TABLE OF CONTENTS
- 1. The Scope
- 2. What Personal Data Do We Have on You
- 3. No Requirement to Disclose Personal Information
- 4. What Personal Data We Collect
- 5. Legal Basis and Reasons for Processing of Personal Data
- 6. Transfer of Personal Data to Third Party
- 7. Cookies and Services from Third Parties
- 8. Retention of Personal Data
- 9. International Transfers
- 10. Security of Personal Data
- 11. Hyperlinks to Third Party Websites
- 12. Modifications to This Policy
- 13. Your Rights
Privacy Policy
We (referred to as "We", "Us" or "Our") are committed to protecting your Personal Data and your privacy. This Privacy Policy explains how we collect and store the information you provide through the website Fundektris (the "Website").
We want you to be able to make informed choices about how your Personal Data is used and processed. We use a range of methods and procedures to give you relevant information. Where we believe you need specific details, we'll provide them at the appropriate time. We're happy to answer any questions you may have regarding the limitations imposed by law.
1. The Scope
1.1 This policy explains the type of Personal Data the Company collects about individuals and how it processes that data, shares it with third parties, secures its processes, and so on.
1.2 This Policy concerns information relating to an identified or identifiable natural person. An identifiable natural person can be defined as someone who is directly identifiable or who can be identified through a combination of additional information we hold or are able to access.
1.3 Under this Policy, "processing" refers to any operation involving the use or collection of Personal Data, including its management, organisation, and storage.
1.4 Our services are intended for general audiences and are not designed for anyone under the age of 18. We do not knowingly seek or collect information from any person under 18 years old, nor do we knowingly permit such persons to use our services. If we become aware that we hold any information about children, we will erase it as quickly as possible.
2. What Personal Data Do We Have on You
2.1 We collect Personal Data when you access the service and channels or visit our website. In certain cases, we may also request your Personal Data.
2.2 In other cases, we collect your Personal Data by analysing how you use our Services or service channels, or by receiving your information from our third-party partners.
3. No Requirement to Disclose Personal Information
3.1 You are not required to provide Us with any personal Data. In certain circumstances, however, withholding such Personal Data may prevent Us from offering the Services or stop users from accessing the website.
4. What Personal Data We Collect
4.1 This includes information about your online activity log, as well as traffic data including:
- IP address
- Date of access and time of access
- Language you used
- Software crash logs
- Type of browser used
- Information regarding the device that you utilised
4.2 The information collected is not private and cannot be used to identify you.
4.3 Personal Data we receive from you: any personal data you choose to provide to Us when you connect with a third party's online trading platform through Us.
4.4 Personal information you provide directly to third-party platforms to facilitate trade: this includes your full name, address, phone number, and email address.
5. Legal Basis and Reasons for Processing of Personal Data
5.1 The company processes your Personal Data for the purposes set out in this section, and in line with the applicable legal basis.
5.2 Without a legal basis, the Company cannot use Personal Data relating to you. The legal grounds on which the Company may rely to process Personal Data concerning you:
- You have given your consent to the processing of your Personal Data for one or more reasons. This applies when you submit personal information via the Website so that we can transfer it to a third-party trading platform.
- The Company or a third party may need to process data to serve their legitimate interests. For example, this is necessary to improve Our Services or to defend legal claims.
- Processing must meet an obligation of law.
5.3 Contact Us via email for further details on the processing required to protect our legitimate interests.
5.4 The following sets out the reasons and legal grounds on which we may use the information you provide to us:
Scope
Legal Basis
1. To share your personal information with third parties at your request in order to access digital trading
If you request it, we may collect Personal Data from you to forward it to third-party companies.
You have given consent to the processing of your Personal Data for one or more reasons.
2. To respond to your requests, questions or concerns
Personal Data is necessary to help us answer any questions you may have about the Services.
The legitimate interests of the Company or a third party require processing.
3. To fulfil any legal obligation, or administrative, judicial or legal requirement, Personal Data is processed to meet such legal requirements.
To ensure compliance with legal obligations, processing is required.
4. To improve Our Services Personal
Data may be used by us to improve Our Services. This includes, among other things, any crash or malfunction reports that we collect in relation to the Services.
The legitimate interests of the Company or those of a third party require processing.
5. To stop fraud and misuse of Our Services.
The legitimate interests of the Company or of a third party require processing.
6. To carry out and manage activities in line with the requirements of Our Services
These include back-office functions, business development, strategic decision-making, oversight mechanisms, and similar tasks.
The legitimate interests of the Company or those of a third party require processing.
7. To carry out analysis, such as statistical analysis
To make decisions on various issues, we use a range of analytical methods (including statistical ones).
The legitimate interests of the Company or those of a third party require processing.
8. To protect our assets, rights and interests, as well as those of third parties
We may process Personal Data to protect our rights, interests and assets, or those of third parties, in line with any applicable laws, regulations or agreements and any conditions, terms or policies.
The legitimate interests of the Company or a third party require processing.
6. Transfer of Personal Data to Third Party
6.1 The Company may also share Personal Data with third-party companies that provide services to us, such as hosting and storage providers, including IP address information and analysis of user experiences.
6.2 You may also request that we share specific Personal Data about you with third-party trading platforms. In such cases, we will provide the Personal Data you give us to those third-party trading platforms. The use of your Personal Data is then subject to their privacy policies. Your Personal Data may be shared with multiple trading platforms.
6.3 The Company may share Personal Data with related entities or business partners. This gives the Company the resources it needs to enhance and improve the products and services it provides to its customers.
6.4 Where necessary to protect the rights of third parties or assets, the Company may disclose Personal Data to regulatory, local, or other official authorities.
6.5 We may also share Personal Data about you with potential investors or buyers, or with lenders to the Company or any other company within the group, should such a transaction occur (including the transfer or sale of assets belonging to the Company or any other company within the group), or as part of any merger, restructuring, consolidation or bankruptcy of the Company or any other business within the group.
7. Cookies and Services from Third Parties
7.1 We may use third-party services, such as advertising partners on our website or analytics companies. These companies may also use cookies or other technologies.
7.2 Cookies are small text files stored on your device each time you visit or access the website. They are used to collect information about your preferences and browsing habits, helping us improve the user experience, remember your settings, and tailor the products and services you may enjoy. Cookies are also used for statistics and analytics.
7.3 Some of the cookies we use are session cookies. These are temporarily downloaded to your device and last only for a short time, until you close your browser. Other cookies are persistent. Persistent cookies remain on your device for a period after you close your browser. They help the Website recognise you as a returning user and allow you to return to the site.
The type of cookie
Cookies are absolutely necessary
Scope
These cookies are essential for you to access the features you've requested and to navigate our website. They are used to deliver the information, products and services you've asked us for.
They are required for your device to download and stream data, allowing you to move around the website, use its features, and return to pages you've previously visited.
Additional Information
Cookies collect Personal Data, such as your username and the date of your last login, to confirm that you are signed in to the site. They are deleted once you close your web browser (session Cookies).
The type of cookie
Functionality Cookies
Scope
Cookies allow us to recognise you each time you visit our site and to save your preferences.
Additional Information
They remain until their expiry date and are kept even after the browser is closed.
The type of cookie
Cookies for performance
Scope
Cookies help Us collect statistical data on the site's performance and improve it. They also allow Us to carry out analysis of our website.
Additional Information
Cookies store anonymous data that isn't linked to any identifiable or identified individual. Some are deleted when you close your browser, while others remain valid indefinitely.
7.4 Cookies are blocked or removed. To prevent or delete cookies, you need to adjust your browser's settings. Below are links to guide you through the process for some of the most popular browsers:
- Firefox
- Microsoft Edge
- Google Chrome
- Safari
7.5 However, please be aware that if this happens, some or all of the Website's functions and features may not work as you expect.
Online Tracking Notice: This service does not currently support do-not-track signals.
8. Retention of Personal Data
8.1 The Company will retain your Personal Data for as long as necessary to fulfil the purpose of processing it, as described in this Policy, or for longer periods where permitted by law, regulations, policies, and any applicable orders.
8.2 We'll share your information with third-party trading platforms for a period of 12 months. If you agree to this, we will continue to share your data for a further 12 months.
8.3 We regularly review the Personal Data we hold to confirm it is no longer required.
9. International Transfers
9.1 Your personal information may be transferred to other countries (i.e. your personal data may be sent to a third country or to international organisations). Company takes all necessary steps to safeguard the Personal Data you provide and to ensure that data users can assert their rights and access effective legal recourse.
These protections and safeguards are available to everyone residing in the EEA (European Economic Area):
- Transfer to a third country or international organisation that the EU Commission has determined provides adequate protection for Personal Data transferred to it, in accordance with article 45(3) of Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "GDPR")
- The transfer is carried out under a legally binding and enforceable agreement between public bodies or authorities, in line with Article 46(2)(a)
- The transfer was carried out in line with the standard data protection clauses adopted by the EU Commission under Article 46(2)(c) of the GDPR
9.3 The Company can provide details of the security measures it uses to protect your Personal Data transferred to third-party countries or international organisations. Send an email to: support@fundektris.app
10. Security of Personal Data
10.1 We have implemented appropriate organisational and technical measures to protect Personal Data. This includes preventing the accidental or unlawful destruction, loss, or alteration of Personal Data.
10.2 We cannot guarantee or warrant that the security of your Personal Data will be maintained without error. We also cannot be held accountable for any intangible, incidental or consequential damages arising from the use or disclosure of Personal Data. This includes, but is not restricted to, any Personal Data disclosed due to errors in transmission, unauthorised access by a third party, or any other cause beyond our control.
10.3 Where required by legal obligations or other circumstances beyond our control, we may have to disclose your Personal Data to third parties, such as public authorities. In these cases, we cannot control the level of security that such third parties apply to your Personal Data.
10.4 Personal Data cannot be transmitted over the internet in a completely secure way. The Company cannot guarantee the security of any Personal Data you send to Us online.
11. Hyperlinks to Third Party Websites
11.1 The website contains links to third-party sites and applications. These sites and applications are not under the Company's supervision. We are not responsible for the collection or processing of Personal Data by these websites or apps. This Policy does not apply to actions taken through such sites or apps.
11.2 Before accessing or using any third-party website or app We recommend you read their privacy policies first. We also suggest you provide any Personal Data to them.
12. Modifications to This Policy
12.1 This Policy may be amended at any time. If we update this Policy, we will notify you of the changes by posting the revised Policy on our website.
12.2 In addition, when we make significant changes to this Policy, we will aim to notify you through the methods we consider appropriate and will publish an announcement on our website.
12.3 Unless otherwise stated, any amendments will take effect once the revised Policy is published.
13. Your Rights
13.1 You have the right to ask us to verify the accuracy of the Personal Data we collect about you, to correct any errors, and to delete all Personal Data we no longer require. You may also restrict the scope and types of processing of your personal information.
13.2 If you reside in the EEA, please refer to this page. These rights apply to the information you provide in relation to your Personal Data. To exercise your rights, you may send an email to the address below.
13.3 Access rights The Company can verify whether Personal Data relating to you is being processed. If it is, you are entitled to access your Personal Data. The Company will provide an electronic copy of the Personal Data currently being processed and may charge a reasonable fee for any additional copies. If you request it, the data will be made available electronically. The right to access Personal Data must not conflict with the rights and freedoms of others. If a request would adversely affect the rights and freedoms of another person, the Company may refuse to comply with it or limit the extent to which it does so.
13.4 Right to rectification The Company is entitled to rectify inaccurate Personal Data. You have the right to request that any incomplete Personal Data concerning you be corrected, taking into account the purpose of the processing.
13.5 Right to Erasure The following reasons apply: (a) the Personal Data are no longer required for the purpose for which they were collected or processed; (b) you withdraw consent and there is no legal basis for processing; (c) you object at any time, for a reason specific to your situation, to the processing of Personal Data about yourself that is based on legitimate interests pursued either by Us or by a third party; (e) the Personal Data are unlawfully processed; or (f) the Personal Data must be erased to meet the company's legal obligation. This right does not apply where the processing is necessary (a) to fulfil an obligation imposed by law that requires processing under European Union law or Member State law; or (b) to establish, exercise or defend legal rights.
13.6 Processing restrictions If you have concerns about the accuracy of your Personal Data, you can ask the Company to limit how your Personal Data is processed. If you request that Personal Data be restricted, it may only be kept if you give consent, or in order to establish, exercise or defend legal rights, or to protect the rights of another individual, or for reasons of significant public interest within the European Union or a Member State.
13.7 Right to data portability Where processing is carried out by automated means and is based on your consent or on a contract to which you are a party, you have the legal right to receive and review the Personal Data you have provided to the Company. You are entitled to request that your Personal Data be transferred directly from the Company to another controller, where technically feasible. Your rights under the right to erasure are not affected by exercising your right to data portability. The right to data portability must not adversely affect the rights or freedoms of others.
13.8 Right to object You have the right at any time to object to any use of Personal Data concerning you that is based on legitimate interests pursued by the Company or a third party. This is not limited to profiling based solely on these legitimate interests. Where we can establish compelling legitimate grounds for processing Personal Data, we may continue to do so unless you can demonstrate that your rights, freedoms or interests override them, or that the processing relates to the exercise, establishment or defence of legal rights. Regarding direct marketing, you have the right at any time to object to the processing of Personal Data concerning you.
13.9 Right to withdraw consent You may withdraw your consent for Us to process Personal Data about you at any time. This will not affect the legality and lawfulness of any processing that relied on your consent prior to its withdrawal. You are entitled to lodge a complaint with the authority that supervises you. You may appeal to a supervisory authority established by a member state to protect the fundamental rights of individuals in relation to the processing of Personal Data within the European Union. The laws of the European Union and Member States may limit your rights in relation to Personal Data concerning you, as detailed in this section 13.
13.10 We will provide the information you request, in line with the rights set out in section 13 of this agreement, within one month of receiving your request. This period may be extended by up to two months where necessary, depending on the nature and number of requests. Within one month of receiving your request, we will inform you of any extension and the reasons for it.
13.11 Provided it does not conflict with the provisions of section 13 of the law, any information you request under your rights in section 13 will be provided free of charge. Where a request is unjustified or excessive, particularly if it is repeated, we may charge a reasonable fee to cover the administrative costs of supplying the information or carrying out the action requested. We may also decline to act.
13.12 If we have any doubts about the identity of the person who submitted your request, we may ask them to provide reasonable proof of their identity.
This Privacy Policy should be read alongside our Term Of Use and Risk Disclosure.
Fundektris 59-60 Grosvenor Street, Mayfair, London, W1K 3HZ | support@fundektris.app