Privacy policy for the app

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 [email protected].

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: [email protected].

Personal data that we process

We collect and process the following personal data:

Device information: the device that you’re using, including information about its operating system, platform and version.
Device ID: we track the unique ID number of your mobile device to communicate with you through push notifications.
Usage details: the date and time you use Curvo’s app, the usage patterns, traffic data and logs.
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 NNEK, the Dutch investment firm who manages your investments. 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 information: serial number and validity dates
h. National register number ("rijksregisternummer" or "numéro de registre national")
i. Mobile number
j. Email
The IBAN of your bank account
Other personal information: any other information that is shared with Curvo via email or via our in-app chat.
Information on your goals, financial knowledge and experience: this information is required for NNEK to match you with the investment portfolio that suits you the best. We ask you these questions during the signup process.
Know-your-customer information: specific questions are asked during the signup process in order for NNEK to comply with the anti-money laundering regulations they are bound to.

How we process your personal data

Let's break down how we process the data mentioned above:

To provide our services to you through the Curvo app.
To communicate with you regarding your investments.
To provide NNEK with the relevant data about you that is required for opening and maintaining an investment account: it’s vital for compliance to the legal frameworks applicable to investment services that NNEK has all the required information about you.
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.
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 any communication. We will not provide your contact details to any third parties for marketing purposes.
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.

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.

Curvo stores your personal data on our IT systems located in the European Economic Area (EEA).

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.

Our retention periods for personal data are based on business needs and legal requirements. We retain your personal data as long as you access and make use of the Curvo app. We will retain your personal data and keep your profile active until the customer relationship with you ends. After it has ended, we will retain your personal data for a limited period of time.

Your rights

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

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.
Rectification: you are free to ask us to change any inaccurate personal data that we process.
‍Erasure: you are free to ask us to delete any personal information that we no longer have a legal ground to process.
Restriction: you can ask us to mark certain personal data as restricted whilst complaints are resolved.
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 [email protected]. 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

We engage with various third-party data processors for the processing of your personal data. We have contracts in place with them that they are bound to. They will hold the data securely and retain it for the period that we instruct.

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 🇺🇸

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 🇧🇪

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 🇪🇺

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 🇺🇸

Skylight (Tilde Inc): this service allows to us to monitor the performance of the app.

Place of processing: United States 🇺🇸

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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 🇫🇷

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 🇪🇺

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 🇩🇪

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 🇺🇸

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 🇺🇸

Changes to the privacy policy

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

This page was last updated on March 15, 2022.