Privacy Policy

1. Introduction

This Privacy Policy (“Policy”) aims to describe how Dawn financial corp, S.A. (“Dawn financial corp”) processes personal data, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (General Data Protection Regulation or “GDPR”), Law 58/2019 of 8 August 2019, which ensures the execution of the GDPR, and all the other legislation on personal data protection. Personal data subject to processing refers to the personal data of Dawn financial corp’s clients (including representatives and beneficial owners, if applicable) and of the users of the websites or mobile applications of Dawn financial corp(“Clients”).

2. Data Controller

The data controller is Dawn financial corp, S.A., with registered office at Avenida João C Real 31, Pardilhó, Aveiro, 3860-544. Registration Office under single registration and legal person number 21 234 807 3562

3. Personal Data

Personal data includes all the information relating to a natural person who is identified or identifiable, directly or indirectly, such as, among others, name, civil or tax identification number, location data, or other specific elements of this person’s physical, physiological, genetic, psychological, economic, cultural or social identity. In its provision of services and offer of products, Dawn financial corpprocesses or may process various categories of personal data, including, but not limited to:

  • Identification data (e.g. name, numbers and expiry dates of civil and tax identification documents, gender, place of birth, date of birth, nationality);
  • Contact details (e.g. postal address, phone number, email address);
  • Data relative to professional activity (e.g. profession, professional activity, name of employer, type of contract, salary, qualifications);
  • Contractual data (e.g. account number, IBAN);
  • Credit and solvency data (e.g. bank account data, value of assets, tax data);
  • Data relative to use of websites and applications (e.g. pages visited or information about the equipment used – IP address, geographic location, browser used).

4. Means of Collection

Dawn financial corpcollects the personal data of its Clients through the following means:

  • Data provided directly by the Clients;
  • Data collected in the context of the provision of services and offer of products;
  • Profiling;
  • Cookies;
  • Data obtained from third-party entities.

5. Purpose for Processing Data

he personal data of Dawn financial corp’s Clients are used for the following purposes, based on their lawfulness:
Execution of contracts or pre-contractual procedures

  • Onboarding of clients and its management;
  • Management of banking operations and services;
  • Management of financial products.

Compliance with legal obligations

  • Administrative management;
  • Prevention of money laundering and terrorism financing;
  • Mandatory reporting to the regulatory entities;
  • Duties imposed on financial intermediaries;
  • Fraud prevention;
  • Risk management;

6. Cookies

i) What are cookies?
Cookies are small text files with relevant information that are downloaded onto the user’s access device (computer, mobile phone/smartphone or tablet) through the browser when a website is visited by the user. The use of cookies not only enables the website to recognise the user’s device the next time they visit it, but also improves the operation and experience of this website. The cookies used by Dawn financial corpon its website do not collect personal information that could identify the user. They only process and keep general information, namely the form or place of origin of the users’ access and the way that they use Dawn financial corp’s website, among other aspects. The cookies only keep demographic data and information related to the users’ preferences. The users may, at any time, through their browser, decide to be notified of the reception of cookies, and may block their entry into their system. However, it should be highlighted that rejection of the use of cookies on Dawn financial corp’s website could result in precluding access to some of its areas and not permit the entire browsing experience on Dawn financial corp’s website.
ii) What are cookies used for? Cookies are used to help determine the usefulness, interest and number of uses of websites, enabling faster and more efficient browsing, and eliminating the need to repeatedly enter the same information.
iii) What type of cookies do we use? Each cookie used has a function and an expiry date. Regarding function, the cookies used may be: Essential cookies – Some cookies are essential to access specific areas of Dawn financial corp’s website. These enable browsing Dawn financial corp’s website and using its applications, such as access to secure areas of Dawn financial corp’s website through login. Without these cookies, the services requiring them cannot be made available. Functional cookies – These cookies enable remembering the user’s preferences relative to browsing on Dawn financial corp’s website. Accordingly, the users do not need to reset and personalise it each time they visit it.
Analytical cookies – These cookies are used to analyse the way that Dawn financial corp’s website is used, enabling the highlighting of articles or services that could be of interest to the users, the monitoring Dawn financial corp’s website performance, and knowledge of which are the most popular pages, what is the most effective method of links between pages or to determine the reason why some pages are receiving error messages. These cookies are used for purposes of creation and statistical analysis only, and never collect information of personal nature. This means that Dawn financial corpcan provide a high-quality experience by personalising its offer and rapidly identify and correct any problems that may arise. Regarding expiry date, the cookies used may be: Permanent cookies – These are stored on the user’s access devices (computer, mobile phone/smartphone or tablet), at browser level, and are used whenever the user returns to Dawn financial corp’s website. Generally speaking, they are used to direct the browsing according to the user’s interests, enabling Dawn financial corpto provide a more personalised service. Session cookies – These are temporary cookies available until the session is closed. Next time the users access their browser, these cookies will no longer be stored. The information obtained by these cookies enables managing the sessions, identifying problems and providing a better browsing experience.