SATOS B.V., with its registered office at Kraijenhoffstraat 137A, 1018 RG Amsterdam and registered with the Chamber of Commerce under number 65743954, is the controller for the processing of personal data as described in this privacy statement.

 

 

 

Contact Details

• Address: Kraijenhoffstraat 137A, 1018 RG Amsterdam

• Phone: 0320 320 036

• Website: https://www.SATOS.eu

 

 

 

What data we process and for what purpose

SATOS mainly processes your personal data when you use our services and/or because you provide this data to us yourself.

 

Below you will find an overview of the personal data we process:

 

• Performance of the contract: When you sign up for our services as specified in the Terms of Use, we may collect your contact details (name, email address, phone number) to enable communication. This processing is necessary for the performance of the contract between you and SATOS. Without provision of this information SATOS would not be able to enter into contract with you and provide relevant services.

 

• Verification and compliance: In order to comply with our legal obligations under the Money Laundering and Terrorist Financing (Prevention) Act (Wwft) and the Sanctions Act 1977, we carry out thorough customer due diligence. We are unable to provide you services without this information. This means that we:

  • Process identity data (copy of identity document, name and address details).

  • Assess your financial background (income and wealth data).

  • Monitor your transactional behavior to identify unusual patterns.

For these purposes, we share necessary data with third parties providing KYC and transaction monitoring services This data exchange is required to comply with our legal obligations and to minimize the risk of fraud and money laundering.

 

• Customer service and support: To handle your questions and requests, we use the Intercom communication platform. The processing of communication data is necessary to provide you with the requested support to fulfill our contractual obligations.

In the event of complaints or requests regarding the processing of your personal data, we will engage our Data Protection Officer. It depends on the situation and your request or complaint whether, and if so, which of your data will be processed in that case.

 

• Website improvement: In order to continue to improve our services, we monitor our website for user behavior with the help of third party software. In doing so, we process information about the use of the website, such as the pages visited and which links are clicked on. From this data, it can be deduced what information someone might be interested in. Please find more information in our Cookie Statement.

 

 

 

Retention periods

SATOS does not store your personal data for longer than is strictly necessary to achieve the purposes for which your data is collected. We use the following retention periods for the following (categories of) personal data:

 

• We store data that we are obliged to process under the Wwft and/or the Sanctions Act 1977 for up to 5 years after the termination of our relationship with you as a customer.

 

• We store your name and contact details via the website’s contact form the same period as the obligated retention period as mentioned above in order to be able to answer the question you ask us via the website.

 

• Data (such as transactional data) that we are obliged to keep under tax law is stored for 7 years.

 

• When our Data Protection Officer is in contact with you, a file can be created in order to be able to handle the situation in question properly. The file will be kept for as long as is necessary for the situation. Once a file has been processed, it will be kept for a maximum of one year.

 

• Other data will be stored for a maximum of 1 year after the termination of our relationship with you as a customer.

 

 

 

Automated decision-making

SATOS uses automated processing to make decisions about matters that may have (significant) consequences for individuals. This involves continuously adjusting a risk rating of all our clients based on, among other things, demographic data and the amount and number of transactions.

 

If the automated processing may result in a possible negative consequence for you, a human assessment will then take place, with which the automated indication can be overruled.

 

 

 

Sharing personal data with third parties

SATOS does not sell your data to third parties and will only provide it if this is necessary for the performance of our agreement with you, to comply with a legal obligation, or if this is necessary for the protection of a legitimate interest (for instance, when we identify and prevent fraudulent activities and misuse to safeguard the security of our users, ourselves, and others. This includes taking measures to avert immediate physical harm or significant financial loss).

 

We enter into a processing agreement with companies that process your data on our behalf to ensure the same level of security and confidentiality of your data. SATOS remains responsible for this processing in these situations.

 

All collected personal information may also be shared with the Dutch Data Protection Authority or other competent authorities. Information is only shared in this regard when it is necessary to properly handle the situation. You will also be notified of the sharing in this situation if this is legally permitted.

 

Furthermore, your data will be shared with the following types of service providers, and for the following reasons:

 

• Background check solutions: We share data with external parties to verify whether clients have been involved in any sanctioned or political activities in the past.

 

• ID processing software: We use software providers allowing us to store identification documentation and contents, and verify the validity of your documents by facial recognition.

 

• CRM software: We use CRM software providers to process and manage records such as customer support chats, e-mail communications, client verifications and providing overall assistance.

 

• Payment processors: Payment processors allow us to process payments and all other bank transaction data.

 

• Blockchain Analytics: We use blockchain analytic tool’s providers to analyse transactions and identify wallets from incoming and outgoing transfers.

 

• Bybit (powered by SATOS): SATOS shares data to fully utilise the framework and infrastructure of the Bybit (powered by SATOS) platform.

 

We share your personal data with our service providers where some processing occurs outside the EU. When transferring personal data to third countries or international organizations outside the European Union, we implement appropriate technical, organizational, and contractual safeguards - such as Standard Contractual Clauses, or rely on European Commission decisions confirming the specific countries are providing adequate personal data protection (Adequacy decisions) to ensure compliance with applicable data protection regulations.

 

 

 

Cookies, or similar techniques, that we use

SATOS uses cookies on its website. Read more about cookies in our Cookie Statement.

 

 

 

Viewing, modifying or deleting data

You have the right to access, correct or request to delete your personal data. Given that SATOS must comply with the Wwft and tax legislation, there is a possibility that we may not be able to fulfill the deletion request. However, after the mandatory retention period has expired, we will securely and responsibly delete your data.

 

In addition, you have the right to withdraw your consent to the data processing or to object to or restrict the processing of your personal data by SATOS and you have the right to data portability. This means that you can submit a request to us to send the personal data that we have about you in a computer file to you or another organisation named by you.

 

Please be advised, where processing is based on consent, you have the right to withdraw consent at any time.

 

You can send a privacy related request concerning your personal data to privacy@SATOS.eu where it will be handled by the Data Protection Officer. You may also contact our DPO by phone: 020 22 659 03.

 

After submitting a request, we may ask you to identify you in a certain way. The way we do it depends on your question.

 

We will respond to your request as soon as possible, but within one month, with a possible extension of two additional months.

 

SATOS would also like to point out that you have the possibility to lodge a complaint with the national supervisory authority, the Dutch Data Protection Authority.

 

 

 

How we protect personal data

SATOS takes the protection of your data seriously and takes appropriate measures to prevent misuse, loss, unauthorised access, unwanted disclosure and unauthorised alteration. If you feel that your data is not properly secured or there are indications of misuse, please contact our customer service or via privacy@SATOS.eu.