Privacy Statement (EU)

Privacy statement

Satos BV, located at Kraijenhoffstraat 137A, 1018 RG Amsterdam and registered with the Chamber of Commerce under number 65743954, is responsible for the processing of personal data as described in this privacy statement.

Contact details

  •   Address: Kraijenhoffstraat 137A, 1018 RG Amsterdam
  •   Telephone: 0320 320 036
  •   Website: https://www.satos.eu

Which 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:

  • General customer information: When you register for our services, we collect your contact information (name, email address, telephone number) to enable communication. This processing is necessary for the execution of the agreement between you and Satos .
  • Verification and compliance: To comply with our legal obligations under the Money Laundering and Terrorism Financing (Prevention) Act ( Wwft ) and the Sanctions Act 1977, we conduct a thorough customer due diligence. This means that we:
    • Process identity data (copy of ID, name and address details).
    • Assess your financial background (income and asset data).
    • Monitor your transaction behavior to identify unusual patterns.

For these purposes, we share necessary data with external parties such as the BKR (for identity verification), Refinitiv World Check (for sanctions, PEP and adverse media checks), and Chainalysis (for analysis of cryptocurrency transactions). 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: We use the Intercom communication platform to handle your questions and requests. The processing of communication data is necessary to provide you with the requested support.

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

  • Website improvement: In order to continue to improve our services, we monitor our website for user behavior using Google Analytics. We process information about the use of the website, such as the pages visited and which links are clicked. From this data it can be deduced which information someone may be interested in.

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 your name and contact details via the website for a maximum of 4 weeks in order to be able to answer the question you ask us via the website.
  •   data that we are obliged to process under the Wwft and/or the Sanctions Act 1977 for up to 5 years after the end of our relationship with you as a customer.
  •   We store data that we are obliged to keep under tax law for 7 years.
  •   When our Data Protection Officer contacts you, a file can be created to properly handle the situation in question. The file is kept for as long as necessary for the situation. Once a file has been processed, it will be kept for a maximum of one year.
  •   We store other data for a maximum of 1 year after ending our relationship with you as a customer.

 

Automated decision-making
Satos makes decisions based on automated processing on matters that could have (significant) consequences for people. This involves continuously updating a risk classification of all our customers based on demographic data and amount and number of transactions.

 

If a possible negative consequence for you may arise from the automated processing, 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 execution of our agreement with you, to comply with a legal obligation, or if this is necessary for the representation of a legitimate interest.

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 these processing operations in those situations.

Information can also be shared with the Dutch Data Protection Authority or other competent authorities. Information is only shared in this regard when necessary to properly handle the situation. You will also be notified of the sharing in this situation.

We use Google Analytics (USA) to analyze the use of our website. Our email is provided by Google (EU).

Furthermore, your data will be shared with the following organizations, and for the following reasons:

  • Credit Registration Bureau (BKR ) : We share your data with BKR to carry out an identity check. BKR provides us with feedback on the ID check performed to ensure the reliability of the identity verification.
  •   Refinitiv World Check : Your name, date of birth and place of birth are shared with Refinitiv World Check to carry out checks in various areas:

o   Sanctions lists: Are you listed on international sanctions lists?

o   Politically Exposed Persons (PEP): Are you known as a politically exposed person?

o   Negative Media: Is your name or a name similar to yours associated with negative media coverage?

If any of the above checks are negative, a manual review will take place to further investigate the situation.

  •   Ballerine: This Israeli company offers a name checking framework . When a customer makes a deposit of one euro, we check the account holder’s name against the ID to ensure compliance. This check prevents incorrect deposits from company accounts to private accounts. After this verification, we receive a score: a score that exceeds the set threshold will trigger a manual review.
  •   Chainalysis: Analyzes transactions of crypto to determine which addresses crypto is being received from or to which addresses it is being sent. Addresses are labeled by Chainalysis . Transactions originating from or addressed to labeled addresses are frozen and reported to De Nederlandsche Bank (DNB). All relevant data is transferred and the crypto remains frozen until DNB approves its release.
  •   Sumsub: Performs ID checks. You will receive a link to verify your ID through a photo and real-life detection. Sumsub also takes care of the archiving of ID cards and proof of registration and assets.
  •   SalesForce: Serves as a file management system.
  •   Intercom: Used for support questions or sending documents. The retention period of the data is the same as that of other research data.
  •   Bunq: To process all bank transaction data.
  •   Cartgate / CuroPayments: As Payment Service Providers (PSP) for payments .
  •   Mail provider: Google (EU-based): For e- mail communication .
  •   ByBit: Takes care of the hosting of the website and transactions. Due to the WWFT obligation, transactions are also partly checked by ByBit . Due to the need for professional traders to trade in milliseconds worldwide, data processing takes place worldwide.

 

More about the security and processing of personal data by these companies can be found on the websites of the companies mentioned.

 

Cookies, or similar techniques, that we use

Satos uses cookies on its website. Read more about cookies in our cookie statement .

View, adjust or delete data
You have the right to view, correct or delete your personal data. In addition, you have the right to withdraw your consent to data processing or to object to 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 we have about you in a computer file to you or another organization mentioned by you.

You can send a request for access, correction, deletion, data transfer of your personal data or request for withdrawal of your consent or objection to the processing of your personal data to privacy@satos.com .

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 quickly as possible, but within four weeks.

Satos would also like to point out that you have the option to file 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, unauthorized access, unwanted disclosure and unauthorized modification. 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.com. You can also contact our external data protection officer on 020 22 659 03.