Privacy policy
A draft, pending a lawyer's review.
Last updated To be confirmedThe date of publication.
Who is responsible for your data
Fastflow Finance OÜ is the controller of the personal data described here.
Registry code 16845923, Estonian e-Business Register.
Sõle tn 14, 10611 Tallinn, Estonia.
Email: info@fastflowfinance.eu.
What this policy covers
This policy covers this website, its contact form and its statistics. If you go on to sign an agreement with us, we give you a separate notice before that.
The website sets no cookies. See the cookie policy.
What we receive through the contact form
When you send the form, we receive:
- your name
- your email address
- your phone number, if you give one
- the topic of your message
- for a business enquiry, the company name or registry code, and the amount and what it is for, if you give them
- your message, and anything you write in it
We also record:
- the address of the page you sent the form from
- the language of that page
- the time
- a random reference for your message, so that it is not delivered twice
We need your name and email address to answer. For a business enquiry we also need the company name or registry code, and for a general question your message. Your phone number, the amount, what it is for and the message on a business enquiry are optional. No law requires you to send the form.
Please do not send identity documents, bank details or data about other people that we do not need.
Why we use it, and on what legal basis
To answer you when you write for a company, or with a general question. This is our legitimate interest in answering the messages we receive and in talking to companies that ask for financing (GDPR article 6(1)(f)).
To answer in the right language and to see which page you wrote from. We use the page, its language and the time for this. This is our legitimate interest in answering the messages we receive (GDPR article 6(1)(f)).
To protect the form from abuse and keep it working. Our server uses your IP address to count the messages sent from it, and refuses more than 3 in 10 minutes. The count stays in the server's memory, and your IP address does not go to the contact relay with your message. This is our legitimate interest in keeping the form secure (GDPR article 6(1)(f)).
You may object to any use based on legitimate interest. See "Your rights".
We make no automated decisions about you from the contact form.
We do not use the form for marketing and we send no newsletters. If that changes, we will ask for your consent first.
To be confirmedThat no marketing is planned.
Website statistics
We measure visits to this website with Rybbit, open-source software installed at st.eclectie.ch.
For each page you open, Rybbit records:
- the address of the page, without query parameters
- the title of the page
- the page you came from
- your browser and operating system, with their versions
- the type of your device and the size of its screen
- your browser's language
- an approximate location (country, region, city, time zone and coordinates) and your network operator, worked out from your IP address
- if you click a link to another website, the link's address and text
To tell automated traffic from real visitors, Rybbit's script checks a few things about your browser and sends the result as two numbers. Rybbit's server also looks at the request headers, the network your IP address belongs to and how often requests arrive.
To count visitors, Rybbit's server makes a short identifier from a hash of your IP address and the names of your browser, operating system and device. Rybbit does not store the IP address itself. The identifier is not linked to a name or an account. It stays the same while your IP address and browser stay the same, and it is the same on other websites measured with this installation. No profiles are built across those websites.
Rybbit sets no cookies and stores nothing on your device.
Statistics do not go to Google or to advertising networks, and we do not use them for advertising.
We use statistics to see which pages people read and where the website needs work. This is our legitimate interest (GDPR article 6(1)(f)). To be confirmedA lawyer confirms this basis.
You may object by writing to info@fastflowfinance.eu. If your browser sends Global Privacy Control or Do Not Track, nothing is recorded. You can also block st.eclectie.ch with a browser extension, and the website keeps working.
Who receives your data
- To be confirmedThe name and country of the company that runs the contact relay. It stores your message and delivers it to us by email. It acts on our instructions.
- To be confirmedThe name and country of the company that hosts this website.
- To be confirmedThe name and country of the company that runs the website statistics service.
- To be confirmedThe name and country of the provider of the info@fastflowfinance.eu mailbox.
- Our professional advisers, when we need their advice. They keep it confidential.
- Authorities and courts, when the law requires it.
We do not sell your data.
To be confirmedWhether we keep this data in the European Economic Area. If a provider is outside it, the country, the safeguard under GDPR chapter V and how to get a copy of that safeguard.
How long we keep it
- Your enquiry and what we record with it: To be confirmedThe period we keep it for. Then we delete it, unless it leads to an agreement.
- Backup copies: To be confirmedHow much longer they last.
- Your IP address in the form's rate limit: in the server's memory only, cleared within about an hour or when the server restarts.
- Server logs: To be confirmedWhat they hold and how long we keep them.
- Website statistics: To be confirmedHow long we keep them.
If you go on to an agreement
Before we enter an agreement, the law requires us to identify you, your representative and your beneficial owners. We also ask about the purpose of the agreement and the source of the money. This comes from the Estonian Money Laundering and Terrorist Financing Prevention Act.
We use this data only to prevent money laundering and terrorist financing. We do not use it for marketing.
We keep it for five years after the relationship ends. We keep contracts and accounting documents for seven years, as the Accounting Act requires.
You receive a separate notice before the relationship starts.
Data we get from other sources
If your enquiry goes on to an assessment, we may check public sources about you or your company.
To be confirmedWhich sources, for example the e-Business Register, sanctions lists, lists of politically exposed persons, any credit information provider.
Someone else may name you in a message to us. We handle that data as part of the message and for the same period.
To be confirmedWhether any decision on financing is made automatically. If yes, how it works and the right to a human review.
Children
This website is not aimed at children.
Your rights
You can ask us to:
- show you the data we hold about you and give you a copy
- correct it
- delete it
- limit its use
- send data you gave us to you or another controller, where the use rests on a contract or on consent
You can object to any use based on legitimate interest. Where a use rests on your consent, you can withdraw it at any time.
Write to info@fastflowfinance.eu. We answer within one month, free of charge. We may ask you to confirm who you are. The law may require us to keep some data even if you ask us to delete it.
Complaints
Please tell us first if you can. You may also complain to the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon), Tatari 39, 10134 Tallinn, info@aki.ee, aki.ee, or to the data protection authority where you live or work. You may also go to court.
Changes
If this policy changes, we publish the new version here with its date.