Effective Date: August 2024

 

ENAC Bella Management and Training LTD ("we", "us", or "our") respects your privacy and is committed to protecting your personal data. This Privacy Policy outlines how we collect, use, store, and share your information when you engage with our services.

 

 1. Who We Are

We are a company that provides HR recruitment, headhunting services, expert-led masterclasses, and project management in the fintech space. Our contact details are:

• Company Name: ENAC Bella Management and Training LTD

• Email: info@bella.guide

 

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2.Data We Collect

We collect personal information voluntarily provided by you for the purpose of fulfilling regulatory obligations or facilitating services. This may include:

• Identification documents (e.g., ID, passport)

• Company documents

• Additional information required by our banking and payment partners (regulated in their respective jurisdictions)

 

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 3. How We Collect Dat

Data is collected through email correspondence. All data is stored using third-party storage providers such as AWS and Google Drive. We do not use private servers.

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4. Purpose of Data Collection

Your data is used for:

• KYC (Know Your Customer) and regulatory screening

• Compliance with AML (Anti-Money Laundering), OFAC, PEP (Politically Exposed Persons), sanctions rules, and other regulations

• Ensuring eligibility according to the relevant banking partner’s acceptance policies and jurisdictional guidelines

 

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5. Data Sharing

We share your data with:

• Regulated banking partners

• Financial institutions and third-party processors responsible for compliance screening

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Data may be transferred internationally, including to the EU, Canada, Hong Kong, Singapore, and other locations where partners are based. Each partner is responsible for complying with local regulations, such as GDPR in the EU.

 

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6. Legal Basis for Processing

We process your data to comply with:

• Regulatory and legal obligations (e.g., Companies House, Financial Intelligence Units, OFAC sanctions)

• Requirements from banking partners and other financial institutions

 

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7. Data Retention

We retain your data for seven (7) years from the moment an account is opened with a banking or payment partner. If no account is opened, you can request that your data be deleted from our systems. However, please note that AWS or Google, as storage providers, may retain data for longer periods, and we do not control their storage policies.

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 8. Security Measures

We take security seriously and ensure that:

• Files are shared only through secure email (e.g., Google Mail or AWS email systems)

• Data is stored on password-protected drives and computers

 

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9. User Rights

As our services are one-time and for professional entities only, you are not considered an ongoing user. However, you may request deletion of your data if an account is not opened with a partner institution.

 

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10. Cookies and Tracking

Our website may use basic cookies for functionality. We do not use cookies for tracking or advertising purposes.

 

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11. Children’s Privacy

We do not offer services to individuals under the age of 18. Our services are strictly for professional entities and individuals.

 

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12. Changes to This Policy

We may update this policy from time to time. Any changes will be posted on our website, and you will be notified via email if necessary.

 

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 13. Contact Information

If you have any questions or concerns about this Privacy Policy, please contact us at: info@bella.guide

 

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14. User Consent and Data Subject Rights

By submitting your personal data to ENAC Bella Management and Training LTD, you acknowledge that you are providing it voluntarily and with your full consent. You may withdraw your consent at any time, which will result in us ceasing to process your data, unless required to continue doing so by law.

 

If you are a resident of the European Union, you have the following rights under the General Data Protection Regulation (GDPR):

• Right to access: You can request a copy of the personal data we hold about you.

• Right to rectification: If your data is inaccurate or incomplete, you can request corrections.

• Right to erasure: You have the right to request that we delete your data, particularly if the data is no longer necessary or you withdraw consent.

• Right to restrict processing: You may request that we limit the processing of your data.

• Right to object: You can object to how we process your data in certain circumstances, particularly when data is processed for legitimate interests.

• Right to data portability: You can request that your data be transferred to another organization in a machine-readable format.

 

To exercise any of these rights, please contact us at info@bella.guide We will respond within the timeframes set by applicable law.

 

 

15.  Third-Party Providers' Compliance

We store your data with trusted third-party providers such as AWS and Google Drive, who comply with international standards for data protection and privacy, including GDPR when applicable. Each provider is responsible for ensuring compliance with local regulations where they operate.

 

We have data protection agreements in place with these providers to ensure that your data is handled securely and in compliance with relevant legal requirements.

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16. International Data Transfers

In some cases, we may need to transfer your data to banking partners or third-party processors located outside your home country. This may include transfers to the European Union (EU), Canada, Hong Kong, Singapore, and other jurisdictions where our partners are based. When such transfers occur, we ensure that appropriate safeguards are in place, such as:

• Standard Contractual Clauses (SCCs): For transfers outside the EU, we use SCCs to ensure that your data is protected at the same level as required by the GDPR.

• Adequacy decisions: Where applicable, we transfer data only to countries that have been deemed to provide an adequate level of protection by relevant authorities (e.g., the European Commission).

 

These safeguards ensure that your personal data is secure and that your privacy rights are protected, no matter where your data is processed.

 

 

17. Data Breach Notifications

In the event of a data breach that affects your personal data, we are committed to notifying you and any relevant regulatory authorities as required by law. We will:

• Assess the severity and impact of the breach.

• Notify affected users as soon as possible if the breach poses a risk to their rights and freedoms.

• Take steps to mitigate the breach and prevent further occurrences.

 

If you believe your data has been compromised, please contact us immediately at info@bella.guide

 

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18. Automated Decision-Making

In some cases, our banking partners or financial institutions may use automated systems to perform AML, sanctions, or other regulatory screenings. These automated decision-making processes help ensure compliance with relevant laws.

 

If you object to automated decision-making that affects you, you can request human intervention by contacting the relevant financial institution or by reaching out to us for assistance.

 

 

19. Website Analytics and Cookies

We only use basic cookies necessary for the functionality of our website. We do not engage in extensive tracking or use cookies for advertising purposes.

 

Should we implement any form of website analytics in the future, we will ensure that you are informed and provided with options to opt-out, in compliance with applicable laws like the GDPR.

 

 

20. Data Portability

If you are an EU resident or are otherwise entitled under relevant regulations, you have the right to request that your personal data be transferred to another organization. Upon request, we will provide your data in a structured, commonly used, and machine-readable format.

 

Please contact us at info@bella.guide to exercise this right.