Privacy Policy

Last updated:Jul 11, 2019

This Privacy Policy governs the manner in which FineToken OÜ(Company) collects, uses, maintains and discloses information collected from users (each, a “User”) of the website (“Site”).

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual, such as name and email address. We may collect Personal Information from Users when they voluntarily provide it to us in a variety of ways, including, but not limited to, when Users visit our Site, subscribe to our newsletter, fill out a Site form, or in connection with other activities, services, features or resources we make available on our Site. Users may visit our Site without providing Personal Information. Users can always refuse to supply Personal Information; however, doing so may prevent them from engaging in certain Site-related activities.

How We Use Personal Information

FineToken OÜ may use Personal Information for the following purposes:

•To respond to a User’s inquiries or fulfill a User’s requests and provide related customer service.

•To send administrative information to a User, such as changes to our terms, conditions and policies.

•To personalize the User’s experience on our Site.

•For our business purposes, such as data analysis, audits, fraud monitoring and prevention, developing new products and services, improving our Site, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities.

•To send periodic newsletters, via email, if the User has opted in to receive our newsletters.

If at any time the User would like to unsubscribe from receiving future marketing emails, he or she can do so by following the unsubscribe instructions contained in each such email.

Disclosure of Personal Information

We may disclose Personal Information to our third-party service providers that provide services such as website hosting, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.

We may also use and disclose your Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, which may include laws outside your country of residence, to respond to requests from public and government authorities, which may include authorities outside your country of residence, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others. In addition, we may use or disclose your Personal Information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

Other Information

“Other Information” is information that does not reveal a User’s specific identity or does not directly relate to an identifiable individual, such as:

• Browser and device information

• Information collected through cookies, pixel tags and other technologies

• Demographic information and other information provided by a User that does not reveal his or her specific identity

• Information that has been aggregated in a manner that does not reveal Users’ identities

If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy.

We may collect Other Information about Users whenever they interact with our Site. Other Information may include the browser name, the type of computer and technical information about Users means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.

We and our service providers may collect Other Information in a variety of ways, including:

• Through your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version. We use this information to ensure that the Site functions properly.

• Using cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Site, pages visited, language preferences and other traffic data. We use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize a User’s experience. We also gather statistical information about the use of the Site in order to continually improve its design and functionality, understand how it is used and assist us with resolving questions about it. We do not currently respond to browser do-not-track signals. If a User does not want information collected through cookies, most browsers allow a User to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. If, however, a User does not accept cookies, he or she may experience some inconvenience in the use of the Site.

• Using pixel tags and other similar technologies: Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of Site users and email recipients, measure the success of our marketing campaigns and compile statistics about the use of the Site and response rates.

• Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of the Site and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. A User can learn about Google’s practices by going to and opt out of them by downloading the Google Analytics opt-out browser add-on, available at

We also use Hotjar’s heat mapping services to display the areas of a Site page where Users most frequently move the mouse or click. These services help us to monitor and analyze web traffic. A User can opt out of Hotjar’s services by going to

•IP Address: Your IP address is automatically assigned to a User’s computer by his or her Internet Service Provider. An IP address may be identified and logged automatically in our server log files whenever a User accesses the Site, along with the time of the visit and the pages were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services. We use IP addresses for purposes such as calculating usage levels, diagnosing server problems and administering the Site. We may also derive your approximate location from your IP address.

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.

Third-Party Services

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any website or service to which the Site links. The inclusion of a link on the Site does not imply endorsement of the linked site or service by us.

How We Protect Your Personal Information

We seek to use appropriate data collection, storage and processing practices and security measures designed to protect against unauthorized access, alteration, disclosure or destruction of Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below. 

Jurisdiction and Cross-Border Transfer

The Site is controlled and operated by us from Estonia and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of Estonia. A User’s Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and, by using the Site, a User consents to the transfer of information to countries outside of the User’s country of residence, including Estonia, which may have data protection rules that are different from those of the User’s country. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access a User’s Personal Information.

Changes to this Privacy Policy

FineToken OÜ may update this Privacy Policy at any time. When we do, we will revise the updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about our information practices. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Your Acceptance of this Privacy Policy

By using our Site, you signify your acceptance of this Privacy Policy. If you do not agree to this policy, please do not use our Site.

Questions? please contact us at: [email protected]