Privacy Policy

Last Updated: January 9, 2025

1. Introduction

Finveri ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and protect your information when you use our online platform and services.

We are a data controller under UK GDPR and comply with the Data Protection Act 2018 and the UK General Data Protection Regulation (UK GDPR).

2. Information We Collect

2.1 Information You Provide Directly

Account Information: Username, email address, display name, profile information
Identity Verification: Government-issued ID, proof of age documents (when required)
Profile Content: Photos, videos, bio, interests, preferences, and other content you upload
Communication Data: Messages, comments, and other communications you send through our platform
Payment Information: Billing details (processed by third-party payment providers)

2.2 Information We Collect Automatically

Usage Data: How you interact with our platform, features used, time spent
Device Information: IP address, browser type, operating system, device identifiers
Location Data: General geographic location (country/region level)
Technical Data: Log files, cookies, and similar tracking technologies

2.3 Information from Third Parties

Payment Processors: Transaction data from CCBill and Paxum
Social Media: If you choose to connect social media accounts
Analytics Providers: Aggregated usage statistics and performance data

3. How We Use Your Information

3.1 Service Provision

To provide and maintain our platform and services
To process payments and manage subscriptions
To verify your identity and age
To enable communication between users
To provide customer support

3.2 Legal Compliance

To comply with applicable laws and regulations
To respond to legal requests and court orders
To protect our rights and interests
To prevent fraud and ensure platform security

3.3 Platform Improvement

To analyse usage patterns and improve our services
To develop new features and functionality
To conduct research and analytics
To personalise your experience

3.4 Communication

To send important service updates and notifications
To provide customer support
To send marketing communications (with your consent)
To notify you of changes to our policies

4. Legal Basis for Processing (UK GDPR)

We process your personal data based on the following legal grounds:

Contract Performance: To provide our services under our Terms of Service
Legitimate Interest: To improve our services, prevent fraud, and ensure platform safety
Consent: For marketing communications and optional features
Legal Obligation: To comply with applicable laws and regulations
Vital Interests: To protect users from harm or illegal activities

5. Data Sharing and Third Parties

5.1 Payment Processors

We share payment-related information with:

CCBill: For payment processing and fraud prevention
Paxum: For alternative payment processing

These providers have their own privacy policies and data protection measures.

5.2 Service Providers

We may share data with trusted third-party service providers who assist us in:

Hosting and infrastructure services
Analytics and performance monitoring
Customer support tools
Content delivery networks

5.3 Legal Requirements

We may disclose your information when required by law or to:

Comply with legal processes or court orders
Respond to government requests
Protect our rights, property, or safety
Prevent fraud or illegal activities

5.4 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred to the new entity.

6. Data Security

6.1 Security Measures

We implement appropriate technical and organisational measures to protect your data:

Encryption of data in transit and at rest
Regular security assessments and updates
Access controls and authentication systems
Staff training on data protection

6.2 Data Breach Response

In the event of a data breach that poses a risk to your rights and freedoms, we will:

Notify the Information Commissioner's Office (ICO) within 72 hours
Inform affected users without undue delay
Take immediate steps to contain and remediate the breach

7. Data Retention

We retain your personal data for as long as necessary to:

Provide our services to you
Comply with legal obligations
Resolve disputes and enforce agreements
Maintain security and prevent fraud

7.1 Retention Periods

Data Type	Retention Period
Account Data	While account is active and for 7 years after closure
Payment Data	7 years for accounting and tax purposes
Communication Data	2 years after the conversation ends
Analytics Data	Aggregated and anonymised data may be retained indefinitely

8. Your Rights (UK GDPR)

Under UK GDPR, you have the following rights:

8.1 Right of Access

Request copies of your personal data
Receive information about how we process your data

8.2 Right to Rectification

Correct inaccurate or incomplete personal data
Update your account information

8.3 Right to Erasure ("Right to be Forgotten")

Request deletion of your personal data
Subject to certain legal and operational limitations

8.4 Right to Restrict Processing

Limit how we use your personal data
In certain circumstances, we may continue processing with your consent

8.5 Right to Data Portability

Receive your data in a structured, machine-readable format
Transfer your data to another service provider

8.6 Right to Object

Object to processing based on legitimate interests
Opt out of direct marketing communications

8.7 Rights Related to Automated Decision-Making

Request human review of automated decisions
Receive information about automated processing

9. Cookies and Tracking Technologies

9.1 Types of Cookies

We use the following types of cookies:

Essential Cookies: Necessary for platform functionality
Analytics Cookies: Help us understand usage patterns
Marketing Cookies: Used for targeted advertising (with consent)
Preference Cookies: Remember your settings and preferences

9.2 Cookie Management

You can control cookies through:

Your browser settings
Our cookie preference centre
Third-party opt-out tools

For detailed information, see our Cookie Policy.

10. International Data Transfers

10.1 Data Transfers

Your data may be transferred to and processed in countries outside the UK. We ensure appropriate safeguards are in place, including:

Adequacy decisions by the UK government
Standard Contractual Clauses (SCCs)
Binding Corporate Rules
Certification schemes

10.2 US Data Transfers

When transferring data to the US, we rely on:

Adequacy decisions where applicable
Standard Contractual Clauses
Additional safeguards as required

11. Children's Privacy

Our platform is not intended for individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.

12. Changes to This Privacy Policy

We may update this Privacy Policy to:

Reflect changes in our platform
Address new types of violations
Comply with legal requirements
Improve community safety

We will notify users of significant changes through:

Platform notifications
Email updates
Website announcements

13. Data Protection Officer

We have appointed a Data Protection Officer (DPO) who can be contacted at:

Email: dpo@finveri.com
Address: [Company Address]

14. Supervisory Authority

You have the right to lodge a complaint with the Information Commissioner's Office (ICO):

Website: https://ico.org.uk
Phone: 0303 123 1113
Address: Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF

15. Contact Information

For questions about this Privacy Policy or your data rights, please contact us at:

Email: privacy@finveri.com
Address: [Company Address]
Phone: [Contact Number]

This Privacy Policy is effective as of the last updated date and supersedes all previous versions.