Bank Boutique — Privacy Policy

Updated: 12 February 2022


Bank Boutique (hereinafter “BB”) may operate under three legal entities depending on the jurisdictions of its clients:

  • SIA FINTECH SOLUTIONS, registration No. 40203110273, Ranka Dambis 34-59, Riga, Latvia, LV-1048;
  • FINNERA PAYMENTS LTD., registration No. BC1282752, 1090 Homer St., Suite 300, Vancouver, BC V6B 2W9, Canada; or
  • FINPAY PTE. LTD, registration No. 201943772K, 151 Chin Swee Road #02-04A, Manhattan House, Singapore, 169876.

BB respects your privacy and is committed to protecting your personal information or, as otherwise termed, your personal data (hereinafter “personal data”).

This Privacy Policy explains how information about you is collected, used, and disclosed by BB under the General Data Protection Regulation 2016/679 (the “GDPR”) and other applicable laws and sets out the basis on which we will process your personal data when you:

  • Visit and use our website (regardless of where you visit).
  • Apply with us to receive our service of either establishing, selling or purchasing a company with license to provide payment services, as well as our legal services, accounting service, expansion support services, bank account opening services or other services, as applicable (the “Services”).
  • Conclude with us an Agreement to receive our Services of either establishing or purchasing a company with license to provide payment services (the “Banks”).

Applicable law

The Privacy Policy is subject to, but not limited to, the applicable laws of the Republic of Latvia, Canada or Singapore, depending on the legal entity (indicated above), which will be selected to provide the Services. In either case, the provisions of GDPR shall be applicable and prevail, if personal data of individuals within the EU/EEA will be processed.

This Privacy Policy also informs you about:

  • How we will handle and look after your personal data.
  • Our obligations in regard to processing your personal data responsibly and securely.
  • Your data protection rights as a data subject.
  • How the applicable laws protects you.

1. Definitions

Set out below are key definitions of certain data protection terms which appear in this Privacy Policy.

1.1. “Data subjects” means individuals (i.e. natural persons) about whom we collect and process personal data.

1.2. “Data controller” or “controller” means a person who either alone or jointly or in common with other persons processes any personal data, or has control over, or authorizes the processing of any personal data, but does not include a data processor.

1.3. “Data processor” or “processor” means any entity or individual that processes data on our behalf and on our instructions (we being the Data controller), but does not include an employees of the Data controller.

1.4. “Personal data” means any information in respect of commercial transactions, which:

  1. A) is being processed wholly or partly by means of equipment operating automatically in response to instructions given for that purpose;
    B) is recorded with the intention that it should wholly or partly be processed by means of such equipment; or
    C) is recorded as part of a relevant filing system or with the intention that it should form part of a relevant filing system, that relates directly or indirectly to a data subject, who is identified or identifiable from that information, or from that and other information in the possession of a data user, including any sensitive personal data and expression of opinion about the data subject.

For the avoidance of doubt, Personal data means data relating to a living individual (i.e. natural person) who can be identified from the data (information) we hold or possess.

This includes, but is not limited to, your name and surname (including maiden name where applicable), address, date of birth, nationality, gender, civil status, tax status, identity card number & passport number, contact details (including mobile and home phone number and personal email address), photographic image, bank account details, emergency contact information as well as online identifiers.

The term “personal information”, where and when used in this Privacy Policy, shall be taken have the same meaning as personal data.

1.5. “Processing”, in relation to personal data, means collecting, recording, holding or storing the personal data or carrying out any operation or set of operations on the personal data, including the
A) organization, adaptation or alteration of personal data; (b) retrieval, consultation or use of personal data;
B) disclosure of personal data by transmission, transfer, dissemination or otherwise making available; or
C) alignment, combination, correction, erasure or destruction of personal data.

For avoidance of doubt, Processing means any activity that involves use of personal data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including, organizing, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

1.6. Note that personal data does not include information relating to a legal person (for example, a company or other legal entity). In that regard, information such as a company name, its company number, registered address and VAT number does not amount to personal data in terms of the GDPR. Therefore, the collection and use of information strictly pertaining to a legal person does not give rise to data controller obligations at law. Naturally, we will still treat any and all such information in a confidential and secure manner.

2. Role of BB

2.1. BB processes your personal data in an appropriate and lawful manner, in accordance with all relevant laws of the jurisdictions in which we operate. This Privacy Policy aims to give information on how BB collects and processes your personal data when we are providing Services to you.

2.2. It is important that you read this Privacy Policy together with any other privacy notice or policy which we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Privacy Policy supplements other notices and is not intended to override them.

2.3. It is imperative that the personal data we hold about you is accurate and current at all times. Otherwise, this will impair our ability to provide you with the Services. Please keep us informed if your personal data changes during your relationship with us.

2.4. Our webpage may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices, statements or policies, therefore we encourage you to read the privacy policy of every website you visit.

3. Personal data that we collect

3.1. Personal data, or personal information, means any information about an individual from which that person can be identified (as stated above). It does not include data where the identity has been removed (anonymous data). In the course of your relationship with us, we may collect, use, store and transfer different kinds of personal data about you which we have grouped together.

3.2. We collect information you provide directly to us. For example, we collect information when you apply to receive our Services, register on the website, apply for a job or otherwise communicate with us. The types of information we may collect include your name, social security number or other government ID number, date of birth, email address, postal address, phone number and any other information you choose to provide.

3.3. We collect the below categories of Personal data of our Clients, which is required for us to provide Services:

  1. A) Identity Data — includes your first name, maiden name (where applicable), last name, address, username or similar identifier, marital status, title, nationality, date of birth, gender, photograph, identity card and/or passport number..
    B) Contact Data — includes your billing address, email address and contact number (telephone and/or mobile).
    C) Financial Data — includes your bank account and payment details (if applicable).
    D) AML / KYC Data — includes the following due diligence / KYC information and documentation about you:
  • copy of ID card or passport;
  • proof of residence (e.g. utility bill);
  • KYC database checks;
  • fraud database check, and
  • any documentation or information which we may, from time to time be required to collect to ensure compliance with any applicable legislation (including applicable foreign laws) and global AML/KYC practices; and/or otherwise be mandated to collect by any competent authority or law enforcement agency (local or foreign).
  1. E) Marketing and Communications Data — includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    F) Portfolio Data — includes details about your assets and Banks, to the extent required for the provision of Services.
    G) Enhanced KYC Data — applies in respect of instances mandated by our AML-KYC policies, which would include, amongst other scenarios, situations where a higher risk of money laundering and funding of terrorism has been identified.

Sensitive Personal data

3.4. We do not knowingly collect Special Categories of Personal Data (or Sensitive Personal Data) about you. Should we receive sensitive personal data about you, we will only process that data where there is a legitimate reason to do so and, in all circumstances, in accordance with our obligations at law and under the appropriate safeguards.

3.5. We collect and process AML / KYC Personal data in order to be able to:

  1. A) Comply with legal and regulatory obligations, as applicable.
    B) Conduct our AML and KYC checks, and other due diligence checks on you.
    C) Verify your identity or claimed identity and identify and/or verify your source of funds and source of wealth, as appropriate.
    D) Ensure provision of Services as this information is usually required by the regulators of respective jurisdiction in which you wish to establish or purchase a Bank.
    E) Take an informed decision on whether we want to enter into a customer relationship with you, and, if positive, to conduct initial and ongoing screening and monitoring and (iv) to comply with any legal or regulatory obligation that we may have and/or any Court, regulatory or enforcement order that may be issued upon us.


4.1. Concluding an Agreement — we will ask you to provide us with your Identity, Contact, Financial and AML/KYC Data when you apply for provision of Services. You provide these personal details and information to us, which we collect and process, when you fill in and submit our application form (together with other related forms) and complete our required application steps.

4.2. Direct interactions — You may also give us your Identity, Contact, Financial, AML/KYC Data and Transaction Data by by corresponding with us by post, phone, e-mail or otherwise. This includes personal data that you provide when you, as applicable:
A) apply for provision of Services;
B) update or edit your details;
C) contact us with complaints or queries;
D) report issues;
E) submit the (additional or supplementary) AML / KYC Data that we may request from you;
F) request marketing to be sent to you;
G) participate in a survey; or
H) provide us with feedback.


4.3. We may also obtain information from other sources and combine that with information we collect through our Services. For example, we may collect information about you from third parties, including but not limited to social media platforms and publicly available sources.

4.4. We may also receive Technical data about you from various third parties and public sources, as set out below:

  • analytic providers such as Google Analytics;
  • advertising networks;
  • search information providers.

4.5. Identity, Contact, AML / KYC Data — from publicly available sources such as public court documents, the corporate registers of the respective  jurisdictions, and from electronic data searches, online KYC search tools (which may be subscription or license based), anti-fraud databases and other third party databases, sanctions lists, outsourced third-party KYC providers and from general searches carried out via online search engines (e.g. Google).


5.1. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular and count visits, manage the registration process for accounts, remember your site preferences, retain certain information to process orders for exchange transactions, and retain information to provide you with support.

5.2. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that choosing to remove or reject cookies could affect the availability and functionality of our Services.

5.3. You can prevent the setting of cookies by adjusting the settings on your browser (see your browser Help for how to do this). Be aware that disabling cookies may affect the functionality of this and many other websites that you visit. Disabling cookies will usually result in also disabling certain functionality and features of the website. Therefore it is recommended that you do not disable cookies.

5.4. In some special cases we also use cookies provided by trusted third parties.


6.1. We collect and use your personal data only with the purpose of providing the Services and only to the extent required for us to be able to provide the Services. Your personal data shall be collected and used in strict compliance with the provision of the GDPR. Most commonly, we will use your personal data in the following circumstances:

  1. A) Where we need to perform the agreement we are about to enter into or have entered into with you in respect of your client relationship with us.
    B) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
    C) Where we need to comply with a legal or regulatory obligation.


6.2. We will only be using your personal data for the provision of Services and ensuring our compliance with the local applicable compliance laws regulations.

6.3. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

6.4. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

6.5. Marketing — where permitted by applicable law and in accordance with your advertising / marketing preferences, you may receive marketing communications from us (which may consist of newsletters, industry updates, mailshots, publications, promotional materials and/or information about our events) where:
A) you provide your consent to receiving such marketing material;
B) you have an ongoing commercial or contractual relationship with us;
C) provided you have not opted out of receiving marketing from us (see Your right to object below).

6.6. Third-party marketing — we will get your express opt-in consent before we share your personal data with any third parties (including our associated or related corporate entities) for marketing purposes.

6.7. Opting out — you can ask us to stop sending such advertising and marketing communications at any time by:
A) following the opt-out links on any marketing message sent to you;
B) contacting us at any time at

6.8. Where you opt out of receiving such communications, this will not apply to personal data processed or provided to us as a result of your entry into an agreement with us.


6.9. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose, or we are obliged to process your data by applicable laws or court or other enforceable orders.

  1. C) If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at

6.10. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without the need to obtain your consent, in compliance with the above rules, where this is required or permitted by law.


7.1. We may have to share your personal data with the parties set out below for the purposes of provision of Services:
A) External third parties.
B) Suppliers and external agencies that we engage to process information on our and/or your behalf, including to provide you with the information and/or materials that you have requested.
C) Our subsidiaries, associates and agents where necessary to facilitate your relationship with us.
D) Regulators, law enforcement agencies, and other authorities who require reporting of processing activities, or may request information from us, in terms of applicable law and in certain circumstances.
E) Professional advisers such as consultants, bankers, professional indemnity insurers, brokers and auditors.
F) Other organizations where exchange of information is for the purpose of fraud protection or credit risk reduction.
G) Debt recovery agencies who assist us with the recovery of debts owed to us.
H) Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets (successors in title). Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Notice.

7.2. We require all third parties to respect the security of your personal data and to treat it in accordance with the law (including applicable data protection and privacy law). We do not allow our third party business partners or service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our documented instructions. Furthermore, these third parties access and process your data on the basis of strict confidentiality and subject to the appropriate security measures and safeguards.

7.3. We may also disclose your data:
A) if we are under a duty to disclose or share your personal data to comply with any legal obligation, judgment or under an order from a court, tribunal or authority, or
B) if we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of BB or others, or
C) in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company; or
D) if we have your consent or at your direction.

7.4. We may also share aggregated or de-identified information, which cannot reasonably be used to identify you.


8.1. While no online or electronic system is guaranteed to be secure, we take reasonable measures to help protect information about you from loss, theft, misuse, and unauthorized access, disclosure, alteration and destruction.

8.2. We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

8.3. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


9.1. You consent to the transfer of data to entities outside the Republic of Latvia, Canada or Singapore, as applicable, for us to able to provide the Service, including to entities outside the European Economic Area, if such transfer is required for the provision of Services. We undertake to take every precaution and provide technological safeguards to protect and keep secure your personal data.

9.2. Such transfers may take place to countries for which there is no adequacy decision pursuant to Article 45 of the GDPR and may lack EU-type privacy protections.


10.1. Please note that we consider our relationship with you to be an ongoing and continuous customer relationship, until terminated.

10.2. We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for (i.e. the ongoing service provision) and, thereafter, for the purpose of satisfying any legal, accounting, tax, AML and reporting requirements or obligations to which we may be subject and/or to the extent that we may also need to retain your personal data to be able to assert, exercise or defend possible future legal claims against or otherwise involving you.

10.3. In the event that BB’s activities are held by competent legislators and regulators to amount to a ‘relevant activity’ at law, we will retain your AML and KYC Data for the duration of your business relationship with us and for a further period of at least five years following its termination. We may need to revise this AML retention period in the event of applicable legal or regulatory developments, but we will notify you if this is the case at the time.

10.4. Whenever and to the extent possible, we anonymize the data which we hold about you when it is no longer necessary to identify you from the data which we hold about you (anonymous data).

10.5. In some circumstances, we may even anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice.


11.1. Under the GDPR and other applicable laws, you remain the right to:

  1. A) Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  2. B) Request correction or rectification of your personal data. This enables you to have any incomplete or inaccurate data we hold about you corrected and/or updated, though we may need to verify the accuracy of the new data you provide to us. As mentioned, it is in your interest to keep us informed of any changes or updates to your personal data which occur during the course of your relationship with us.
  3. C) Right to information. When collecting and processing personal data about you from publicly accessible or third party sources. When this takes place, we will inform you, within a reasonable and practicable timeframe, about the third party or publicly accessible source from which we have collected your personal data.
  4. D) Request erasure of your personal data. This enables you to ask us to delete or remove personal data where:
  • there is no good reason for us continuing to process it;
  • you have successfully exercised your right to object to processing (see below);
  • we may have processed your information unlawfully; or
  • we are required to erase your personal data to comply with local law.

Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. These may include instances where continued processing is necessary in order to be able to:

  • comply with a legal or regulatory obligation to which we are subject; or
  • establish, exercise or defense of legal claims.
  1. E) Object to processing of your personal data. When we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  2. F) Request restriction of processing your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • if you want us to establish the data’s accuracy;
  • where our use of the data is unlawful but you do not want us to erase it;
  • where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
  • you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  1. G) Right to withdraw consent. You have the right to withdraw your consent at any time when we are relying on consent to process your personal data. This will not however affect the lawfulness of any processing which we carried out before you withdrew your consent. Any processing activities that are not based on your consent will remain unaffected.
  2. H) Right to lodge a complaint. You reserve the right to lodge a complaint in relation to processing of your personal data as applicable to either:

1) The Data State Inspectorate of the Republic of Latvia;

2) The Office of the Privacy Commissioner of Canada; or

3) Personal data protection Commission of Singapore.

  1. D) If you wish to exercise any of the rights set out above, please contact us at

Kindly note that none of these data subject rights are absolute and must generally be weighed against our own legal obligations and legitimate interests. If a decision is taken to override your data subject request, you will be informed of this by our data protection team along with the reasons for our decision.

11.2. You are entitled to exercise your rights mentioned above free of charge, except in cases if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in the above circumstances.

11.3. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other data subject rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

11.4. We try to respond to all legitimate requests within the period of one month from receipt of the request. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

12. Changes to Privacy Policy

12.1. We may change this Privacy Policy from time to time, particularly where we need to take into account and cater for any business developments and/or legal or regulatory developments under applicable law.

12.2. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

12.3. If you have any questions regarding this Privacy Policy, or if you would like to send us your comments, please contact us today or alternatively write to us using the details on our website or email us to

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