Privacy & cookies

Effective Date: 1st January 2022

This Privacy Policy and Cookie Policy ("Policies"), together with our Terms of Use, governs Ferriswheel’s collection, processing and use of your personal data and our use of cookies and similar technologies. As used in these Policies, "Ferriswheel", "we", "us" or "our" refers to CEFINE UAB., a company organized under the laws of Lithuania. These Policies constitute a part of the Terms of Use to which you have previously agreed by registering for our Services and accessing our websites.

The governing language of these Policies is English. Any other language translation is provided for convenience only.

Please contact us with questions, comments, or concerns regarding our Privacy Policy and Cookies Policy and/or practices at

1 Acceptance of Policies and Updates

By clicking a checkbox or a button that contains words such as "I Agree" when these Policies are presented to you or, if earlier, by accessing or using any Services, you, you signify your acceptance to the terms of this Privacy Policy and Cookie Policy. If you do not agree with or are not comfortable with any aspect of these Policies, you should immediately stop accessing and using the Services. You may also contact us with questions, comments, or concerns regarding our Privacy Policy and Cookies Policy and/or practices at

We reserve the right to modify this Privacy Policy and/or Cookies Policy at any time, and when required by law, we will notify you of changes to these Policies. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on our Sites prior to the change becoming effective.

2 Definitions

Certain capitalized terms used in this Privacy Policy have the following meanings.

"Account" means an individual or corporate account for use of the Services opened by you in accordance with the Terms of Use.

"Data Privacy Laws" means data protection laws applicable to Ferriswheel, including without limitation the UK Personal Data Protection Act 2018 and the EU General Data Protection Regulation 2016/679, and their respective successors or implementing texts.

"Personal Data" means any information that directly or indirectly can be used to identify a natural person. Personal Data does not include anonymized and/or aggregated data that does not identify a specific user.

"Services" has the meaning given in our Terms of Use.

"Terms of Use" means the Terms of Use posted on the Sites, which govern your use of the Services.

"Sites" has the meaning given in our Terms of Use.

3 Privacy Policy

Ferriswheel respects and is committed to protecting your privacy. The purpose of this Privacy Policy is to describe:

In cases where we require your consent to process your personal information, we will ask for your consent to the collection, use, and disclosure of your Personal Data as described further below. We may provide additional disclosures or additional information about the data collection, use and sharing practices of specific Services. These notices may supplement or clarify Ferriswheel’s privacy practices or may provide you with additional choices about how Ferriswheel processes your data.

3.1 Collection of Personal Information

We collect Personal Data to provide you with our Services. You are free to choose whether to provide us with the types of Personal Data requested, but we may not be able to offer you some or all our Services when you choose not to share certain information with us.

For example, we collect Personal Data which is required under law to open an account, to link a bank account, or to execute a transaction. We also collect Personal Data when you use or request information about our Services, subscribe to marketing communications, request support, complete surveys, or communicate with us.

We may also collect Personal Data from you offline, such as when you attend one of our events or when you contact customer support. We may use this information in combination with other information we collect about you as set forth in this Privacy Policy.

Personal Data we collect may include the following:

Information you provide to us. We collect information that you provide directly to us through the Sites or by e-mail, phone, or any other medium. This may include:

Information we collect when you use our services. We also automatically collect information about your computer, device and browsing activity when you access the Sites or use Services. This information may include:

Information we collect from other sources. We may collect information from third party partners, public authorities, public websites, social media and other public sources, which may include information related to your identification, location, reputation, business activities, and other personal details.

3.2 How We Use Your Personal Information

We only use your Personal Data if we have a proper reason for doing so. Unless we receive permission from you, we will not use your Personal Data for purposes other than those set forth below.

Legal Obligations. We process certain information to comply with our legal obligations:

Contractual Obligations. We process certain information to be able to perform our obligations under our contract with you:

Legitimate Interests. We process certain information based on our legitimate business interests in connection with our provision of the Services to you:

3.3 Automated Decision Making

We may make automated decisions on certain matters, such as to fulfil our obligations imposed by law (such as to verify your identity), to detect fraudulent or prohibited activities, or to determine whether you are eligible for certain of our Services. If you disagree with the decision you are entitled to contest this by contacting us at following email address:

Our Use of Cookies and Similar Technologies

Please see Part 4 (Cookies Policy) below for a description of how we use cookies and similar technologies on the Sites.

3.4 Disclosures to Third Parties

We take care to allow your Personal Data to be accessed only by those who need to perform their tasks and duties, and to share your Personal Data only with third parties who have a legitimate purpose for accessing it. Except in the following circumstances, we will not sell, exchange, or share your Personal Data without your consent:

3.5 Consent to International Transfers of Personal Data

As a global company, we may store and process your Personal Data in our facilities in various locations. This Privacy Policy applies regardless of the location in which we store and process your Personal Data.

We transfer Personal Data to service providers that process for the specific purposes of performing identity verification and other screening, to enable us to prevent fraud and to comply with our know-your-customer obligations under anti-money laundering and countering the financing of terrorism laws and regulations. We transfer Personal Data to service providers for the specific purposes of delivering emails and targeted marketing. When we send emails, Personal Data may pass through our service provider’s data centres for geo-forwarding.

By accepting this Privacy Policy, you specifically and voluntarily consent to the transfer of your personal information to each of the countries specified in the preceding paragraphs. Some of these countries might not have protections in place for personal data as extensive as those within your country of residence. However, we require our service providers to treat your personal information in strict confidence and to use appropriate security measures to protect it. We also require them to uphold all of our other obligations under this Privacy Policy.

You may revoke your consent to this section at any time by contacting us at

3.6 Your Rights

You have certain rights concerning your Personal Data under Data Privacy Laws, which you can exercise by contacting us at These rights include:

3.7 Right to Submit a Complaint

If you believe that we have infringed your rights, we encourage you to contact us first at so that we can try to resolve the issue or dispute informally. You can also submit a complaint about our processing of your Personal Data to the relevant data protection authority. You can submit a complaint in the country where you live or work or in the place where the alleged breach of the applicable Data Privacy Laws has taken place.

3.8 Security of Personal Data

We use a variety of security measures to ensure the confidentiality of your Personal Data and to protect your Personal Data from loss, theft, unauthorized access, misuse, alteration or destruction. For example, we use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorize access to Personal Data only for those employees who require it to fulfil their job responsibilities.

However, we cannot guarantee that loss, theft, unauthorized access, misuse, alteration or destruction of your Personal Data will not occur. Please take adequate measures to protection your Personal Data. When registering to use our Services, it is important to choose a password of sufficient length and complexity and to keep this password a secret. Please notify us immediately if you become aware of any unauthorized access to or use of your account.

Furthermore, we cannot ensure the security or confidentiality of Personal Data that you transmit to us or receive from us via the internet or wireless connection, including email, phone, or SMS. If you have reason to believe that your data is no longer secure, please contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy.

3.9 Retention of Personal Data

We retain Personal Data for as long as necessary to fulfil the purposes described in this Privacy Policy, subject to our own legal and regulatory obligations. The criteria we may use to determine the retention period for certain categories of data includes:

Except where prohibited by law, this period may extend beyond the end of your relationship with for so long as is necessary for audit or other accounting or regulatory purposes. When Personal Data are no longer needed we have procedures either to destroy, delete, erase or convert it to an anonymous form. After you have terminated your use of our Services, we reserve the right to maintain your Personal Data as part of our standard back up procedures in an aggregated format.

3.10 Children’s Personal Information

We do not knowingly request to collect Personal Data from any person under the age of 18. If a user submitting Personal Data is suspected of being younger than 18 years of age, we will require the user to close his or her account. We will also take steps to delete the Personal Data as soon as possible. Please notify us if you know of any individuals under the age of 18 using our Services so we can act to prevent access to our Services.

4 Cookies Policy

4.1 Description of Cookies

Cookies are small text files that are placed on your computer by websites that you visit. They are widely used to allow websites to work properly or more efficiently, as well as to provide information to the owners of the website.

There are two general categories of cookies. "First-party cookies" cookies are set directly by us. "Third-party cookies" are set by a third party, and that third party can recognize your computer both when it visits the Sites and when it visits certain other websites and/or mobile apps. Cookies can remain on your computer or mobile device for different periods of time. Some cookies are "session cookies", which exist only while your browser is open and expire once you close your browser. Other cookies are "persistent cookies", which survive after your browser is closed. They can be used by websites to recognize your computer when you open your browser and browse the internet again.

More information on cookies and their use can be found at or

4.2 Why We Use Cookies

When you access our Services, we or companies we work with may place cookies on your computer or other device. These technologies help us better understand user behaviour and inform us about which parts of the Sites people have visited.

We use cookies to:

4.3 Categories of Cookies We Use

We use the following categories of cookies:

4.4 Advertising and Tracking Cookies

Our Sites may feature advertising. We may allow third party companies, including advertising companies, to place cookies on our Sites. These cookies enable such companies to track your activity across various sites where they display ads and record your activities so they can show ads that they consider relevant to you as you browse the Internet. These cookies also allow us and third parties to know whether you have seen an ad or a type of ad, and how long it has been since you last saw it. This information may be used for frequency capping purposes, to help tailor the ads you see, and to measure the effectiveness of ads. These cookies are anonymous – they store information about the content you are browsing, but not about who you are.

4.5 Other Similar Technologies We Use

In addition to cookies, we may use other similar technologies such as web beacons to track users of our Services. Web beacons, or "clear gifs", are tiny graphics with a unique identifier, similar in function to cookies. They are used to track the online movements of web users.

In contrast to cookies, which are stored on a user's computer hard drive or device, clear gifs are embedded invisibly on web pages. We and our third-party service provider employ web beacons for the reasons stated above (under "4.2 – Why We Use Cookies"), but primarily to help us better manage content on our Services by informing us which content is effective.

4.6 Avoiding and Disabling Cookies

You have the right to choose whether or not to accept cookies, and instructions for exercising this right are given below. However, please note that if you choose to refuse cookies you may not be able to use the full functionality of our Sites.

Disabling cookies can be through the Cookiebot widget on the bottom right corner of the web app.