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1. Identification of the Controller

Toqio Fintech Ltd is the Controller of the processing of your personal data in order to provide you the services identified in this website (the “Website”).

Toqio Fintech Ltd, is a company domiciled at Harwood House, 43 Harwood Road,London SW6 4QP with company registration number 11760343. This company has appointed Toqio Fintech S.L. as its representative before the European Union, with domicile at Calle Princesa 5, Madrid, Spain 28005 and CIF number B84576669, and the entity Toqio Kenya Limited with PIN P052089321B and registered office at 90 James Gichuru Road, Nairobi, Kenya.  The entities are hereinafter referred to as ‘Toqio’.

Toqio is committed to the fundamental right to the protection of your personal data and this privacy policy is intended to inform you of your rights.

2. What information will we collect from you?

You should be aware that there are different ways to collect personal data: 

a) The data you provide directly to us. 

We collect information about you when you contact us through the channels provided for this purpose, such as the register or contact form, telephone, e-mail,  when you give us your CV to work with us, when you register with us and set up an account to receive our products/services, when you complete surveys that we use for research when you make payments to us, through this website or otherwise, when you elect to receive marketing communications from us, when you use our services, or when you interact with us in any other way

When you contact us, we may collect personal data, for example: name; surname, job position, contact data or payment data.

All the fields marked with an asterisk (*) in the forms provided will be mandatory, the omission of any of them could lead to the impossibility of us being able to provide the services requested. You must provide truthful information, and it is forbidden to impersonate anyone or to use an alias or anonymous name. 
 
It is essential that you keep your reference data, passwords and access codes generated at all times. You will be solely responsible for the use of your personal account, and in this respect you undertake to make diligent use of this information, not to make it available to third parties, and to inform us, without delay, of its loss or theft. 

In order to ensure that the information provided is always up to date and free of errors, you must notify Toqio as soon as possible of any changes to your personal data by sending an e-mail to dpo@toq.io. 

Likewise, by clicking on the “I accept” (or equivalent) button incorporated in the aforementioned forms, you declare that the information and data you have provided are accurate and truthful.

b) Data obtained indirectly. 

When you browse, different cookies and other tracking devices may be installed on your device, as explained in the cookies policy.

3. What is the source of your data?

We consider all data processed by Toqio to have been provided to us freely and in compliance with data protection legislation. This includes data that we may collect from third parties. 

In the event that the personal data provided is from a third person, you guarantee that you have informed them of this Privacy Policy and have obtained their authorisation to provide the data to Toqio for the purposes indicated above. You also guarantee that the information provided is accurate and up to date, and you are responsible for any direct or indirect damage or harm that may be caused as a result of non-compliance with this obligation.


4. How will we use your personal information and what services will we provide you?

Toqio acts as the controller of the personal data for the following purposes: 

Based on the management of the contractual or pre contractual relationship: 
- To provide you with the services you have requested and to attend to your requests for information. 
- To evaluate the CVs received, carry out the necessary selection tests and, in general, manage the selection processes. 

Based on the existence of a legal obligation of Toqio:  
- Fulfilling our legal obligations
- Facilitate the exercise of your rights.

Based on the existence of a legitimate interest of Toqio:  
- To keep you informed about the products and services of Toqio, as well as to send you news, events and other activities that we carry out in Toqio, by conventional and/or electronic means (e-mails, SMS, …), related to products or services similar to those you have already contracted and that may be of interest to you.
- To carry out periodic reviews of our services and carry out satisfaction surveys in order to evaluate and improve the quality of the service we provide. 
- Keep the CV for up to two years for other selection processes similar to the ones you have applied for.

On the basis of the explicit, free and unequivocal consent that you give us at the time of collecting your data: 
- If applicable, to keep you informed about our own products and services that are not similar to those contracted and those of third parties,, always sent through Toqio, and provided that you have given us your explicit consent to do so, by conventional and/or electronic means (emails, SMS, …), regarding financial and technology sectors.

5. Data processors, Data transfers and international transfers.

All transfers of personal data that we carry out are necessary for the fulfillment of the above-mentioned purposes, or are made in order to fulfill a legal obligation: 


- To public administrations and the administration of justice, and to law enforcement agencies in compliance with the legal obligations applicable to us. 
- Companies providing payment services (banks, payment gateways, etc.), in case the customer makes a payment through the service offered by one of these companies. 
- Companies providing IT services, tools or IT infrastructure on which the services provided by Toqio are based, such as hosting providers, CRMs, emailing service companies, etc. 
- Other companies in the group to which Toqio belongs
- Possible companies interested in acquiring Toqio or part of Toqio
- External auditing companies

In this regard, we inform you that any transfer will be made taking into account all the necessary legal safeguards. We also guarantee that we sign specific contracts with all our service providers as established by the regulations. 

Furthermore, Toqio guarantees that the necessary safeguards are in place to ensure that the data can be transferred securely, either because the provider offers adequate guarantees, through, among others, the EU-US Privacy Framework, the signing of Standard Contractual Clauses of the European Commission, or any of the exceptions contained in the regulations. 

6. Exercising your rights.

We inform you that you will be able to exercise the following rights:

- Rights of access to your personal data to know which ones are being processed and the processing operations carried out with them.
- Right to rectify any inaccurate personal data.
- Right to delete your personal data, where possible. 
- Right to request limitation of the processing of your personal data when the accuracy, legality or necessity of the data processing is in doubt, in which case, we may retain the data for exercise or defense of claims. 
- Right to object to the processing of your personal data when the legal basis that enables us to process them is the legitimate interest. 
- The right to the portability of your data, when the legal basis that enables us to process them is the existence of a contractual relationship or your consent. 
- Right to revoke the consent granted to Toqio.

You can exercise your rights at any time and for free in the following ways: 

- By sending an e-mail to dpo@toq.io email address indicating the right you wish to exercise and your identification data. 

- By sending a written request to the address Harwood House, 43 Harwood Road,London SW6 4QP or Calle de Pedro Muñoz Seca, 6ª Planta 28001, Madrid, Spain or at 90 James Gichuru Road, Nairobi, Kenya, indicating the right you wish to exercise and your personal data.

In addition, when you receive any communication from us, by clicking on the unsubscribe section that will contain that communication, you can unsubscribe from all previously accepted commercial communications. 

We also inform you that you have the right to file a complaint at the Information Commissioner’s Office (ICO) (https://ico.org.uk) for UK residents,  the Office of the Data Protection Commissioner (ODPC) (https://www.odpc.go.ke/) for Kenyan residents and the Spanish Data Protection Agency (www.aepd.es) for EU residents, if you believe that we have breached the applicable data protection legislation regarding the processing of your personal data.  

In addition, we inform you that you can sign up for the Robinson List at www.listarobinson.es: the advertising exclusion system managed by the Spanish Association for the Digital economy (ADIGITAL), where you can register in order to show your opposition to your data being used for the purpose of sending you commercial communications. 

7. Retention periods

We will only keep your data for as long as necessary to provide you with these services. Any of the data you provide us through the channels will be blocked as long as they are no longer necessary to manage the service and will only be available if there is a legal obligation (derived from a request from the appropriate authorities) and when you exercise your rights.

8. Security and confidentiality.

We are dedicated to the security of your information. In order to prevent unauthorized access or unauthorized disclosure of personal data, we have undertaken appropriate technical and physical measures and management processes to safeguard and secure the information we collect from you.

9. Minors

Minors under 18 years of age may not use the services available through the Website.


10. Update of the privacy policy

We do our best to keep our privacy policy fully updated on a monthly basis. If we make changes, they will be clearly identifiable in a conspicuous manner (for example: we may communicate changes to you by email). 

This privacy policy has been reviewed and published as of 27-11-2024. 


11. Spanish government funding disclosure

Project title: Advanced Integration and Data Management Technologies for Fintech Platforms
Project reference: CPP2021-008971
The project CPP2021-008971 is funded by MCIN/AEI /10.13039/501100011033 and by the European Union Next GenerationEU/ PRTR. Toqio aims to become a fully SaaS fintech platform of the future by integrating partners’ fintech capabilities and enabling customers to implement them easily and effectively.
Project CPP2021-008971 funded by:

MICIU+NextG+PRTR+AEI