Privacy Policy

1. Introduction

This Privacy Policy explains how personal information is collected, used, and protected when individuals access or use the fac3less services.

The fac3less platform is a digital service operated by Continental Capital Bank Ltd., a financial institution incorporated in the Commonwealth of Dominica.

This policy applies to:

• the website fac3less.com
• the web application fac3less.app
• related digital services operated under the fac3less brand

Continental Capital Bank Ltd. acts as the controller of personal data processed through the fac3less platform.

2. Information We Collect

Depending on how the fac3less services are used, the following categories of information may be collected.

Identification Information

• full legal name
• date of birth
• nationality
• residential address
• government-issued identification documents

Contact Information

• email address
• telephone number
• mailing address

Account and Transaction Information

• account activity
• payment transactions
• card transactions
• service usage

Technical Information

• IP address
• browser type
• device type
• operating system
• access time and pages visited

This information is used primarily for security, service operation, and system maintenance.

3. Purpose of Data Processing

Personal information may be processed for the following purposes:

• customer identification and verification
• compliance with anti-money laundering (AML) and know-your-customer (KYC) requirements
• prevention of fraud and financial crime
• operation of financial and payment services
• customer support and account administration
• compliance with legal and regulatory obligations

4. Identity Verification

As part of regulatory compliance requirements, users may be required to complete identity verification during onboarding.

Identity verification services may be performed using specialized third-party providers. The fac3less platform may utilize Sumsub (Sum & Substance Ltd.) to perform identity verification checks.

Personal data required for identity verification may be transmitted securely using encrypted communication channels.

5. Sharing of Information

Personal information may be shared with authorized service providers when necessary to provide services or comply with legal obligations.

• identity verification providers
• payment processing partners
• card program service providers
• fraud monitoring and security services
• regulatory authorities where required by law

Personal information is not sold to third parties.

6. Technical Data and Cookies

When you access the fac3less platform, certain technical information may be collected automatically such as IP address, device type, and operating system.

Cookies are used for:

• Security and authentication
• Identity verification during onboarding
• Service functionality and performance

Disabling cookies may limit the availability of certain services.

7. Payment and Card Services

Where payment cards or financial services are offered through the fac3less platform, transaction and account information may be processed by authorized partners.

• card program managers
• payment processors
• issuing banks
• card networks such as Visa or Mastercard

Transaction data may be used for:

• transaction processing
• settlement
• fraud monitoring
• dispute and chargeback handling
• compliance with payment network rules

8. International Data Transfers

Personal information may be transferred internationally when required to provide services or comply with regulatory requirements. Appropriate safeguards are implemented to protect personal data.

9. Data Retention

Customer identification and transaction records may be retained for a minimum period of seven (7) years following the end of a customer relationship or as required by applicable AML regulations.

10. Data Security

Technical and organizational safeguards protect personal data against:

• unauthorized access
• loss or destruction
• misuse
• unauthorized disclosure

11. Website Technologies

The fac3less website may use cookies or similar technologies to improve functionality and analyze service usage.

Cookies may be used to:

• maintain session functionality
• remember user preferences
• improve service performance

Users may disable cookies in browser settings, although some services may not function correctly without them.

12. Third-Party Links

The fac3less website may contain links to third-party websites. The platform is not responsible for the privacy practices of external websites and encourages users to review the privacy policies of those sites.

13. Changes to This Policy

This Privacy Policy may be updated periodically to reflect changes in services, regulatory requirements, or operational practices.

The most recent version will always be available through the fac3less platform.

14. Contact Information

Continental Capital Bank Ltd.
40 Kennedy Ave.
Roseau
Commonwealth of Dominica
Email: privacy@cc-bank.com