Last updated on the 1st of April 2023

PRIVACY POLICY OF LONVEST PLATFORM

This Privacy Policy (hereinafter also referred as “Policy”) along with the General Terms and Conditions, Anti-Money Laundering and Counter Terrorist Financing Policy, Cookie Policy constitutes an agreement between User and Lonvest which are represented by the following company:

• Lonvest Platform d.o.o.:

- Registry code: 081501022;

- Address: Zagreb (Grad Zagreb), Lovinčićeva ulica 3.

DISCLAIMER. By visiting, accessing or using our Website, Services, you consent to this Privacy Policy, so please read it carefully. If you consider any term or condition of this Privacy Policy to be unacceptable, please do not visit, access or use the Website or Services of the Lonvest.

LEGISLATION

This Policy was drafted under the rules prescribed by Regulation (EU) 2016/679 (General Data Protection Regulation), Law on the Implementation of the General Data Protection Regulation of Croatia in order to satisfy necessary compliance procedures and guarantee high level of protection of your personal data. Please, examine your rights under these acts to understand them fully.

GENERAL PROVISIONS 

In relation which undergo the rules of this Policy, Lonvest acts as a controller of the personal data of a User. Personal data means any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Please note, that Lonvest do not will not gather any sensitive personal data. All information Lonvest gathers in order to provide Users with our Services should be considered as data Lonvest must protect according to the legislative requirements. 

Additionally, you should take into account that GDPR does not apply to legal entities. But with respect to our Users, Lonvest takes the data of legal entities seriously and does all necessary actions to preserve the privacy of their data.

 DISCLAIMER. Lonvest does not intentionally collect any information about natural persons who are under the age of 18. In addition, Lonvest does not knowingly gather information about natural persons recognized by the court as incapacitated or partially incapacitated, which means the inability of such natural persons to legally enter into relationships with Lonvest and the inability to understand the meaning of their actions. 

DATA PROCESSING

Lonvest may process your personal data in different ways and using different methods including but not limited with following: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Lonvest processes personal data for following purposes:

• maintain and provide our Services as much and as thoroughly as Lonvest can;
• analyze ways of using our Services and Website by our Users;
• improve and enhance user experience in using our Services and Website;
• find and prevent money laundering and fraud.

Usually, Users personally provide us with their data by directly interacting with Lonvest via: 

• visiting our Website;
• applying for our Services and/or making use of any of our Services;
• creating an account;
• requesting marketing to be sent to User, for example by subscribing to Lonvest newsletters;
• giving us feedback or contacting us.

Lonvest will also use third parties and/or publicly available sources to obtain data related to you. Lonvest may use the following sources:

• fraud and crime prevention agencies;
• publicly available information on the Internet;
• public blockchain.

TYPES OF DATA WE COLLECT

All User’s data will be collected with respect to our General Terms and Conditions, Anti-Money Laundering and Counter Terroris Financing Policy, and Cookie Policy. You can get acquainted thoroughly with these types of data in above mentioned documents. Here we indicate these data in general types:

Private Data:

• full name (full legal name), email address, home address (registered or business address), date of birth and gender, nationality, phone number;
• documents national identity cards, passports, driving licenses or other forms of identification documents, tax ID number, visa information, utility bills;
• transaction history, and/or tax identification, source of funds and related documentation, other information that is needed to complete CDD procedures;
• nature and details of employment;  
• the customer’s source of funds, i.e. where the funds or assets that will be used for the business relationship or transaction were derived (e.g. income, business profits, investments, dividends, inheritance, property sale, business sale, etc.);  
• the customer’s source of wealth, i.e. how the customer derived his or her or its wealth, particularly in higher risk scenarios (e.g. income, business profits, investments, dividends; inheritance, property sale, business sale, etc.) and level of wealth (i.e. the total value of a applicant for business’ or customer’s wealth);  
• data, whether the customer has a criminal record or is a known associate of criminals or criminal organizations; and  
• whether the customer is a PEP. 
• chat messages with Customer Support, chat attachments which may include screenshots, photos, videos etc., survey responses.

Lonvest collects some sort of information automatically while you are using our Services and interacting with our Website to the extent permitted by applicable legislation. This information can be set in following categories:

• Usage data: information about how you use the Website and Services, and other offerings made available by us, including:

- device download time,

- interaction type and time,

- event time, name and source.

• Marketing data: your preferences in receiving marketing from us or third parties.
• Online Identifiers: geo location/tracking details, browser fingerprint, operating system, browser name and version, and/or personal IP addresses.

We may also automatically receive and record the following information on our server logs:

• how you came to our Website and use the Services;
• device type and unique device identification numbers;
• device event information (such as crashes, system activity and hardware settings, browser type, browser language, the date and time of your request and referral URL);
• how your device interacts with our Website and Services, including pages accessed and links clicked;
• broad geographic location (e.g. country or city-level location); and
• other technical data collected through cookies, pixel tags and other similar technologies that uniquely identify your browser.

RIGHTS OF THE USER

If you have any questions, problems, issues or complaints, contact us at [email protected]. Under the GDPR Lonvest has 1 month to answer your request and this term may be extended to 3 months due to complexity and difficulty of your problem. If you are not satisfied with our solution to your problem, you can contact authorities in the field of private data protection. List of such authorities in the EU available here.  

Under the GDPR, Users have the following rights related to their personal information:

• Right to be informed: Your right to be informed is met by the provision of this Privacy Policy, and similar information when Lonvest communicates with you directly – at the point of contact.
• Right of access: You have the right to obtain a copy of personal data that Lonvest holds about you and other information specified in the GDPR, although there are exceptions to what Lonvest is obliged to disclose.
• Right to rectification: You have the right to ask us to rectify any inaccurate data that Lonvest holds about you.
• Right to erasure (‘right to be forgotten’): You have the right to request that Lonvest erases personal data about you that Lonvest holds. This is not an absolute right, and depending on the legal basis that applies, Lonvest may have overriding legitimate grounds to continue to process the data.
• Right to restriction of processing: You have the right to request that Lonvest restrict processing of personal data about you that Lonvest hold. You can ask us to do this for example where you contest the accuracy of the data.
• Right to object: You have the right to object to processing of personal data about you on grounds relating to your particular situation. The right is not absolute and Lonvest may continue to use the data if Lonvest can demonstrate compelling legitimate grounds.
• Right to data portability: This right is only available where the legal basis for processing under the GDPR is consent, or for the purposes of a contract between you and the Lonvest. For this to apply the data must be held in electronic form. The right is to be provided with the data in a commonly used electronic format.
• Rights in relation to automated individual decision-making including profiling: You have the right to object to being subject to a decision based solely on automated processing, including profiling. Should Lonvest performs any automated decision-making, Lonvest will record this in this Privacy Policy, and ensure that you have an opportunity to request that the decision involves personal consideration. 
• Right to complain to the Information Commissioner: You have the right to complain to the Information Commissioner if you are not satisfied with any aspect of how the Lonvest processes your personal data or believe that Lonvest is not meeting our responsibilities as a data controller. 

Please note that mentioned rights are not absolute and may be limited in order to complete regulatory requirements and Lonvest legal interest. Take into account that Lonvest may request to provide some details necessary to verify your identity when you request to exercise a legal right regarding your personal data.

DISCLOSURE

Lonvest may share User’s personal data with third-party service providers, agents, subcontractors and other associated organizations, our group companies, and affiliates in order to complete tasks and provide the Services to User on Lonvest’s behalf. 

Lonvest may share your personal data with: 

• companies that we plan to merge with or be acquired by (should such a combination occur, we will notify you and will require that the newly combined entity follow this Privacy Policy with respect to your personal data);
• law enforcement, government officials, or other third parties when we are compelled to do so by a subpoena, court order, or similar legal procedure; or we believe in good faith that the disclosure of Personal Data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of any of our policies;
• identity verification agencies to undertake required verification checks;
• fraud or crime prevention agencies to help fight against crimes including fraud, money-laundering and terrorist financing;
• our vendors and agents, hired by us to provide you with the Services;
• transaction processors (for the purpose of ensuring transaction performance and their operation).

DATA RETENTION

Lonvest keeps your personal data for as long as it remains necessary for the identified purpose or as required by applicable law, which may extend beyond the termination of our relationship with you. Lonvest may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable data, account recovery, or if required by law. 

CHANGES

Lonvest reserve the right to modify or amend this Privacy Policy at its sole discretion. The date of the most recent modification will always be indicated at the top of this page. When Lonvest amends Privacy Policy, User will be notified in a manner commensurate with the nature of the changes made. If and where required by applicable data protection regulations, Lonvest will get User’s approval to any major changes. If the User does not accept a new edition of the Privacy Policy, they must stop using Website and Services.