Privacy Policy
How Euroly collects, uses and protects your personal data, and the rights you have over it.
Who we are
Euroly [legal entity TBC] is the data controller responsible for your personal data. You can reach our Data Protection Officer at dpo@euroly.example.
Data we collect
We collect the following, mapped to our onboarding and account-servicing flows:
- Phone number and OTP verification metadata
- Identity details: name, date of birth, nationality
- Residential address and identity-document images
- Selfie / liveness biometric data (see below)
- Employment and income details
- Device and trusted-device identifiers
- Transaction data and support-chat content
Legal bases for processing
We rely on different legal bases depending on purpose:
- Contract performance — servicing your account
- Legal obligation — AML/CTF, KYC/KYT, sanctions and PEP screening
- Legitimate interest — fraud prevention and security notifications
- Consent — marketing and optional analytics
Biometric data
Our liveness/selfie check processes biometric data, which is special-category personal data under the GDPR. We process it only with your explicit consent, and only to verify your identity, using our KYC vendor [TBC].
International transfers
Where a processor is located outside the EEA, we put appropriate safeguards in place, such as Standard Contractual Clauses.
How long we keep your data
AML records are typically retained for five years after our relationship ends [confirm per regulator]; marketing data is kept for a shorter period and deleted on request.
Your rights
You can exercise the following rights, including through the in-app GDPR request flow:
- Access, rectification and erasure
- Data portability
- Objection to certain processing
- The right to withdraw consent at any time
Automated decision-making
Some KYC approvals and rejections are automated. Under Article 22 of the GDPR you have the right to request human review, which our manual KYC review process provides.
Complaints
You have the right to complain to your supervisory authority [regulator TBC]. We would also welcome the chance to resolve your concern first — please contact us.