Privacy Policy

DWELL.FI PRIVACY POLICY

This Privacy Policy describes how Dwell.fi and its affiliates and subsidiaries (collectively, “Dwell.fi”, “we”, “us” or “our”) collects, uses, stores, shares and protects your information when you use the Services (as defined below), visit the dwell.fi website and what we do with such information.

The “Services” shall mean all Dwell.fi Account, Dwell.fi API services, and all other communications or other engagement between you and Dwell.fi, which may be subject to change from time to time.

This Privacy Policy provides a general overview of our privacy practices regarding your information. It is important that you read this Privacy Policy together with any other privacy notice or fair processing notice we may provide on specific occasions and which may be applicable to you 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 the other notices and is not intended to override them. You can learn more about certain jurisdiction-specific information in the applicable sections at the bottom of this Privacy Policy.

I. PURPOSE OF THIS PRIVACY POLICY

We know how important privacy is to our users, which is why this Privacy Policy explains how we collect and use data.

  1. The Data we Collect about You 

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, middle name, maiden name, last name, title, identity document number, nationality and any other information contained in any identification documents you provide to us (e.g., your passport or driver’s license).
  • Transaction Data includes details of your Dwell.fi activity such as the amount, date, time, recipient for each transaction.
  • Technical Data includes your internet protocol (IP) address, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access the Services.
  • Profile Data includes your username or similar identifier, password, your preferences, feedback and any survey responses.
  • Usage Data includes information about how you use the Services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
  • Survey and Customer Feedback Data includes information you provide in any survey or feedback forms on Services.
  • Location Data includes information about your device location.

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, genetic and biometric data).

2. Information about Criminal Convictions

When you register for a Dwell.fi Account or otherwise use the Services, we may receive information about your criminal convictions when we perform certain verification or compliance checks. We carry out these checks in order to detect or prevent any unlawful or fraudulent acts and to comply with our legal obligations.

3. If you fail to provide Personal Data

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 (i.e., to provide the Services to you). In this case, we may have to close your Dwell.fi Account or limit or restrict your access to other Services, in accordance with the terms of the Dwell.fi Terms of Use, but we will notify you if this is the case at the time.

II. HOW WE COLLECT YOUR PERSONAL DATA 

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your identity, contact, financial, transaction, profile, usage, marketing and communications and location data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when:
    • you create or use your Dwell.fi Account;
    • you send a wire transfer to your Dwell.fi Account;
    • we need to request more information to verify your identity or to meet our legal obligations;
    • you request marketing material to be sent to you;
    • you participate in a survey; or
    • you give us some feedback.
  • Automated technologies or interactions. When you interact with our Services, we may automatically collect usage and technical 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.

IIIHOW WE USE YOUR PERSONAL DATA

We collect all of the information in Section II above so that we can provide you with the Services. The information we collect allows us to:

  • Deliver the full functionality of the Services;
  • Keep in touch with you – whether it be for providing customer service, notifying you of new features or updates to the Services, or providing security notices or information;
  • Verify your identity so that we can prevent fraud or unauthorized activity, and to comply with applicable laws; and
  • Fulfill any other purpose for which the information was collected.

We will never share, sell, or rent your personal data to third parties. We may combine your information with information we collect from other companies and use it to improve and personalize the Services, as well as our content and advertising.

  1. Purposes For Which We Will Use Your Personal Data

We have set out below a description of 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 support@dwell.fi.

2. Change Of Purpose

We will only use your personal data in accordance with the purposes described in this Privacy Policy and as provided for under applicable law for the purposes for which we collected it. 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.

3. Third-Party Links

The Services 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 are not responsible for the data collection and processing practices of the third party and use of any third-party websites is subject to their privacy policies. When you leave our website, we encourage you to read the privacy notice of every website you visit.

4. Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

●      Promotional Offers from Us
  • You will receive marketing communications from us if you (i) have requested information from us; (ii) use our Services; or (iii) provided us with your details when you registered for a promotion and you have not opted out of receiving that marketing.
●      Third-Party Marketing
  • We will get your express opt-in consent before we share your personal data with any company outside the Dwell.fi for marketing purposes.
●      Opting Out
  • 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 support@dwell.fi 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, a product/service experience, or other transactions. Opting out will also not opt you out of receiving non-marketing information such as account statements and updates to this Privacy Policy or our user agreement.

5. Marketing

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 our website may become inaccessible or not function properly.

Do Not Track (“DNT”) is an optional browser setting that allows you to express your preferences regarding tracking by advertisers and other third-parties. At this time, we do not respond to DNT signals.

IV. HOW WE PROTECT YOUR PERSONAL DATA

We protect your information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to data centers and information access authorization controls.

Sometimes in order to better secure your information and use it for the purposes contemplated by this Privacy Policy, certain personal data may be stored with our third-party partners and service providers.

1.          Data Retention

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

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 unauthorized 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 requirements.

2.           Children’s Privacy

If you’re under 18, you can’t use the Dwell.fi Account or other Dwell.fi products. We do not knowingly solicit or collect information from anyone under 18. If we become aware that a person under the age of 18 has provided us with personal information, we will delete it immediately.

V. CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

We may change this Privacy Policy from time to time. When we do make updates, we’ll let you know by changing the date at the bottom of this Privacy Policy. If it is a more extensive or significant update, we’ll send you a notification or post a notice on our website. If you ever have any questions about changes made to the Privacy Policy, just reach out to support@dwell.fi.

It is important that the personal data we hold about you is accurate and current. If you need to add or change any information, you can just log in to your Dwell.fi Account and make the change in your settings. If you cannot make the change on your own, just reach out to support@dwell.fi and we will take care of it. Please keep us informed if your personal data changes during your relationship with us.

VI. QUESTIONS 

If you have any questions about this Privacy Policy, feel free to reach out to support@dwell.fi.

VII. NOTICE TO CALIFORNIA RESIDENTS

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”

For more details about the personal information we collect from you, please see the “The Data we Collect about You” section above. We collect this information for the business and commercial purposes described in the “The Data we Collect about You” section above. Dwell.fi does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. California consumers may make a request pursuant to their rights under the CCPA by contacting us at support@dwell.fi. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

Last updated on: February 1, 2024