2. consent on which the processing is based is withdrawn, and there is no other legal ground for the processing;
  3. the personal data have been unlawfully processed
  4. 3. the personal data have to be erased for compliance with a legal obligation
• Right to object: right to object at any time to the processing of personal data having as a legal basis a legitimate interest of the Controller and/or to the processing for marketing purposes, including profiling. In the case of objection to the processing for marketing purposes, the personal data are not processed for those purposes anymore
• Right to restriction of processing: right to obtain from the Controller restriction of processing where the accuracy of the personal data is contested (for a period enabling the controller to verify the accuracy of the personal data), the processing is unlawful and/or the data subject has objected to processing;
• Right to data portability: right to receive the personal data in a structured, commonly used and machine-readable format, and the right to have the data transmitted from one Controller to another, where technically feasible, only where the processing is based on consent or on an agreement and only for the data processed through electronic means;
• Right to lodge a complaint with a supervisory authority: without prejudice to any other administrative or jurisdictional claim, the data subject that considers the processing that concerns him/her is violating the Regulation has the right to lodge a complaint with the supervisory authority of the member state in which he resides or is established, as well as in the state where the assumed violation occurred
• Right not to be subject to an entirely automated profiling: when the profiling is entirely automated, the right to obtain human intervention on the part of the Controller, to express his or her point of view and to contest the decision

Moreover, we hereby inform you that you have the right to revoke at any time your consent previously given to optional activities, notwithstanding the lawfulness of the processing activities carried out before the withdrawal.

To exercise your rights as a Data Subject, you can send your request to:

• DCIC S.A., with registered office in Bloc Office Hub, Fifth Floor, Santa Maria Business District, Panama City Republic of Panama
• E-mail address: info@decash.com

Am I required to provide information?

In the course of our business relationship, you must provide us with the personal information we need to initiate and conduct our business relationship and to fulfill our contractual obligations in this regard, as well as the information we must collect by law. Without such data, we will not be able to enter into or perform the contract (in which case we will notify you).

In particular, before we can enter into a business relationship with you, money laundering legislation requires us to verify your identity through your identification documents and to collect and record your full name, place and date of birth, nationality, address and identification document details. In order for us to fulfill this legal obligation, you must provide us with the information and documents required under the Anti-Money Laundering Act and promptly notify us of any material changes in the course of our business relationship. If you do not provide us with the required information and documents, we will not be able to initiate or continue our business relationship.

Security of data

DCIC adopts technical measures such as:

• cryptography
• pseudonymisation
• logging
• access control
• data backup on multiple servers and organizational
• instructions for our employees
• confidentiality agreement
• reviews

adequate to ensure the security of the information collected and processed from unlawful access, misuse, loss, falsification and destruction. Access to your personal information is permitted only to those who need it to perform their duties.

It is generally impossible, however, to completely rule out security risks: some residual risks are most often unavoidable. In particular, since perfect data security cannot be guaranteed for communications via email, instant messaging or similar means of communication, we recommend that you send confidential information via particularly secure means such as mail or by agreeing on additional safeguards with our technical staff.

The content of this website – script code, graphics, texts, charts, images, sounds, and any other information available in any form – are protected within the meaning of legislation in the field of intellectual works. Any company and products referred to in this website are identified by their trademarks, that might be protected by patents and/or copyright granted or registered by the competent authorities. Software products and informative contents, unless specified otherwise, can be downloaded or used for personal use only, or eventually for non- commercial use citing the source.