Personal information collection and use

Envestio, (“Company”, “Website Manager”) is committed to respecting and protecting the User’s personal data and privacy by fully implementing and complying with internationally accepted data protection principles and all relevant provisions of the EU’s General Data Protection Regulation (the “GDPR”).

The Website Manager collects, uses and shares the User’s information in order to enable Users to use Website Manager’s Services. This Privacy Policy applies to use of any of the information that the Website Manager receives through Company’s different webpages, cookies, APIs, email notifications, applications, buttons, and widgets, altogether called the “Services” or “Envestio”.

By using the Website, the User agrees to this Privacy Policy.

Information collection and use

Regardless of which country the User accesses the Services from, resides in, or supplies information from, the User agrees to the collection, transfer, manipulation, storage, disclosure and other uses of the User’s information as described in this Privacy Policy and the User expressly authorizes the Company to collect, transfer, use and process the User’s information in Estonia and any other country in which the Company or Company’s vendors operate. In giving this consent, the User understands that the legislation on holding, processing, using and transferring personal information in Estonia may vary and be less protective of the User’s privacy than legislation of the User’s state or country.

The Company may collect and process information in following cases and ways:

Amongst other, the Website Manager may collect information and record details of the User’s visits and interactions and the way in which the User uses Envestio, including, but not limited to: traffic data, location data, weblogs and other communication data, whether this is required for the Company’s own purposes or otherwise and the resources that the User accesses; and (on a non-obligatory basis) other information, which from time to time could be relevant for the effective provision of the Company’s Services.

The Website Manager may collect information about the device or any computer the User may use to access the Services, including, where available, the device's or computer's unique device identifiers, operating system, browser type and mobile network information as well as the device's telephone number, for system administration and to report aggregate information to the Company’s advertisers. The Website Manager may associate Device information with Registration Information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.

When the User uses the Services or views content on Envestio, the Website Manager may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, browser type, operating system, the referring web page, pages visited, location, the User’s mobile carrier, device and application IDs, search terms, internet service provider (ISP), clickstream data, language, viewed and exit pages and date or time stamps and cookie information.

The Company’s Services use cookie technology to distinguish the User from other users of the Company’s Services. They are designed to improve the functionality and use of the website, also for the purpose of analysis, to streamline the access to the website and information contained therein. This helps Envestio to improve the functionality and use of the website as well as the Company’s Services as they evolve over time. A cookie is a small data file that is transferred to the User’s computer's hard disk. Envestio may use different types of cookies to better understand how the User interacts with the Company’s Services, to monitor aggregate usage by the Company’s users and web traffic routing on the Company’s Services, and to customize and improve the Company’s Services. Most Internet browsers automatically accept cookies. The User can instruct the User’s browser, by changing its settings, to stop accepting cookies or to prompt the User before accepting a cookie from the websites the User visits.

However, some Services may not function properly if the User disables cookies.

Storing the User’s personal data

All information the User provides to Envestio is stored on the Company’s secure servers. SSL encryption technology is used to ensure secure communication between the User and the Company.

The User is responsible for keeping the User’s chosen password confidential. The Website Manager strictly suggests the User not to share any passwords with anyone.

The transmission of information via the Internet is not completely secure. Although the Website Manager will do the best to protect the User’s personal data, the Website Manager cannot guarantee the security of the User’s data transmitted to Envestio. Once the Website Manager receives the User’s information, the Website Manager will use strict procedures and security features in order to prevent any unauthorized access.

Certain Services may from time to time include chat room or forum features. When using these features, it must be ensured that the User does not submit any personal data that the User does not want to be seen, collected or used by other users.

Usage of the information

The Website Manager may use information held about the User in the following ways:

The Website Manager may also use the User’s data to improve the User’s user experience, to provide the User with information, marketing and advertising and for statistical purposes.

The Website Manager is allowed to process personal data of the User gathered for the purpose of preventing money laundering and terrorist financing, but such data must not be additionally processed in a manner that does not meet the purpose, for instance, for marketing purposes.

Data processing and protection principles

Envestio does not request from a Person and does not process more information than is necessary to achieve the certain purpose and observes the main principles established by the Regulation.

Envestio processes Data lawfully, fairly and in a transparent manner in relation to the Person – the Investors and employees are kept notified of all the Data processed by the Platform and the legal basis for concrete processing.

Envestio undertakes all the necessary actions and requires updates from Persons to ensure that Data is accurate and, where necessary, kept up to date.

Envestio stores Data only for a concrete purpose, which means that Data that not required anymore is being deleted, unless the legal requirements regarding the term of Data storage exist and are binding to the Platform or the Person.

Envestio provides appropriate security of Data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures. For that purpose Envestio continuously develops information technologies in order to ensure the protection of Personal Data.

Envestio ensures that access to Data is prohibited to those employees who don’t need it for the performance of their duties. Envestio has approved a respective internal procedure for Processing of Data and included confidentiality and Data protection obligations in the employment and co-operation contracts entered into with the employees or outsourcing services providers who Envestio grants the access to the Data.

Envestio allows a Person to control and monitor their Data Processing. The respective information is being provided to the Persons on request.

Disclosure of the User’s information

The Website Manager will not disclose the User’s personal information to any third parties without the User’s consent. Before transferring data to a third person, Envestio concludes the agreement with the respective third person obliging it to process and protect the Data. During the cooperation, only the Data required for the certain purpose will be transferred to the third person. If there is such possibility, The Website Manager transfers such information, so that the third person is not able to identify the particular Person. Envestio may not enter into a contract with a third party only in cases where the transfer of the relevant Data is regulated by the applicable legal regulation and Data protection regulation is in the same manner binding to the respective third person.

The Website Manager may disclose the User’s personal information to third parties in the following specific cases:

Companies belonging to Envestio Group (parent, subsidiaries, affiliates) are not considered to be third parties.

Data may be transferred to:

Changing the User’s information

The GDPR gives the User the right to access information held about the User. The User’s right of access can be exercised in accordance with GDPR. The User may ask Envestio to change, improve or delete any partial, false or outdated information regarding the User or the User’s activities.

The User’s rights

The User has the right to ask Envestio not to process the User’s personal data for marketing purposes. The Website Manager will inform the User (before collecting the User’s data) if the Website Manager intends to use the User’s data for such purposes.

The Company’s Services may, from time to time, contain links to and from the third-party websites. If the User follows a link to any of these websites, please note that these websites and any services that may be accessible through them have their own privacy policies and that the Website Manager does not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as contact and location data. These policies must be checked before the User submits any personal data to these websites or uses these services.

The User may obtain information as to whether or not Envestio processes your personal data, and, where that is the case, access to the personal data processed by Envestio and to receive information on what personal data and from which sources are collected, the purposes of the processing, the recipients to whom the personal data have been or may be provided; to obtain from Envestio a copy of the personal data undergoing processing in accordance with the applicable law. Upon the receipt of your written request, Envestio, within the time limit laid down in the legislation, shall provide the requested data in writing, or specify the reason of refusal. Once in a calendar year, data may be provided free of charge, but in other cases remuneration may be set at a level not exceeding the cost of the data provision.

The User has the right to request termination of the data processing (erase the data), in the case the data subject withdraws consent on which the processing is based, or the personal data are no longer necessary in relation to the purposes for which they were collected, or the personal data have been unlawfully processed, or the personal data have to be erased for compliance with a legal obligation. A written notice of objection to personal data processing shall be submitted to Envestio personally, by post or via electronic means of communication. If your objection has legal grounds, Envestio, after examining the request, shall terminate any actions of processing of your personal data, with the exception of cases provided for by law. It should be noted that the right to require the immediate erasure of your personal data may be limited or not possible due to the obligation of Envestio to store data about the clients' identification, payment transactions, concluded agreements, etc. for the period laid down in legislation;

The User has the right to request to restrict the processing of personal data, where the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims. A data subject who has obtained restriction of processing shall be informed by the data controller before the restriction of processing is lifted.

Security

All personal data is being kept in the Company’s secure and firewalled network. All the Company’s and the Company’s Group’s employees have confidentiality clause in their agreements.

Changes to privacy policy

The Company’s privacy policy might be a subject to change. Any changes the Website Manager may make to the Company’s privacy policy in the future will be posted on this page.

Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to Envestio SI OÜ (registry code 14433607, located at Raeküla tee 5, Rae Küla, Rae Vald, Harjumaa, Eesti, 75310 or by email: info@envestio.com

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