Page last updated: September 10, 2023

Privacy Policy

1. General information

Finlloyd.com is operated by Anthaea Srl, a Costa Rica company, located in San José, Costa Rica (the “Company”, “we”, or “us”), a subsidiary of Finlloyd Group. It is the operator of any Website published by the Company, including, but not limited to, anthaea.com, finlloyd.com, and finlloyd.crypto, aesbit.com, aesbitgold.com, karatum.com, anthaex.com, mitalys.com, and xeebet.com (the “Websites”).

As the operator of the Websites, we take the protection of your personal data very seriously. We collect, process, and use your personal data in accordance with this privacy policy and in compliance with Costa Rica’s Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011 (the “Law”).

This privacy policy (“Privacy Policy”) will provide you with information about the collection, processing, and use of your personal data when using the Websites.

In case you provide us with the personal data of third persons (such as family members or work colleagues) you should make sure that these persons are familiar with this Privacy Policy and you should only share their personal data if you have permission to do so and ensure that his personal data is correct.

2. Responsible Person

For any matters, relating to data protection you may contact Anthaea Srl – San Jose (Costa Rica) by e-mail at the following address:

Email: legals@anthaea.com

3. Data processing in connection with the Websites

3.1 Visiting our Websites

When you visit our Websites, the hosting provider(s) of our Websites may automatically collect and store various information in server log files that your browser transmits to us. The information/data mentioned is neither assigned to specific persons nor linked to data from other sources. The following technical data may be recorded by us, as usual with every connection with a web server, without your intervention, and stored by us until automatic deletion after no later than two days:

Any collection and processing of this technical data is for the purpose of enabling the use of our Websites, continuously ensuring system security and stability, optimizing our Websites, and for internal statistical purposes. This is our legitimate interest in the processing of data in the sense of the Law.

Furthermore, the IP addresses may be evaluated, together with other data, in case of attacks on the network infrastructure or other unauthorized use or misuse of the Websites, for the purpose of intelligence and protection, and if appropriate, used in criminal proceedings for identification and civil and criminal proceedings against the relevant users. This is our legitimate interest in the processing of data in the sense of the Law.

3.2 Use of Website Cookies

The Websites may use cookies. Cookies are text files that are stored in a computer system via an Internet browser. More detailed information on cookies and how they work can be found at: http://www.allaboutcookies.org

Many Internet sites and servers use cookies. Many cookies contain a so-called cookie ID. A cookie ID is a unique identifier of the cookie. It consists of a character string through which Internet pages and servers can be assigned to the specific Internet browser in which the cookie was stored. This allows visited Internet sites and servers to differentiate the individual browser of the data subject from other Internet browsers that contain other cookies. A specific Internet browser can be recognized and identified using the unique cookie ID.

Through the use of cookies, the Company may provide the users of the Websites with more user-friendly services that would not be possible without the cookie setting.

Cookies may allow us, as previously mentioned, to recognize our Website users. The purpose of this recognition is to make it easier for users to utilize our Websites. The Website user that uses cookies, e.g. does not have to enter access data each time the Website is accessed, because this is taken over by the Website, and the cookie is thus stored on the user’s computer system.

You may, at any time, prevent the setting of cookies through our Websites by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, previously set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, it may not be possible to use all the functions of our Websites.

For detailed information on the cookies we use and the purposes for which we use them, see our Cookie Policy.

3.3 Google Analytics

The Websites may use Google Analytics. Where this is true, the information generated by the cookies about your use of the Websites (including your automatically anonymized IP address) may be stored on the servers of our hosting provider(s) in Singapore, and Malaysia. For more information about Google Analytics, visit the official page at https://analytics.google.com/

Before the data is stored, the IP address will be abbreviated by activating IP anonymization (anonymizeIP) on this Website.

In addition to the data listed in section 3.1, we may receive the following information because of Google Analytics:

We may use this technical data to analyze your use of the Websites by compiling reports on Website activity for the understanding and/or optimizing of our Websites and/or for internal statistical purposes. We do not use the information and personal data collected by Matomo to identify individuals unless we become aware of specific indications of illegal use.

Any processing of this technical personal data helps us to identify what is working and what is not on our Websites and how we may improve our Websites. Without any data thus received, we may not be able to provide you with the service we are currently offering to you. Your data will be used only to improve the user experience on our Websites and help you find the information you are looking for. This is our legitimate interest in the processing of data in the sense of the Law.

You can opt out of being tracked by Google Analytics and prevent the website from analyzing the actions you take using the website with the methods listed below:

This will prevent us from learning from your actions and creating a better website experience for you and other users.

3.4 Opening an account for the Web Forum (if any)

To access our forums you must set up an account and provide us with your username, e-mail address, Telegram ID, and password.

The collected data, which you have voluntarily provided, is used for the purpose of providing your password-protected access to the base data we have stored. The legal basis for processing the data for this purpose lies in the consent you have provided in accordance with the Law.

3.5 Contact possibility via the Websites

You may contact us via our Website’s contact page or by e-mail at the following e-mail address: info@anthaea.com. For this, we require the following information: Name, Subject, E-Mail address, Message.

We use this data, which you may give voluntarily, only in order to answer your contact question or to reply to your e-mail in the best possible manner. Therefore, the processing of this data is in our legitimate interest in accordance with the Law and you have provided consent in accordance with the Law.

3.6 Registration for our newsletter (if any)

The receipt of our newsletter requires registration. For this, you must provide your name and e-mail address. By registering, you give us your consent to process the given data in order to periodically send the newsletter to the address you have given. This consent constitutes the legal basis for our processing of your e-mail address in the sense of the Law. All information gathered this way will never be passed on or sold to any third party.

At the end of each newsletter, a link is provided by means of which you can unsubscribe at any time. After unsubscribing your personal data will be deleted.

3.7 Social Media

We may use plug-ins from social networks such as Blog, GitHub, YouTube, Reddit, Gitter, Twitter, StackExchange, Facebook, or Meetups on our Websites. When you activate them by clicking on them, the operators of the respective social networks may record that you are on our Websites and may use this information. This processing of your personal data is the responsibility of these individual social media platforms and occurs according to their privacy policy. Please check with these individual social media platforms regarding their privacy policies. The Company is not responsible for data collected by these individual social media platforms. We only use these platforms to inform our community of updates and answer user questions.

3.8 Event Registration

To register for any event organized by the Company through our Websites, we may require the following registration data: First and last name, language, company affiliation, company title, credit card information, and e-mail address.

We may use this information as well as other information you voluntarily provide (e.g. preferences, comments) only in order to execute the reservation agreement unless otherwise stated in this Privacy Policy or you have not specifically consented thereto.

We may process the data by name in order to record your reservation as you have requested, to contact you in case of a question or problem, and to ensure correct payment.

The legal basis for the data processing for this purpose lies in the fulfillment of an agreement in accordance with the Law.

4. Other parties who have access to the information we collect

With the exception of the provider(s) of our Websites, we do not make your personal data available to third parties unless you have expressly consented to it, if we are legally obligated to, or if this is necessary to enforce our rights concerning a contractual relationship.

Personal data collected via the Websites may be passed on to and/or accessed by the Website service provider(s). The Websites may be hosted on servers in Singapore and Malaysia. The transfer of data is for the purpose of providing and maintaining the functionality of our Websites. This is our legitimate interest in the sense of the Law.

If you pay by credit card through the Websites, we may forward your credit card information to the credit card issuer and the credit card acquirer. If you choose to pay by credit card, you may be asked to provide all the necessary information. The legal basis for passing on the data lies in the fulfillment of an agreement in the sense of the Law.

5. International transfer of personal data

We are entitled to transfer your personal data to third parties abroad for the purposes of the data processing described in this Privacy Policy. This concerns especially the following receiver(s):

They are obliged to protect data privacy to the same extent as we ourselves. If the level of data protection in a given country does not correspond to the Costa Rica data protection level, we contractually ensure that the protection of your personal data corresponds to that in Costa Rica at all times by concluding agreements using the standard contractual clauses and complying with the Law.

6. Data security

We use appropriate technical and organizational security measures to protect your stored personal data against manipulation, partial or complete loss, and unauthorized access by third parties. Our security measures are continuously being improved in line with technical developments.

Please note that any data transmission on the Internet (e.g. communication by e-mail) is generally not secure and we accept no liability for data transmitted to us via the Internet. Unfortunately, absolute protection is not technically possible.

This information does not apply to the Websites of third parties and the corresponding links given on our Websites. The Company assumes no responsibility and liability for these.

7. Your Rights regarding your data

7.1 Right to confirmation

You have the right to obtain confirmation from the Company as to whether or not personal data concerning you is being processed. If you wish to avail yourself of this right of confirmation, you may, at any time, contact the responsible person as stated in section 1 of this Privacy Policy.

7.2 Right to access

You have the right to obtain from the Company free information about your personal data stored at any time and a copy of this information. Furthermore, you will have access to the following information:

If you wish to avail yourself of this right of access, you may at any time contact the responsible person as stated in section 1 of this Privacy Policy.

7.3 Right to rectification

You have the right to obtain from the Company, without undue delay, the rectification of inaccurate personal data concerning you. Taking into account the purposes of the processing, you shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If you wish to exercise this right to rectification, you may, at any time, contact the responsible person as stated in section 1 of this Privacy Policy.

7.4 Right to erasure (right to be forgotten)

You have the right to obtain from the Company the erasure of personal data concerning you as soon as possible, and the Company shall have the obligation to erase personal data without undue delay where one of the following grounds applies:

The personal data has been collected in relation to the offer of information society services referred to the Law.

If any one of the aforementioned reasons applies, and you wish to request the erasure of personal data stored by the Company, you may at any time contact the responsible person as stated in section 1 of this Privacy Policy. The responsible person at the Company shall promptly ensure that the erasure request is complied with as soon as possible.

7.5 Right to restriction of processing

You have the right to obtain from the Company restriction of processing where one of the following applies:

If any one of the aforementioned conditions is met, and you wish to request the restriction of the processing of personal data stored by the Company, you may at any time contact the Company’s responsible person. The responsible person will arrange the restriction of the processing.

7.6 Right to object

You have the right to object, on grounds relating to your particular situation, at any time, to the processing of personal data concerning you, which is based in the Law. This also applies to profiling based on these provisions.

The Company shall no longer process the personal data in the event of the objection unless the Company can demonstrate reasonable grounds for the processing, which override the interests, rights, and freedoms of you, or for the establishment, exercise, or defense of legal claims. In order to exercise the right to object, you may directly contact the responsible person.

7.7 Automated individual decision-making, including profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you, or similarly significantly affects you, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between you and the Company, or (2) is not authorized by the applicable law and which also lays down suitable measures to safeguard your rights and freedoms and legitimate interests, or (3) is not based on your explicit consent.

If the decision (1) is necessary for entering into, or the performance of, a contract between you and the Company, or (2) it is based on your explicit consent, the Company shall implement suitable measures to safeguard your rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express their point of view and contest the decision.

Please note that the Company does not use automatic decision-making but we may use profiling according to these Privacy Policy rules.

7.8 Right to withdraw data protection consent

You have the right to withdraw your consent to the processing of your personal data at any time. If you wish to exercise the right to withdraw the consent, you may at any time directly contact the responsible person as stated in section 1.

8. Duration of the storage

The Company will process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the applicable laws or regulations. If the storage purpose is not applicable, or if a storage period prescribed by the applicable laws expires, the personal data is routinely erased in accordance with the legal requirements.

9. Minors

The Company does not knowingly collect or use any personal data from minors. A minor may be able to willingly share personal information with others, depending on the products and/or media channels used. If a minor provides us with their information without the consent of their parent or guardian, we will ask the parent or guardian to contact us for the purpose of deleting that information.

10. Updates to our Privacy Policy

The Company may update this Privacy Policy from time to time and inform you on the Websites that the policy has been amended. The current version of the Privacy Policy, as published on our Website, is applicable. With each update to our policies, we will note which sections have been updated.

11. More information about privacy regulations

For more information on applicable privacy regulations, you may refer to:

Costa Rica’s Protection of Persons Regarding the Processing of their Personal Data No. 8968 of 2011: https://caseguard.com/articles/law-no-8968-of-2011-costa-rican-data-rights/

Please do not hesitate to contact us if you have any questions regarding this Privacy Policy by contacting us at info@anthaea.com