UNIFINANCE PRIVACY POLICY

General Provisions

UniFinance LLC (hereinafter – “UniFinance”, “we”, “our”, “us”, etc.) respects your privacy and treats your personal data with great care UniFinance LLC manages personal data in accordance with the General Data Protection Regulation standarts and frameworks and applicable national laws. In this privacy policy (Policy), the process of personal data collection, processing and protection through the use of our website, applications and services is detailed.

Concepts used in this Policy:

1. data controller – UniFinance LLC, legal entity code 304186270, with its registered office at Suite 305, Suite 305, Griffith Corporate Centre P.O. Box 1510, Beachmont, Kingstown St. Vincent and the Grenadines.

2. The data controller establishes the aims and appropriate measures for data processing;

3. data subject – any user, natural or legal person, who uses, used or has indicated the intention to use the services of UniFinance;

4. personal data – any information related to a user who can be identified, directly or indirectly, in particular by reference to a name and surname, personal identification number, location data and online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person;

5. data processing – any operation or set of operations which are performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction;

6. services – any services offered or provided by UniFinance.

7. Other concepts used in this Policy shall be understood in accordance with the definitions set by the General Data Protection Regulation (GDPR) – Regulation (EU) of the European Parliament and of the Council and other legislation.

8. This Policy is applied when you use, used or have indicated the intention to use UniFinance services, as well as in cases when relations had been established before this Policy came into force and (or) when your personal data was presented to or received by UniFinance.

9. Regarding any matter related to the processing of your personal data, please contact us by e-mail at [e-mail].

10. For the purpose of personal data processing, UniFinance reserves the right to use third party services. UniFinance aims to ensure that the users’ personal data are processed by the data processor in accordance with the UniFinance guidance and under existing legislation. The aforementioned data processors are obliged to maintain confidentiality and process personal data to the extent necessary for the performance of their functions or tasks.

11. In order to protect users’ personal data against unlawful access, misuse, copying, accidental or unlawful destruction, alteration, unauthorized disclosure and any other unlawful processing, UniFinance uses appropriate legal, administrative, technical and physical security measures.

12. By browsing this website and (or) using information contained therein, you confirm that you understood, agree and have familiarized yourself with this Privacy Policy. UniFinance reserves the right, at its discretion, to change this Privacy Policy. Notifications about changes will be given at the website.

13. Personal Data and Purposes of Its Processing

Personal data are to be received and processed if:

1. the user intends to enter or have entered electronic agreement (Terms of Services) with UniFinance;

2. consent was given by the user;

3. the processing of personal data is possible on the basis of existing legislation;

4. required in order to meet our legitimate interests (such as to enhance the quality of our services, to express and defend our company’s interests in legal disputes, to accomplish other legal acts, to prevent or reduce losses, to systematically monitor and prevent illegal activities, and to constantly assess the risks associated with the monitoring and prevention of illegal activities, etc.).

Purposes and collection of personal data:

1. Identity establishment and verification, communication with users, anti-money laundering and counter-terrorist financing measures, provision of services (account opening/managing, transfer/operations of digital assets, and other services, provided by UniFinance), execution of agreementual and other legal obligations. The user’s name, surname, personal number, address, date of birth, ID document and a copy of the ID document, photo, video (live audiovisual transmission) recording, nationality, e-mail address, phone number, IP address, occupation, public functions, and other information maybe required and further kept, processed, stored, kept ( which is necessary to comply with the frameworks on the prevention of money laundering and terrorist financing).

2. These data are received directly from the data subject, as well as from third parties if possible in accordance to applicable law, personal data verification databases, companies processing registers of international sanctions, and other persons.

3. Data are stored for 5 (five) years from the date of termination of the business relationship. This time limit may be extended for up to 2 (two) years upon reasoned instruction of a competent authority. The time limit for data storage is established with purpose of the prevention of anti-money laundering and terrorist financing.

4. These data may be provided to the supervisory authority, credit, financial, payments and (or) electronic money institutions, payment receivers, lawyers, auditors, and, if you give your consent, to other subjects with legal right to access to this information and subjects with whom we have a agreement.

5. This data may be provided to third parties in case your transaction was through a third party or a third-party partner is engaged in the transaction execution.

6. The processing of these data is required to comply with the frameworks on the prevention of money laundering and terrorist financing. If a user refuses to provide this information, UniFinance retains the right not to enter or to terminate the agreement and to refuse service.

7. These data may be provided to companies processing consolidated debtor files, credit, financial, payments and (or) electronic money institutions, lawyers, bailiffs, courts, law enforcement institutions, the and other subjects with legal right to access to this information.

8. These data may be provided to third parties in case the third party is related to the debt creation.

9. This data processing is required by the laws of the Republic of Lithuania and our Terms and Conditions. If a user refuses to provide this information, UniFinance retains the right not to enter or to terminate the agreement and to refuse service.

10. Maintenance and administration of a business relationship with the user, correspondence with the user, assessment of the user’s needs, consultation. Data necessary to fulfill the aforementioned principles: user’s name, surname, address, date of birth, e-mail address, phone number and other information received directly from the data subject. For this purpose, the information is stored for 5 (five) years from the date of termination of the business relationship and is not provided to other persons. The processing of these data is required by our Terms of Services. If a user refuses to provide us this information, UniFinance retains the right not to enter or terminate the agreement and to refuse service.

11. Informing users about our services. The user’s e-mail address, provided directly to us by the data subject, is required, and, with the user’s consent, it is used to provide information about our services. The user retains the right to refuse to receive such information and he or she can exercise this right by sending an e-mail to UniFinance. The user’s e-mail address, with his or her agreement, is stored for 24 (twenty-four) months from the date of termination of the business relationship. The information stored for this purpose is not provided to other persons.

12. Protection of our lawful interests, dispute prevention and collection of evidence. Information necessary for the processing: user’s IP address, payment statements, phone records, correspondence with the user, information about legal or administrative proceedings the user participates in, payable amounts and other information provided to us for the aforementioned purposes. This information is stored for 5 (five) years from the date of termination of the business relationship with the user. These data may be provided to the supervisory authority, lawyers, courts, law enforcement institutions, other subjects with legal right to access this information, and, with your consent and (or) upon request of law enforcement authorities established in accordance with the applicable law. This information is not provided to third parties, except on the basis set out by law enforcement authorities and this Policy.

13. Direct marketing. To perform this activity, the user’s e-mail address, received directly from the data subject, is required. For this purpose, the information is stored for 24 (twenty-four) months from the date of termination of the business relationship. This information may be provided to search engines and social networks, but not to other persons.

14. Direct marketing requires your consent. You have the right to object to direct marketing and to withdraw your consent at any time by writing us.

15. The personal data collected for the purposes mentioned above, except name, surname, personal number, number of your ID document and home address, may be processed for the purposes of statistical analysis. In that case, your personal data is processed in a manner that ensures that it would not be possible to identify concrete data subjects included in the scope of statistical analysis. Personal data collection for the purposes of statistical analysis is based on the legitimate interests of analyzing, improving and developing the activities performed by UniFinance.

16. You retain the right to disagree and refuse the processing of your personal data for the purposes of statistical analysis at any time and in any form, by informing UniFinance. UniFinance reserves the right to further process the data further for statistical analysis if proven that the data is being processed for legal reasons that override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of the Data Controller’s legitimate interests.

17. By collecting and using personal data entrusted to us and received from other sources, we adhere to legality, fairness, transparency, purpose limitation, data minimization, precision, limitation of storage period, integrity and confidentiality principles.

18. UniFinance undertakes to process your personal data only for the legitimate purposes specified in this Policy, except in cases specified by law.

Personal data Processing and Third Parties

All information specified in paragraph II shall not be provided to any third party without your consent, except in cases where it is required by applicable legislation or necessary for the purposes of service provision.

UniFinance is not responsible for ensuring users’ privacy in third parties’ websites, even in cases where the user has accessed third-party websites by using links provided on this website. UniFinance recommends that you familiarize yourself with the privacy policies of third-party websites” beforehand.

Cookies

Cookies are used at the UniFinance website. They are intended to improve the functionality and performance of the website.

By browsing the UniFinance website, you agree to our use of cookies. You retain the right to disagree with our use of cookies, however, disabling cookies might prevent some functions of our website from working correctly.

UniFinance bears no responsibility for the use of cookies by third parties.

Client Rights

The data subject has the right to:

1. obtain confirmation from the data controller as to whether or not personal data concerning him or her is being processed, and, where that is the case, access to the personal data and information regarding its processing;

2. have inaccurate personal data rectified by the data controller without undue delay. Taking into account the purpose of the processing, the user has the right to have incomplete personal information completed, inter alia, by providing an additional statement;

3. request the data controller to restrict data processing in cases specified in applicable law;

4. obtain from the data controller the erasure of personal data concerning him or her without undue delay, except keeping personal data required to meet frameworks on the prevention of money laundering and terrorist financing;

5. agree with the processing of personal data for direct marketing purposes, including profiling, and for our legitimate interests;

6. have personal data transferred to another data controller or provided directly in the manner most convenient to him or her (this only concerns personal data provided by the data subject directly and which is processed by automated means on the basis of consent or conclusion and performance of the agreement);

7. withdraw your consent, without prejudice to the previous use of your personal data;

8. lodge a complaint to the appropriate authorities;

9. You may submit a request to exercise any of your aforementioned rights to the e-mail address [e-mail]

10. We will reply to your request in up to 14 (fourteen) calendar days from the day the request is received. In exceptional circumstances requiring additional time, with prior notice, we have the right to extend the time limit to respond to your request or to other requirements provided in your request for up to 30 (thirty) calendar days from the date of submission of your request.