I. Scope and Definitions
Service or “Restro”
All the services provided by Restro.io including visiting/registering/etc.
Personal Data means the data about a living individual who can be identified by this data (or from other information either in our possession or likely to come into our possession).
Usage Data is the data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
Cookies are small pieces of data stored on your device (computer or mobile device).
Data Processors (or Service Providers)
Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more efficiently.
Data Subject (or User/Customer)
Data Subject is any living individual who uses our Service and is the subject of Personal Data.
Information Collection And Use
We collect several different types of information for various purposes to provide to and improve Restro for you. Types of Data Collected:
While using Restro, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:
- Email address
- First name and last name
- Address, State, Province, ZIP/Postal code, City
- Cookies and Usage Data
- ID document etc.
We may also collect information how LendaBit is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our service that you visit, time and date of your visit, time spent on those pages, unique device identifiers and other diagnostic data.
Tracking & Cookies Data
III. Use of Data
Restro uses the collected data for various purposes:
- To provide and maintain Restro
- To notify you about changes introduced to Restro
- To allow you to participate in interactive features of Restro when you choose to do so
- To provide customer care support
- To provide analysis or valuable information so that we can improve the Restro
- To monitor the usage of the Restro
- To detect, prevent and address technical issues
- To provide you with news, special offers and general information about other goods, services and events which we offer and that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.
IV. Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)
Restro may process your Personal Data because:
- We need to perform a contract with you
- You have given us permission to do so
- The processing is in our legitimate interests and it’s not overridden by your rights
- To comply with the law
V. Retention of Data
Restro will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a short period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obliged to retain this data for longer time periods. By registering on Restro you are giving a consent for us to retain your Personal Data.
VI. Transfer of Data
VII. Disclosure of Data
Restro may disclose your Personal Data in the good faith belief that such action is necessary:
- To comply with a legal obligation
- To protect and defend the rights or property of Restro or its customers
- To prevent or investigate possible wrongdoing in connection with Restro
- To protect the personal safety of users of Restro or the public
- To protect against legal liability.
VIII. Security of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
IX. “Do Not Track” Signals under California Online Privacy Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
X. Your Data Protection Rights under General Data Protection Regulation (GDPR)
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Restro aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. However, we imply the same rights to all our users from any jurisdiction.
If you wish to be informed what your Personal Data we hold and if you want it to be removed from our systems, please contact us. We will do our best to do so as soon as possible unless it is currently not possible due to a service contract you concluded via Restro. In this case, we will fulfil your request after all the obligations under such contract are fulfilled or expired.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you. Whenever is possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
- The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
- The right to object. You have the right to object to our processing of your Personal Data.
- The right of restriction. You have the right to request us to restrict the processing of your personal information.
- The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
- The right to withdraw consent. You also have the right to withdraw your consent at any time where Restro relied on your consent to process your personal information (with the exceptions mentioned in Terms and Condition due to the obligations occurred from service agreements).
Please note that we may ask you to verify your identity before responding to such requests.
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local Data Protection Authority in the European Economic Area (EEA).
XI. Service Providers
We may employ third party companies and individuals to facilitate Restro (hereinafter referred to as the “Service Providers”), to provide Restro on our behalf, to perform Restro -related services or to assist us in analysing how Restro is used. These third parties have access to your Personal Data to the extent of performance of these tasks on our behalf and are obliged not to disclose or use it for any other purpose.
XII. Links To Other Sites
XII. Children’s Privacy
Restro does not address anyone under the age of 18 (hereinafter referred to as “Child” or “Children”). We do not knowingly and intentionally collect the personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take measures to remove that information from our servers.
XIII. Establishing contact with us and with other customers
Restro enables you to establish a contact with us. It is possible, for example, by sending an email to us, or any message via the permitted message service (according to the Terms and Conditions). The information you provide when contacting us is stored to process the request and, where appropriate, for the subsequent correspondence.
We do not disclose your personal information to any other Restro customer unless it is necessary. You agree that, in the course of generating and managing your service contracts, and operating the Restro account, it may be required to send to Payment Processors, as the case may be, certain transactional information (for example, a unique identifier, a transaction amount and card verification details etc.); and your full name, post code address, or payment details, unless a non requirement agreement was made in advance. We will not be liable for any use or misuse of the transactional data by Payment processors, but you must inform us of any misuse of Restro that you have become aware of.
You are solely responsible for your interactions with other Restro Customers. We reserve the right, but have no obligation, to monitor disputes between you and other users.
XIV. Registration function
You can register as a user of our Restro service on the relevant website pages, as an user, partner, service or investor. The received data will be used in operation of our Restro service, as well as to inform you about changes in the scope of our Restro services, or any technical changes or for other messages (via email). Registration includes the entry of the following data:
- Email address;
- AML/KYC policy information and documents which may be requested during and after the registration, such as Gender, First name, Last name, Address, ID document etc. See AML/KYC Policy for more information.
Besides, the IP-address used for registration, as well as the date of the registration, are stored in order to prevent the abuse of registration. By adding information from social networks profiles for Restro registration, we receive information from the social network (profile id, name, surname, other data according to terms and conditions of social networks). You agree with processing of your social networks information during registration.
XV. Access data/server log files
Details of your visit to our website are stored in a log file (the so-called server log file). We collect (or our internet provider servers) the following data on each access to our Restro:
- IP address of the accessing computer;
- name of the file requested;
- date and time of the request;
- amount of data transmitted;
- notification of successful request;
- browser type and version along with the operating system used;
- referrer URL;
- requesting Provider;
- screen resolution.
The log data is used by us only for statistical analysis in the context of operation of Restro. In case of illegal use of our service, the log data also may serve as a resolution in the eventuality of any violation of the law.
XVI. Service messages
There are some messages (hereinafter referred to as the “Service Messages”) that we will send you if necessary. These Service Messages may be sent via email, post or text message (according to the addresses and directions provided by you during the registration), and shall include notifications about information on updates and other information regarding the use of Restro. From time to time we may also send you advertisements and other information about our services, or services of our partners.
XVII. Monitoring and recording
We may monitor, record, store and use any telephone, email or other communication with you to check any instructions given to us, for instructional purposes, crime prevention, and in order to improve the quality of our customer service.
For purposes of this Policy, “us,” “we,” or “our” refer to the company Restro Ltd website https://restro.io/ and related services.
Our Anti-Money Laundering and Know Your Customer Policy (hereinafter “AML/KYC Policy”) is designated to prevent and mitigate possible risks of us being involved in any kind of illegal activity.
Both international and local regulations require us to implement effective internal procedures and mechanisms to prevent money laundering, terrorist financing, drug and human trafficking, proliferation of weapons of mass destruction, corruption and bribery and to take action in case of any form of suspicious activity of our customers.
AML/KYC Policy covers the following matters:
- Compliance Officer;
- Risk Assessment;
- Identity Verification Procedures;
- Monitoring Transactions.
The Compliance Officer is the person, duly authorised by us, whose duty is to ensure the effective implementation and enforcement of AML/KYC Policy. It is the Compliance Officer’s responsibility to supervise all aspects of our anti-money laundering and counter-terrorist financing requirements, including but not limited to:
- Collecting customers’ identification information;
- Establishing and updating internal policies and procedures for the completion, review, submission and retention of all reports and records required under the applicable laws and regulations;
- Monitoring transactions and investigating any significant deviations from normal activity;
- Implementing a records management system for appropriate storage and retrieval of documents, files, forms and logs;
- Updating risk assessment regularly;
- Providing law enforcement with information as required under the applicable laws and regulations.
The Compliance Officer is entitled to interact with law enforcement authorities, which are involved in the prevention of money laundering, terrorist financing and other illegal activities.
We, in line with the international requirements, have adopted a risk-based approach to combating money laundering and terrorist financing. By adopting a risk-based approach, we are able to ensure that measures to prevent or mitigate money laundering and terrorist financing are commensurate with the identified risks. This will allow resources to be allocated in the most efficient ways. The principle is that resources should be directed in accordance with priorities so that the greatest risks receive the highest attention.
Our identity verification procedure requires the customer during the registration to provide us with such documents according to AML/KYC Policy:
a) Identity Document – this is a valid, reliable and independent source document with the following information: First Name and Last Name; date of birth; customer’s photo, identity document serial number. The customer is free to provide one of the following types of documents:
- National ID card (both sides) or national passport;
- International passport;
- Driver’s license (both sides).
Please note that we accept documents as proof of your identity only if all the information in it is provided with Latin transliteration.
b) Proof of address – this is a document confirming the customer’s residence containing First Name and Last Name, address and issued within the last 3 months. The customer is free to provide one of the following types of documents:
- Certified tenancy agreement or a bank statement;
- Utility or electricity bill;
- Tax return or council tax;
- Other official document with current residential address, First Name and Last Name and issued within the last 3 months.
Please note that we accept documents as proof of address only if all the information in it is provided with Latin transliteration.
c) “Selfie” – a photo of yourself holding a sheet of paper with the inscription “Restro.io or Restro Ltd” and the current date.
We will take steps to confirm the authenticity of documents and information provided by the customer. All legal methods for double-checking identification information will be used and we reserve the right to investigate certain customers who have been determined to be risky or suspicious.
We reserve the right to verify a customer’s identity on an on-going basis, especially when his identification information has been changed or his/her activity seemed to be suspicious (unusual for the particular customer). In addition, we reserve the right to request up-to-date documents from the customer, even though he/she have passed identity verification in the past.
We reserve a right to reject any person on registering on https://restro.io/ and using related services if we are unable to verify any information due to non-cooperation of the customer, or if customer’s actions are likely to have a material adverse effect on us for being in violation of any applicable laws or industry best-practice guidelines.
We may from time to time temporarily reject customers from some countries/territories. The current list of such countries/territories can be reviewed here. This applies to both new customers at the registration stage and existing users of our services. In the latter case, we will notify the customer of the refusal to provide services in advance, and provide reasonable time for the termination of the use of our services.
The customers are known not only by verifying their identity (who they are) but, more importantly, by analyzing their transactional patterns (what they do). Therefore, we rely on data analysis as a risk-assessment and suspicion detection tool. We perform a variety of compliance-related tasks, including capturing data, filtering, recordkeeping, investigation management and reporting. System functionalities include:
a) A daily check of customers against recognized “black lists” (e.g., OFAC), aggregating transfers by multiple data points, placing customers on watch and service denial lists, opening cases for investigation if it is essential, sending internal communications and filling out statutory reports, if applicable;
b) Case and document management.
restro.io demonstrates strong commitment in maintaining the integrity of its website services.
a) The company constantly analyses all provided customer data and monitors all transactions and it has the right to:
- monitor and control all transactions by means of automated screening, particularly employment of the Google Analytics Tool or any other transaction monitoring tool and manual screening aimed at prompt identification of high-risk transactions. Transaction monitoring systems are reviewed regularly to ensure the system is operating appropriately and effectively.
- analyze customers’ historical information and other contextual profile data (placing requests, offers, input and output data, website activity tracking, etc.).
- monitor and control unnecessarily complex and unusual transactions to identify different suspicious actions.
b) In case of detection of any suspicious or toxic transactions, Restro.io follows the algorithm:
- request the customer to provide any additional information or documents in case of suspicious transactions.
- temporary suspend (lock out) or deactivate a user account if data provided by the user is fictitious (false, incomplete or misleading) with regard to origin of funds.
- terminate the user account and cancel all transactions engaged in suspicious (fraudulent) activities.
c) Upon detection of any suspicious (fraudulent) transactions, the company reserves the right to employ corresponding prevention measures without prior notice or explanation to the user, which include but are not limited to:
- blocking/closing of the existing/open client’s transactions on the website.
- restricting and/or blocking access to the website.
- cancellation of all deposit/withdrawal transactions deemed as suspicious (fraudulent).
- reporting of any suspicious user’s transactions to the relevant enforcing authorities.
With regard to AML/KYC Policy, we will analyze all provided customer data and monitor all transactions and it reserves the right to:
- ensure that transactions of suspicious nature are reported to the proper law enforcement through the Compliance Officer;
- request the customer to provide any additional information and documents in case of suspicious transactions;
- temporary suspend (block) or terminate customer’s account when we have reasonable suspicion that such customer is engaged in illegal activity.
The above list is not exhaustive and the Compliance Officer will monitor customers’ transactions on a day-to-day basis in order to define whether such transactions are to be reported and treated as suspicious or are to be treated as bona fide.