Privacy Policy

1. Introduction

This Privacy Policy explains how FINBPM LIMITED ("FINBPM", "we", "us", "our") collects, uses, stores, and protects personal data. FINBPM LIMITED is registered in Gibraltar under company number 126267, with its registered address at Unit G02, EuroCity, Europort Avenue, Gibraltar GX11 1AA. FINBPM provides services exclusively to corporate and business entities and does not offer services to individuals acting in a personal capacity.

2. Scope

This Policy applies to personal data processed in connection with:

• Merchant onboarding;
• Compliance and due diligence;
• Contractual relationships;
• Website use;
• Communications and support.

3. Legal Basis and Regulatory Framework

FINBPM processes personal data in accordance with:

• Gibraltar data protection laws;
• UK GDPR;
• EU GDPR (where applicable);
• Applicable regulatory guidance.

4. Data We Collect

FINBPM may collect and process the following categories of personal data:

• Identification data (name, date of birth, nationality);
• Contact data (email, telephone, business address);
• Corporate role information (director, shareholder, officer);
• Beneficial ownership data;
• Due diligence and compliance data;
• Technical data (IP address, device information);
• Communication records.

5. Purposes of Processing

Personal data is processed for the following purposes:

• Merchant onboarding and verification;
• AML/CTF and regulatory compliance;
• Risk management and fraud prevention;
• Contract administration;
• Service delivery and support;
• Legal and regulatory reporting;
• Website operation and security.

6. Legal Grounds for Processing

FINBPM processes personal data on the basis of:

• Legal and regulatory obligations;
• Performance of a contract;
• Legitimate business interests;
• Consent (where required by law).

7. Data Sharing and Disclosure

FINBPM may share personal data with:

• Regulatory authorities and law enforcement;
• Banks and payment service providers;
• Compliance and screening service providers;
• Professional advisers;
• IT and hosting providers.
• Data is shared only where necessary and subject to appropriate safeguards.

8. International Transfers

Where personal data is transferred outside the EEA or UK, FINBPM ensures appropriate safeguards, including standard contractual clauses or equivalent protections.

9. Data Retention

Personal data is retained only for as long as necessary for legal, regulatory, and business purposes, and generally for a minimum of five (5) years following termination of the business relationship.

10. Data Security

FINBPM implements appropriate technical and organisational measures to protect personal data, including: Access controls; Encryption; Secure storage systems; Regular security reviews; Incident response procedures.

11. Data Subject Rights

Individuals whose personal data is processed by FINBPM have the right to:

• Access their data;
• Rectify inaccurate data;
• Request erasure (where applicable);
• Restrict processing;
• Object to processing;
• Data portability;
• Lodge complaints with supervisory authorities.
• Requests may be submitted in writing using official communication channels.

12. Cookies and Tracking

FINBPM’s use of cookies and similar technologies is governed by its separate Cookies Policy.

13. Changes to This Policy

FINBPM may update this Privacy Policy from time to time. Updates will be published on official platforms.

14. Contact Information

Data Protection Contact FINBPM LIMITED Unit G02, EuroCity Europort Avenue Gibraltar GX11 1AA Gibraltar For privacy-related inquiries, please contact FINBPM through official channels.