Privacy Statement

INTRODUCTION

Welcome to FinVentures Limited’s Privacy Statement.

FinVentures respects your privacy and is committed to protecting your Personal Data, also referred to herein as Personal Information. This privacy notice will inform you as to how we look after your personal data when you use our services (regardless of where you are) and tell you about your privacy rights and how the law protects you.

We will collect and process all Personal Data that you provide us, be that by filling in forms on the website or by corresponding with us via email. This includes information you provide us when you subscribe to any of our services. If you contact us, we will keep a record of that correspondence.

By entering your details in the fields requested, you enable us and our service providers to provide you with the services you select. Whenever you provide such personal information, we will treat that information in accordance with this policy. When using your Personal Information, we will act in accordance with current legislation and aim to meet current Internet best practice.

FinVentures is the controller and responsible for your personal data (collectively referred to as “FinVentures”, “we”, “us” or “our” in this privacy statement).

Our services are not available to anyone under the age of 18 years and therefore we do not knowingly collect data relating to individuals under this age.

This privacy statement is provided in a layered format so you can click through to the specific areas set out below.

1. THE DATA WE COLLECT ABOUT YOU
2. HOW WE COLLECT AND USE INFORMATION
3. COOKIES POLICY
4. WHO WE SHARE INFORMATION WITH
5. HOW WE APPLY OUR POLICY
6. INTERNATIONAL TRANSFERS
7. YOUR LEGAL RIGHTS
8. CHANGES TO THIS STATEMENT
9. CONTACTING THE REGULATORY AUTHORITY

THE DATA WE COLLECT ABOUT YOU

Personal Data, means any information about an individual from which that person can be identified. As defined by the General Data Protection Regulation (GDPR), we are data controllers and have a lawful basis for collecting your Personal Information where you have given us clear consent to do so. Please note that we are not able to provide our services if you do not consent to us using your data in the manner set out within this policy.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, date of birth, gender and identity numbers as contained within your provided identity documents.
• Contact Data includes your home address, email address, telephone numbers and ID for Skype or other social media and communication platforms.
• Financial Data includes details about payments to and from you and other details of products and services you have purchased from us including bank and other payment service provider details. Please note that these details are also held subject to the relevant payment legislation.
• Technical Data includes internet protocol (IP) address, your login data, browser type and version and other technology on the devices you use to access this website.
• Profile Data includes your username, password, cookies and any unique identifier assigned by us.
• Usage Data includes information about how you use and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

HOW WE COLLECT AND USE INFORMATION

We collect personal information on our customers in various ways, including: subscriptions; sign up for products and/or services by telephone, the Internet or email; offers; competition entry forms; or feedback, research or request forms and in writing or through any other medium.

We may use your personal details:

• to verify your identity to confirm your continued eligibility to use our products and services, to protect against fraud and to comply with relevant laws;
• to meet orders or requests for services or information; to process payments; and to keep our records up-to-date;
• to tell you by telephone, post or email about special offers and current or new products and/or services that you may be interested in;
• to enable other people or businesses to carry out our work on our behalf;
• where you have given us your permission, to pass your information to carefully selected organisations to allow them to tell you about their special offers or products and services that may be of interest to you.

In some instances, FinVentures and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of FinVentures’ online presence, and to measure the effectiveness of our marketing activities.

COOKIES POLICY

We use Cookies to make our website user-friendly, maintain and improve website performance, maintaining our systems safely. Some Cookies remain stored on your end device until you delete them. They enable us to recognize your browser the next time you visit our website.

What types of Cookies do we use?

There are several different types of cookies, however, our website uses:

• Functionality – We use these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
• Advertising – We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address.
• Web beacons – these mechanisms can be used to deliver a cookie to your browser. They can also be used in email marketing to identify to the sender if an email has been opened.
• Session cookies – temporary cookies that are not stored on your computer or mobile device. They are used as part of the login, authentication and session management flows. Certain session cookies are also used to understand, for example, if you are a new visitor or a visitor returning as part of the same browsing session. These session cookies are erased when you close your browser, or after extended inactivity.
• Persistent cookies – placed on your device for a pre-determined length of time when you visit this site. They are used to understand (through Google Analytics) what areas of our websites and platform are most popular, and how customers and users engage with them.

The use of Google Analytics and your data

We use Google Analytics. Google Analytics is a web analytics service provided by Google that tracks and reports on all traffic that passes through our website. It also integrates with AdWords, allowing us to review the performance of our online ad campaigns by tracking website visits, conversion rates, and other key metrics.

The information generated by the Cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States of America. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, to provide the website operator with other services relating to website activity and internet usage, and to compile reports on performance based on demographic characteristics and interests.

The IP address transmitted by your browser as part of Google Analytics is not combined with other data from Google. You may refuse the use of Cookies by selecting the appropriate settings on your browser. Please note, however, that in this case you may not be able to use all functions of our website to their full extent. You can also prevent Google from collecting the data generated by the Cookie and related to your use of the website (including your IP address) and from processing this data by downloading and installing the browser plugin. To opt out of being tracked by Google Analytics across all websites, visithttp://tools.google.com/dlpage/gaoptout .

How do you change your cookie settings?

Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set, visithttps://www.aboutcookies.org.uk/ .

Find out how to manage cookies on popular browsers:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

To find information relating to other browsers, visit the browser developer's website.

BY NAVIGATING ON OUR WEB SITE OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

WHO WE SHARE INFORMATION WITH

To provide you with our service, we share your data with a small number of trusted third-party service providers. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

HOW WE APPLY OUR POLICY

In order to put our policy into practice, we use our best endeavours to follow seven guidelines:

1. We will ensure our systems are secure to protect your Personal Information from misuse and follow appropriate physical, electronic and managerial procedures to safeguard it;
2. We will respect your privacy in the way that we contact you, whether by telephone, email or text message;
3. We will not hold your Personal Information for longer than is necessary to effectively provide you with our services and comply with applicable legislation;
4. We will not sell, trade or rent your Personal Information.
5. We will comply promptly with any instructions from you to update your Personal Information or requests from you to see the Personal Information that we hold on you;
6. We will comply with lawful requests to disclose personal information to certain authorities (e.g. the police);
7. We may monitor and record any telephone calls to ensure we follow your instructions correctly and to improve our service
8. Data is not only collected for services provided but for due diligence purposes to discharge all legal and regulatory obligations

INTERNATIONAL TRANSFERS

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your Personal Data. These rules are called "binding corporate rules".

Some of our external third parties/ service providers are based outside of the European Economic Area (EEA) so their processing of your Personal Data will involve a transfer outside the EEA.

Whenever we transfer your Personal Data outside of the EEA, we ensure that the organisation receiving the personal data has provided adequate safeguards.

Adequate safeguards may be provided for by:

• a legally binding agreement between public authorities or bodies (e.g. the Privacy Shield in the US);
• standard or 'Model' data protection clauses in the form of template transfer clauses adopted by the European Commission;
• standard data protection clauses in the form of template transfer clauses adopted by a supervisory authority and approved by the European Commission;
• compliance with an approved code of conduct approved by a supervisory authority;
• certification under an approved certification mechanism as provided for in the GDPR;
• contractual clauses agreed authorised by the competent supervisory authority;

YOUR LEGAL RIGHTS

Under certain circumstances, you have rights under data protection laws in relation to your Personal Data. They are as follows:

• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via email: privacy@iaecsp.org.

If you believe that the processing of your data violates the data protection law or your data protection claims have otherwise been violated in any way, you can contact our Data Protection Officer at privacy@iaecsp.org or the Gibraltar Regulatory Authority.

CHANGES TO THIS STATEMENT

FinVentures may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the "updated" date at the top of this page. Any changes to the processing of personal information as described in this Privacy Statement affecting you will be communicated to you through an appropriate channel, depending on how we normally communicate with you.

CONTACTING THE REGULATORY AUTHORITY

Should you wish to report a complaint or if you feel that We had not addressed your concern in a satisfactory manner, you may contact the Gibraltar Regulatory Authority.

You can contact the Gibraltar Regulatory Authority:

Address: 2nd floor, Eurotowers 4, 1 Europort Road, Gibraltar;

Tel.: (+350) 20074636;

Fax: (+350) 20072166;

E-mail: info@gra.gi