Privacy Policy

About us

Sthaler Limited (Sthaler) is a UK registered company, no 08161567, with its registered office at 4 Riverview, Walnut Tree Close, Guildford, GU1 4UX, United Kingdom.

FinGo is a product of Sthaler.

Questions about the FinGo Service, GDPR and your data privacy rights can be resolved by emailing our Data Protection Officer at [email protected].

Purpose of the policy

This Data Privacy Policy describes how we protect your privacy and how we use information about you when providing the FinGo Service to you.

At the core of our service is the belief that your data belongs to you and to you alone. We do not share your data with 3rd parties, except those specifically involved in providing the FinGo Service. We do not allow anyone else to use or access your data outside the purposes for delivering the FingGo Service to you

Any data we are in possession of about you is treated as “Special Category Data” and is protected and handled in accordance with:

• The UK Data Protection Act 2018
• EU General Data Protection Regulation

Sthaler are committed to protecting and respecting your privacy. This Data Privacy Policy sets out how we both use and protect the personal information that you provide to us when you use the FinGo Services.

What information we collect

To provide the FinGo Service we will need to collect information from you for the purposes of registration, enrolment and continued use of the services. This data collection is required in order for the service to be provided to you under the terms of this Contract. The mandatory data collected is:

• First name
• Last name
• Mobile number
• Email address
• Password
• Payment card number (only the last four numbers are kept)
• Payment card expiry date
• Receipts of purchases made through FinGo
• A proof of identity document (e.g., passport, drivers licence)
• Your finger vein template
• Your facial image (only collected to verify your identity and link with your FinGo account)
• Postcode, town, county and country (only collected for Variable Recurring Payment service)

What we do with the information we collect

We collect information from you to provide the FinGo Service you have requested, and in particular:

• To provide a requested service or carry out a contract with you.
• To register you as a user of the FinGo services
• To verify your identity to authorise payment by the Payment Service Provider
• To verify your identity to link your finger vein ID with your FinGo account
• To verify your age in order to authorise payment for age restricted sales
• To verify your age in order to authorise access to age restricted venues
• To provide you with service messages, including messages notifying you about changes to FinGo services or changes to our terms, conditions and policies
• To confirm your identity with your finger vein ID and facilitate you making a payment

If we have your consent.

• To register you as a user of the FinGo services
• To verify your identity to authorise payment by the Payment Service Provider
• To verify your identity to link your finger vein ID with your FinGo account
• To verify your age in order to authorise payment for age restricted sales
• To verify your age in order to authorise access to age restricted venues.
• To provide you with service messages, including messages notifying you about changes to FinGo services or changes to our terms, conditions and policies
• To confirm your identity with your finger vein ID and facilitate you making a payment

If we have your consent.

• To contact you (including by email or SMS) with marketing messages according to your marketing preferences

Where we have a legitimate interest to improve customer experience and the quality of the FinGo services.

• To help us respond to your Technical or Service queries
• To aggregate anonymised data to produce market trend information
• To enable us to contact you by means such as SMS, email

Where we have a legal obligation.

• To comply with our legal and regulatory obligations (including fraud prevention, anti-money laundering and sanction screening). This may include checking the information you provide to us against information from other sources.

How long we retain your personal information

We only retain your information for as long as is necessary for us to use your information to provide you with the FinGo Services as described above or to comply with our legal obligations.

You may delete your FinGo account at any time by using the “delete” button in your FinGo account. If you cease to be a FinGo user we will generally delete personal information we hold on you within 120 days from the date of termination. However, please be advised that we may retain some of your information after you cease to be a FinGo user or use the FinGo Services, for instance if this is necessary to meet our legal obligations such as retaining the information for regulatory purposes.

Your information will be encrypted and stored in accordance with legal requirements for a period of 7 years for audit purposes. After 7 years the data is permanently removed from our systems.

When determining the relevant retention periods, we will take into account factors including:

• Our contractual obligations and rights in relation to the information involved
• Legal obligation(s) under applicable law to retain data for a certain period of time
• Statute of limitations under applicable law(s)
• (Potential) disputes
• Guidelines issued by relevant data protection authorities

Otherwise, we securely erase your information once this is no longer needed.

Who we share information with

The data you provide to us will not be disclosed to organisations other than to the suppliers that we work with to deliver the service to you.

We may disclose your personal data where we have your permission or where we are under a duty to share your personal information in order to comply with any legal obligations.

How you can access or amend the information we hold about you

You may request details of personal information we hold about you in accordance with the UK Data Protection Act 2018 and EU General Data Protection Regulation. To do so, or if you think the information we hold about you is incomplete or incorrect or you wish to have your account deleted, please contact our Data Protection Officer at:

Sthaler Limited, International House, 1 St Katharine’s Way, London E1W 1UN 

Email: [email protected] Web: www.fingo.to

If the information we hold about you is inaccurate, you can also access and update it at any time by logging on to your FinGo account and updating your details.

Furthermore, under the EU General Data Protection Regulation, you have the following rights;

• The right to be informed
• The right of access
• The right to rectification
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• Rights in relation to automated decision making and profiling*
• The right to lodge a complaint with a supervisory authority (The UK ICO is an example, the Danish Supervisory Authority is another)

* We only collect information necessary to supply FinGo services. We do not use your data for profiling.

How we protect your data

We operate under an extensive security policy framework to ensure that all reasonable efforts are made to ensure that all data (including personal information) collected by the service is made available to you, remains confidential, and is protected from disclosure or unauthorised amendment.

Where we send data to third parties to help us provide the service to you, we will provide those 3rd parties with only the information they need to deliver the service. Those 3rd parties are prohibited from using this information for any other purpose than stated in this Data Privacy Policy and are contractually obligated to maintain and manage data in accordance with our Terms and Conditions.

How we use cookies

We use cookies to help us deliver an effective online service. Cookies are files that store information on your hard drive or your browser. These cookies mean that the Website can recognise that you have previously visited the Website. This allows you to maintain your preferences on the Website and for us to measure the usability of the Website.

You can, should you wish, disable the cookies from your browser and delete all the cookies currently stored on your computer. However, by deleting the cookies you may find you are prevented from taking full advantage of the Website.

You can find out how to delete cookies for your browser by clicking ‘help’ on your browser’s menu. For further information on how to do this, visit www.aboutcookies.org or www.allaboutcookies.org.

We use only session cookies to help identify your computer so we can improve the website’s usability, analyse the use of the website, prevent fraud and improve the security of the website.

We use Google Analytics with anonymous IP to analyse and create reports about the use of our website, this processing does not identify you as an individual. We do not profile our users. We don’t use third party cookies for any commercial purposes.

How to contact us

If you have any questions regarding this Data Privacy Policy or would like any further information regarding how your information is used or shared please contact our Data Protection Officer at:

Sthaler Ltd (FinGo), International House, 1 St Katharine’s Way, London E1W 1UN

Email: [email protected] Web: www.fingo.to

Changes to this data privacy policy

Our Data Privacy Policy may require updates from time to time. Any changes we may make to our Data Privacy Policy in the future will be published on our website www.fingo.to. In addition, registered users will receive an email to inform them of changes.

In the event that you are not in agreement with any modified or revised FinGo Data Privacy Policy updates, then you are able to withdraw from using the service via your FinGo account. In your account you have the possibility to delete your account.