Curvo's privacy policy

Let's dig into our commitments to protect your data

Curvo SRL (“Curvo” or “we”) values the privacy of our users and we strive to protect the privacy and the confidentiality of personal data that we use in connection with our mobile app.

This privacy policy describes how we use your personal data (as a data controller). We collect, use, disclose and otherwise process your personal data where this is necessary for the purposes identified in this privacy commitment and only where permitted by the EU General Data Protection Regulation (GDPR) and local data protection laws (the Data Protection Rules).

We treat your personal data with care. If anything is unclear, don't hesitate to reach out to us at hello@curvo.eu.

Data controller and contact details

Curvo is the data controller in respect of the personal data we receive in connection to our app. Curvo is a private limited liability company and has its registered office address at Quai Paul Verlaine 2, Boîte 2, 6000 Charleroi, Belgium.

Curvo has appointed a data protection officer which is Yoran Brondsema. In case of any questions in relation to our use of your personal data, you can contact our data protection officer using the following email address: yoran@curvo.eu.       

Personal data that we process

We collect and process the following personal data:

  1. Device information: the device that you’re using, including your IP address and information about its operating system, platform and version.
  2. Your contact information: to register and use Curvo, you must have an itsme® account. We collect this information which is then shared directly with our partners at NNEK that handles the discretionary management of your investments. 
  3. Device ID: we process the unique ID number of your mobile device.
  4. Usage details: the date and time you use Curvo’s app, the usage patterns, traffic data and logs.
  5. Your identification and individual details: we receive your information from  your itsme® account. This information is used to conduct the “know your customer” checks by our partners. Curvo does not process or use this information, it’s shared directly with NNEK. The following is collected:
    a. Full name
    b. Date of birth
    c. Place of birth
    d. Gender
    e. Nationality
    f. Address
    g. E-ID info
    h. National Register Number
    i. Mobile number
    j. Email
  6. Other personal information: any other information that is shared with Curvo via email or via our in-app chat.
  7. Information on your financial knowledge and experience: we gather some information from you with a series of questions when you first download the Curvo app.

How we process your personal data

Let’s break down how we use your data and how we follow GDPR guidelines:

  1. To provide the Curvo app to you: we require your personal data in order to provide our services to you. We require this information in order to handle all the communication with regards to your investments.
  2. To provide our partners at NNEK with the relevant data about you which is required for opening a new investment account: it’s vital for compliance that NNEK has all the required information with regards to your data.
  3. To provide NNEK data about you to enable you to deposit money or set up direct debits for your Curvo portfolio: we need to process your bank account information so that your money is sent to your Curvo portfolio account or debited correctly every month.
  4. To provide you with your documents: we need to process your personal data in order to send you your quarterly and annual reports with a breakdown of your investments.
  5. For marketing Curvo: we may use your personal data to contact you about our services. We may push notifications through the app or send you an email. You may opt-out at any time from our newsletters. We will not provide your contact details to any third parties for marketing purposes.
  6. If we change business structure: we may have to disclose your personal data with regards to legal proceedings or investigations from third parties such as public authorities, law enforcement agencies and regulators. We may also provide your personal data to any potential acquirer of or investor in any part of Curvo’s business for the sole purpose of that acquisition or investment. 
  7. To conduct customer due diligence and anti-fraud checks: Curvo shares your personal information directly to NNEK which processes your personal data to conduct credit checks and checks to prevent fraud, money laundering, terrorist financing and to establish whether you are a politically exposed person (PEP). If false or inaccurate information is provided and fraud is identified or suspected, details may be passed to the relevant authorities.

Curvo stores your personal data on our IT systems located in the European Economic Area (EEA). We engage with various data processors for the processing of your personal data which are listed below.

We have contracts in place with our data processors, which means that they cannot do anything with your personal data unless we have instructed them to do so. They will not share your personal data with any organisation (unless legally required to do so) apart from us. They will hold it securely and retain it for the period that we instruct.

How we protect your personal data

Curvo has implemented appropriate technical measures to secure the processing of personal data. These safeguards are designed to keep personal data protected from unauthorized access. This includes the encryption of communications via SSL, encryption of information during storage, firewalls and access controls.

All Curvo team members and contractors, who will have access to personal data on our instructions, will be bound to confidentiality and we use access controls to limit access to individuals that require such access for the performance of their responsibilities and tasks. 

How long we retain your personal data

We collect, use, disclose and otherwise process your personal data that is necessary for the purposes identified in this privacy policy or as permitted by the Data Protection Rules. If we require personal data for a purpose inconsistent with the purposes we identified in this privacy policy, we will notify you of the new purpose and, where required, ask for your consent to process personal data for the new purposes.

We retain your personal data as long as you access and make use of the Curvo app. In any case we will retain your personal data and keep your profile active until you, or under exceptional circumstances, we end our customer relationship with you. After our customer relationship with you has ended, we will retain your personal data for a limited period of time.

Our retention periods for personal data are based on business needs and legal requirements.

Your rights

Under GDPR, you have rights in relation to your personal data:

  1. Right of access: you can obtain confirmation on how your personal data is being processed but also obtain a copy of the personal data we maintain about you.
  2. Rectification: you are free to ask us to change any inaccurate personal data that we process.
  3. Erasure: you are free to ask us to delete any personal information that we no longer have a legal ground to process.
  4. Restriction: you can ask us to mark certain personal data as restricted whilst complaints are resolved.
  5. Portability: you can ask us to transmit the personal data that you have provided to us and we still hold about you to a third-party electronically.

If you wish to exercise one of these rights, please contact our data protection officer directly at yoran@curvo.eu. Simply specify your request and to indicate to which personal data your request relates.

If you’re unhappy with how we respond to you, you have the right to complain to the Belgian Data Protection Authority. You may lodge a complaint (in French, Dutch or German) through their website.

Third parties that we work with

App analytics

Amplitude (Sonalight, Inc.): we collect various information from your device when using Curvo's app. We process trackers and usage data to see how you're using Curvo and improve our service accordingly.

Place of processing: United States 🇺🇸

Privacy Policy

Hosting and infrastructure

Google Cloud Storage (Google LLC): we host data and files that enable Curvo to run and be distributed. We process all the data listed above.

Place of processing: Belgium 🇧🇪

Privacy Policy

Heroku (Salesforce.com, Inc.): they provide us with a ready-made infrastructure to run the Curvo app. We process all the data listed above.

Place of processing: Europe 🇪🇺

Privacy Policy

Infrastructure monitoring

Sentry (Functional Software, Inc.): this service allows to monitor the use and behaviour of our components within the app. It helps us with performance, maintenance and troubleshooting with the app.

Place of processing: United States 🇺🇸

Privacy Policy

Help, chat and communication

Crisp Widget (Crisp IM SARL): this service allows us to chat with you within Curvo's app and also to provide a help centre. We collect browsing and usage data within the app. Note that your conversations with us within the app are all logged.

Place of processing: France 🇫🇷

Privacy Policy

Customer.io (Pearberry Software Inc.): this allows us to communicate with you as a Curvo customer. We collect browsing and usage data within the app. We have the ability to send you notifications through this service and can send you messages and updates through email.

Place of processing: Europe 🇪🇺

Privacy Policy

Pipedrive (Pipedrive OÜ): we use this service as a customer relationship manager (CRM). This allows us to communicate with you as a Curvo customer. It allows us to phone you and log calls. We also have the ability to send you emails through this service.

Place of processing: Germany 🇩🇪

Privacy Policy

Operations

Quota Guard: they are the world’s leading Static IP solution provider for distributed networks and cloud-based applications. QuotaGuard Static uses HTTP and SOCKS5 for outbound service and SSL Termination for inbound service. This service is used for Curvo to "speak" with NNEK's infrastructure.  

Place of processing: Europe 🇪🇺 and United States 🇺🇸

Privacy Policy

Registration and authentication

itsme® (Belgian Mobile ID NV): to use Curvo, you must have an itsme® account. By registering or authenticating yourself on Curvo's app, you allow us to identify you and provide access to our investment service.

Place of processing: Belgium 🇧🇪

Privacy Policy

Tag management

Segment (Segment Inc.): this service helps us manage our customers and debug any issues. It allows us to flow data between the services that we use and improve our app. We process and collect usage data and your information.

Place of processing: United States 🇺🇸

Privacy Policy

Changes to Curvo’s GDPR Privacy Commitment

This page may change and evolve. We will update you with the changes and publish it on Curvo’s website.

This page was updated on September 30, 2021.