Privacy Policy

Last Updated: December 8, 2020

eBanqo, Inc. (hereinafter referred to as “eBanqo”, “we”, “our” or “us”) understands that the trust the users of our Services (hereinafter referred to individually and collectively as “Client”, “End User”, “your”, or “you”) have in eBanqo is the most important asset. As such, Client privacy is essential for us. This privacy declaration (hereinafter referred to as “Privacy Policy”) is applicable, inter alia, to (i) our websites https://www.ebanqo.com/ and https://www.ebanqo.io/ (hereinafter referred to as the “Website”), (ii) visiting our offices and (iii) all (commercial) relations between eBanqo and its customers, prospects and business partners.

This Privacy Policy includes information about the personal data collected by eBanqo, how we collect said personal data, and the manner in which eBanqo uses and processes this personal data.

Visiting the Website, creating an account for the purpose of eBanqo Messenger Trial, creating an account in order to use eBanqo Services, subscribing for the newsletter and/or a seminar, webinar or event implies your express approval (through disclosure of your personal information or opt-in) of the Privacy Policy and consequently how we collect, use and process your personal data.

Types of personal data that we collect:

When you create an account with us, order, or use any of our products or services, we collect personal data that you voluntarily provide during the account creation. eBanqo can collect and process the following personal data:

• Name
• Company name
• Designation
• Company address
• Email address
• Telephone number
• Google User name
• Password
• Information concerning your use of the Website, the eBanqo Messenger platform (hereinafter referred to as the “Platform”) and/or the eBanqo Messenger mobile application (hereinafter referred to as the “App”) (including, but not limited to IP address, browser type, the web pages you visited when you obtained access to the Website)
• The log-in details of your mobile device, as well as geographical location data (where appropriate)
• Photograph
• Communication preference
• All personal data freely provided to eBanqo (e.g. in light of correspondence with eBanqo)

eBanqo also automatically collects anonymous information regarding your use of the Website and eBanqo services via the Platform and/or the App. As such, eBanqo shall, for example, automatically log which sections of the Website, Platform and/or App you visit, which web browser you use and which website you visited when you obtained access to the Website. We cannot identify you through these data, but it allows eBanqo to draw up statistics regarding the use of the Website, the Platform and/or the App.


Methods of personal data collection
Personal data is collected by us when you voluntarily provide data to us in the following contexts:

• Request a quote
• Create a (trial) account
• Collaborate with eBanqo
• Download the e-book
• Visit the Website
• Visit the offices of eBanqo
• Use eBanqo services, whether or not via the Website, the Platform and/or the App, and whether or not using a mobile device
• Subscribe to the newsletter and/or the blog (via the Website or not)
• You provide information after a request by us for the verification of your identity (e.g. when you contact customer support)
• Incoming and outgoing correspondence with eBanqo
• Communicate ideas to eBanqo with regards to improving the services, the Platform and/or the App
• exchange business cards with us
• Make a connection between the Platform and social network platforms

The personal data collected by eBanqo are therefore expressly and voluntarily provided by you

We may also collect information automatically or passively via the use of cookies, where permitted, and mobile devise unique identifiers on our Website. Please refer to the section on cookies below for further explanation on how we may use cookies.

Use of personal data

eBanqo can use your personal data for the following legitimate business purposes:

• Registration of visitors when visiting the eBanqo offices
• Creating a (trial) account and confirmation thereof
• Performance of the agreement with eBanqo (including follow-up thereof)
• Providing eBanqo services, whether or not via the Website, the Platform and/or the App, and whether or not using a mobile device
• Providing technical support/assistance (e.g. in case of problems) to users or potential users
• Send targeted marketing and advertising, updates and promotional offers based on your communication preferences and – where applicable – upon explicit consent Issuing invoices and collecting payment
• Providing e-books, newsletters and/or blog
• Sending a confirmation upon subscription for a webinar, seminar, event
• Optimising the quality, management and content of the Website, the Platform and/or the App
• Creating statistics
• Drawing up a quote
• Conducting customer satisfaction studies, surveys and other market research
• Security of eBanqo offices

Please note that we may still use any aggregated and de-identified personal data for legitimate business purposes.
We will ensure that all personal data disclosed by you and that is held by us will be: (i) processed lawfully, fairly, and in a transparent manner; (ii) collected for specified, explicit, and legitimate business purposes and not further processed in a manner that is incompatible with those legitimate business purposes; (iii) adequate, relevant and limited to what is necessary; (iv) kept in a form which permits identification of data subjects for no longer than is necessary; and (v) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage. Processing takes place on the following legal grounds, as the case may be:

• You have given consent to the processing of your personal data for one or more specific purposes
• Processing is necessary for the performance of the agreement with eBanqo or in order to take steps at your request prior to entering into an agreement
• Processing is necessary for compliance with a legal obligation to which eBanqo is subject
• Processing is necessary in order to protect your vital interests or of another natural person
• Processing is necessary for the performance of a task carried out in the public interest
• Processing is necessary for the purposes of the legitimate business interests pursued by eBanqo, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, which require protection of personal data (in particular when you are a child).

Disclosure of personal data to third parties

eBanqo shall not disclose your personal data to third parties, unless it is necessary in the context of providing eBanqo services and optimizing them (including but not limited to maintenance works, payment processing, the delivery of services to eBanqo (e.g. subcontracting) and database management). For clarity, your personal data may be disclosed to payment providers, software providers, cloud partner, data center, external IT-consultants and service providers and you expressly agree to such disclosure. If it is necessary that eBanqo discloses your personal data to third parties in this context, the third party is required to use your personal data in accordance with the provisions of this Privacy Policy.
Notwithstanding the foregoing, it is however possible that eBanqo discloses your personal data:
• To the competent authorities (i) if eBanqo is obliged to do so under the law or under legal or future legal proceedings and (ii) to safeguard and defend our rights;
• If eBanqo, or the majority of its assets, are taken over by a third party, in which case your personal data – which eBanqo has collected – shall be one of the transferred assets;
• For the purpose of identifying similar profiles to your own, except if you have expressly opted out in this respect.
In all other cases, eBanqo will not sell, hire out or pass on your personal data to third parties, except when it (i) has obtained your permission to this end and (ii) has completed a data processing agreement with the third party in question, which contains the necessary guarantees regarding confidentiality and privacy compliance of your personal data.

Storage of personal data

Unless a longer storage period is required or justified (i) by the law or (ii) through compliance with another legal obligation, eBanqo shall only store your personal data for the period necessary to achieve and fulfil the purpose in question.

Cookie Notice

We may place small data files, called cookies, or similar technologies on your browser. A cookie is a small text file saved on your computer or mobile device when you visit a website. In some jurisdictions, we are not permitted to send cookies to the browser of a user without the prior consent of the affected user. In this case, we will seek such consent. The remainder of this section assumes that either the use of cookies is not restricted by applicable law, or if it is restricted that you have expressly and explicitly consent to the use of the cookies.
In the cookie banner on the Website and in this notice we will explain in clear and plain language the relevant details about their use. This includes: where they are hosted, the lifespan of the cookie, and their purpose. This list is subject to change and it may not include all such providers at any given time.
The Website uses four types of cookies; strictly necessary, performance, functional and marketing, and analytics cookies. These include first and third party cookies: first party cookies are set and controlled by eBanqo, while third party cookies are set and controlled by a third party tool or service.
The duration of a cookie varies: session cookies disappear from your computer or browser when you logout of your account or close your browser, while persistent cookies are stored even after you have closed the page.
With the exception of Strictly Necessary Cookies, cookies will only be placed on your device and/or browser after you confirm or update your preferences through the cookie banner.
If you decide to not allow opt-in cookies, the Website may not function as designed. For example, you may face issues logging in or retaining set preferences.

Your Privacy Rights

Even though we collect your data only for legitimate business purposes, your data stays your own. The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) the certain rights, with some limitations. We will establish a system to enable and facilitate the exercise of data subject rights related to:Right of access to personal data which eBanqo possibly has concerning you;

• Right to rectification, completion or update of your personal data;
• Right to change your cookie settings;
• Right to delete your personal data (‘right to be forgotten’) (eBanqo wishes to point out that in this context certain services will no longer be accessible and/or can no longer be provided if you delete certain required personal data);
• Right to limit the processing of your personal data;
• Right to transferability of your personal data;
• Right to object to/oppose the processing of your personal data;
• If you wish to invoke or exercise your privacy rights, please contact privacy@eBanqo.com.
• • In principle, you can exercise these rights free of charge via the above-mentioned form. In addition, you can always, via your personal account, update, modify and/or verify your personal data which you were required to submit when creating your (trial) account.
• The California Consumer Privacy Act (CCPA) provides California consumers with the right to request access to their personal information additional details about our information practices and deletion of their personal information (subject to certain exceptions). California consumers also have the right to opt out of sales of personal information, if applicable. We describe how California consumers can exercise their rights under the CCPA below. Please note that you may designate an authorized agent to exercise these rights on your behalf by providing written materials demonstrating that you have granted the authorized agent power of attorney. Please note that if an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the consumer about whom we collected personal information. We will not discriminate against you if you choose to exercise your rights under the CCPA.

You may request, no more than twice in a 12-month period, access to the specific pieces of personal information we have collected about you in the last 12 months. You may also request additional details about our information practices, including the categories of personal information we have collected about you, the sources of such collection, the categories of personal information we share for a legitimate business or commercial purposes, and the categories of third parties with whom we share your personal information. You may make these requests by contacting using the contact information provided below in the “Contact eBanqo” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.


You may request, no more than twice in a 12-month period, transportable copies of your personal information that we have collected about you in the last 12 months. You may make these requests by contacting using the contact information provided below in the “Contact eBanqo” Section. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.


You may request that we delete the personal information we have collected about you. Please note that we may retain certain information as required or permitted by applicable law. You may make these requests by contacting us using the contact information provided below in the “Contact eBanqo”” Section below. After submitting your request, please monitor your email for a verification email. We are required by law to verify your identity prior to granting access to your data in order to protect your privacy and security.

Security and Storage of personal data

eBanqo undertakes to take reasonable, physical, technological and organizational precautions in order to avoid (i) unauthorized access to your personal information, and (ii) loss, abuse or alteration of your personal data. Your personal data is safeguarded against loss, access, use, modification, disclosure, or other misuse. All reasonable steps are taken to prevent unauthorized use or disclosure of your personal data including without limitation firewalls, virus scan tools, employee training, and physical office security measures. Please note that despite these reasonable measures no security can absolutely guarantee the complete safety of your personal data.
eBanqo is located in the US and adheres to the laws of US. Personal data collected by eBanqo may be transferred to the US eBanqo shall store all personal data which it has collected in the cloud (with data center(s)) within the US. You expressly consent to your data being transferred to the US. Notwithstanding eBanqo’s security policy, the checks it carries out and the actions it proposes in this context, an infallible level of security cannot be guaranteed. Since no method of transmission or forwarding over the internet, or any method of electronic storage is 100% secure, eBanqo is, in this context, not in a position to guarantee absolute security.
Finally, the security of your (trial) account will also partly depend on the confidentiality of your password in obtaining access to the Platform and/or the App. eBanqo will never ask for your password, meaning that you will never be required to communicate it personally. If you have nonetheless communicated your password to a third party – for example because this third party has indicated that it wishes to offer additional services – this third party shall have access to your (trial) account and your personal data via your password. In such cases, you are liable for the transactions which occur as a result of the use made of your (trial) account. eBanqo therefore strongly advises you, if you observe that someone has accessed your (trial) account, to immediately change your password and contact us.


We will retain and store your personal data only for as long as necessary to fulfill the legitimate business purposes(s) for which it was collected and to comply with applicable laws and your consent to such purpose remains valid after termination of our relationship with you. When we no longer need information, we will take reasonable steps to destroy the information.

Email, Text, and Telephone Communications.

You can unsubscribe from email, text and phone communications at any time. To stop receiving our promotional emails, follow the unsubscribe instructions in the email messages you receive from us or contact us as described in the “How to Contact Us” Section below. To opt-out of receiving text messages, follow the opt-out instructions in the text messages that you receive from us. We will process your request within a reasonable time after receipt, in accordance with applicable laws. Note that you will continue to receive transaction-related emails regarding products or services you have requested. We may also send you certain non-promotional communications regarding Fracture and, to the extent permitted by law, you will not be able to opt-out of those communications (e.g., communications regarding updates to this privacy policy).

Updates to the Privacy Policy

eBanqo is entitled to update this Privacy Policy by posting a new version on the Website. We will alert you that changes have been made by indicating on the Privacy Policy the date it was last updated. As such, it is strongly recommended to regularly consult the Website and the page explaining the Privacy Policy, to make sure that you are aware of any changes. By visiting this Website, you are accepting the practices described in the current version of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, do not use the Website.

Children’s Privacy

We are concerned about the safety and privacy of children who use the Internet. We encourage the viewing of our website by children to be done with parental supervision. Consistent with the Children’s Online Privacy Protection Act of 1998 (“COPPA”), we will never knowingly request Personally Identifiable Information from anyone under the age of 13 without prior verifiable parental consent. If we become aware that a child under 13 has provided us with personal data without verifiable parental consent, we will use our best efforts to remove such information from our files. If a parent or guardian becomes aware that his or her child has provided us with personal data without verifiable parental consent, he or she should contact us at privacy@eBanqo.com.

Other websites

The Website may potentially contain hyperlinks to other websites. When you click on one of these links, you may be redirected to another website or internet source that could collect information about you through cookies or other technologies. eBanqo does not bear any responsibility, liability or control authority over these other websites or internet resources, nor about their collection, use and disclosure of your personal data. You must check the privacy policies of these other websites and internet sources in order to be able to judge whether they act in accordance with the privacy legislations.

Contact eBanqo

If you have questions about this Privacy Policy, or the manner in which eBanqo collects, uses or processes your personal data, please contact us via e-mail: privacy@eBanqo.com.