Privacy Policy

Introduction

Spring Finance Spółka z o.o. (“Spring Finance,” “we,” “us,” or “our”) is fully committed to protecting your personal data. This Privacy Policy describes our policies and procedures regarding your personal information in line with the EU General Data Protection Regulation (GDPR) 2016/679 and the applicable Polish data protection laws, including the Polish Personal Data Protection Act.

Controller of Personal Data

The Controller responsible for your personal data is:
Spring Finance Sp. z o.o.
Grzybowska 43, 00-855 Warszawa, Poland
Registered at the District Court for the Capital City of Warsaw, XIII Commercial Division of the National Court Register (KRS No. 0001114691),
EU Trademark Registration No: 019093232.
Any inquiries concerning this Privacy Policy can be sent to our Data Protection Officer at: legal@spring-finance.com

Types of Data We Collect

We may process the following personal data:

  • Compliance Data: Data required for regulatory checks (KYC, AML, sanctions screening).
  • Identification Data: Full name, date of birth, national ID documents, etc.
  • Contact Details: Email address, phone number, postal address.
  • Financial Information: Bank details, transaction records, wallet/account details.
  • Technical Data: IP addresses, cookies, device identifiers, and geolocation data.

Purpose and Legal Basis for Data Processing

Your data is processed based on one or more of the following legal grounds according to GDPR (Art. 6):

  • Contractual necessity (Art. 6(1)(b)): To provide financial services including wallets, payments, remittances, and customer support.
  • Legal obligation (Art. 6(1)(c)): Complying with Polish Payment Services Act, AML Act (Ustawa o przeciwdziałaniu praniu pieniędzy oraz finansowaniu terroryzmu), and GDPR.
  • Legitimate interests (Art. 6(1)(f)): Fraud prevention, network security, and internal administration.
  • Consent (Art. 6(1)(a)): Marketing, communications, analytics (consent can be withdrawn at any time).

Sharing and Disclosure of Data

We may disclose your personal data to:

  • Regulatory authorities including the Polish Financial Supervision Authority (KNF) and General Inspector for Financial Information (GIFI) upon legitimate requests.
  • Partners and service providers necessary to deliver financial and technical services.
  • Third parties performing AML, compliance, auditing, and cybersecurity services on our behalf.

Transfers outside the EU/EEA, if necessary, will only be performed under approved safeguards.

Security Measures

Spring Finance applies rigorous data protection measures:

  • Strong encryption methods and secure VPN connections.
  • Multi-factor authentication (2FA).
  • Regular security audits and compliance training.
  • Business continuity and disaster recovery plans including secure off-site backups.

Data Retention Period

We retain personal data only as long as necessary to fulfill contractual, legal, and regulatory requirements. Specifically:

  • Financial transactions and AML-related data: at least 5 years after transaction completion as mandated by Polish AML law.
  • Contractual data: up to statutory limitations (typically 5–6 years in Poland).

Your Data Protection Rights under GDPR

Under GDPR and Polish laws, you have the following rights:

  • sure: Right to request deletion of your personal data under specific circumstances.
  • Restriction of processing: Right to restrict processing of your personal data.
  • Data portability: Right to transfer your data to another controller.
  • Objection: Right to object to data processing.
  • Withdrawal of consent: You can withdraw consent at any time if consent is the basis for processing.
  • Complaint: Right to lodge a complaint with the Polish Data Protection Authority (UODO).

To exercise these rights, please contact: legal@spring-finance.com

Automated Decision-Making and Profiling

We may use automated processing or profiling for AML compliance, fraud detection, and risk assessment. You have the right to request human intervention regarding these decisions.

Use of Cookies

Spring Finance’s website utilizes cookies to enhance user experience and analyze site usage. Cookies are small files stored on your device. You may manage cookies via your browser settings.

Changes to This Policy

This policy may be periodically updated to reflect changes in law or practice. All updates will be posted clearly on our website.

Contact Information

If you have any queries or require clarification regarding this Privacy Policy, please contact us at:
Spring Finance Sp. z o.o.
Grzybowska 43, 00-855 Warszawa, Poland
Email: legal@spring-finance.com