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Privacy policy

 

1. GENERAL INFORMATION 

The privacy policy of Sutelktinio finansavimo platforma PROFITUS, UAB (hereinafter referred to as PROFITUS, “we”, or the Data Controller) (hereinafter referred to as the Privacy Policy) defines the terms of the processing of personal data using our website and/or services.

Details of your Data Controller:

Sutelktinio finansavimo platforma PROFITUS, UAB

Head office: Vasario 16 st. 2, Vilnius

tel. +370 637 60776

e-mail: info@profitus.lt

company code: 304570552

We have appointed a Data Protection Officer (hereinafter referred to as the DPO), to which you can contact to by pareigunas@profitus.lt.

CHANGES TO THE PRIVACY POLICY. We may change this Privacy Policy from time to time to reflect how we process your personal data. If significant changes are made, we will notify you via the website or other appropriate means of communication, such as e-mail, so that you can review these changes before continuing to use our website.

The terms and conditions of the Privacy Policy apply each time you access our content and/or service, regardless of which device (computer, mobile phone, tablet, TV, etc.) you use.

It is very important that you read the Privacy Policy carefully because every time you visit our website, every time you use our services or participate in our events, you agree to the terms and conditions described in this Privacy Policy. If you do not agree to these terms and conditions, please do not visit our website, do not use our content and/or services.

If the user of Platform is a legal entity, this Privacy Policy applies to the natural person whose data has been transferred to us by that legal entity. The User shall properly notify the data subjects (head, beneficiaries, representatives, collateral givers, guarantors, etc.) of the transfer of their data to Profitus and provide them with this Privacy Policy. In this Privacy Policy, the term “you” will apply to a natural person (talking about a legal entity – to head, beneficiary, representative, collateral giver, surety, etc. of the user of Platform), whose data is managed by Profitus.

Definitions in this Privacy Policy are used in accordance with the General Rules of Use of the Profitus Platform (for investors and for project owners) as well as with the General Data Protection Regulation.

We confirm that your data will be collected and processed in accordance with the applicable legal requirements of the European Union and the Republic of Lithuania and the instructions of the supervisory institutions.

Persons under the age of 16 cannot provide any personal data through our website. If you are a person under the age of 16, you must obtain the consent of your parents or other legal guardians before submitting your personal information.

2. FOR WHAT PURPOSES DO WE COLLECT THE INFORMATION

Profitus collects and manages information about you for the following purposes:

i. Provision of crowd-funding services, identification, prevention of fraud, money laundering and terrorist financing and other financial crimes, execution of other obligations relating the prevention of money laundering, creditworthiness assessment.

ii. Correspondence of business relations.

iii. Settlement of disputes.

iv. Debt management.

v. Direct marketing.

vi. For statistical purposes.

vii. For event organisation purposes.

3. WHAT INFORMATION WE COLLECT ABOUT YOU, FROM WHICH SOURCES AND TO WHOM WE TRANSFER IT 

3.1. Provision of crowd-funding services, identification, prevention of fraud, money laundering and terrorist financing and other financial crimes, execution of other obligations relating the prevention of money laundering, creditworthiness assessment

For this purpose, Profitus may collect the following personal data:

Data on your identity: name, surname, personal number or other unique sequence of characters for personal identification, date of birth, number of identity document, copy thereof, nationality or country issuing the identity document, country of residence, face photograph, etc. (identity data)

Contact data: address, telephone number, e-mail address, etc. (contact data)

Know Your Customer information: checks in public and private registries, workplace, position, activity, marital, social status, income and their type, education, services rendered, operations and transaction concluded, information about political involvement, etc. (Know Your Customer information)

Payment information: account number, payment service provider, account balance, amount paid, amount invested, etc. (payment data)

Creditworthiness data: credit rating, payments, debts, information on bankruptcy proceedings, etc. (creditworthiness data)

We may receive data from both you and from third parties (such as, financial institutions, providers of identity verificationservices, credit rating systems, registers, databases, social networks whose accounts you link to our system, etc.); also, we may check publicly available information about you to verify your identity or the data you provide, operations and transactions concluded.

The above data is collected by Profitus on the following basis:

- Profitus, as operator of a crowd-funding platform, must verify your identity, monitor user operations and transactions, prevent money laundering, terrorist financing, other financial crimes, as well as properly perform the obligations of the operator of crowd-funding platform, assess the creditworthiness of the financed entity, as required by the law.

- Data is necessary for the conclusion and performance of a contract with the user.

In view of this, in case of failure to provide the requested data to Profitus, Profitus may refuse to enter into business relations with the user and provide services.

Your data may be provided to: supervisory authorities, banking and other financial services partners, partners that provide identification, verification of sanction lists, transaction monitoring services, public authorities, lawyers, bailiffs, notaries, pre-trial investigation authorities, courts, auditors, other persons with a legitimate interest or your consent.

Your data will be processed for 10 years from the date of the conclusion of transaction or 8 years after the end of the business relationship with the user (this period may be extended by a period of 2 years at the request of the competent authority), whichever comes later.

3.2. Correspondence of business relations

We may notify you of any changes to the terms of the provision of services, the progress of the implementation of Projects and Financing Transactions, and to contact you for information or clarification. These notices are not direct marketing messages, so you will not be able to opt out of receiving them. Accordingly, you can contact Profitus for information or advice.

For this purpose, Profitus manages your Identity Data, Contact Information and the content of correspondence for business relations.

These data are necessary for the performance of a contract with the user, and such data must be collected and stored by Profitus in compliance with the statutory requirements for the prevention of money laundering and terrorist financing.

The data will be processed for 5 years from the end of the business relationship with the user. This period may be extended by a period of 2 years at the request of the competent authority.

Your data may be transferred to: supervisory authorities, lawyers, pre-trial investigation institutions, public authorities, courts, auditors, other entities with a legitimate interest or your consent.

3.3. Settlement of disputes

Before starting a dispute with us or any other user, you should make a complaint to Profitus before so that we can investigate it and, if justified, settle it out of dispute or give an opinion on the possibilities of your dispute with another user of Platform.

When a complaint or dispute with Profitus or another user is initiated, we may collect the following data: Identity Data, Contact Data, Know Your Customer Data, Payment Data, as well as the data you provide in your complaint, its enclosures, other data required to resolve your complaint/dispute.

These data are collected for the legitimate interests of Profitus in resolving disputes with you or between users, as well as proper investigation of the complaints you submit while complying with legal requirements.

The data will be processed for 3 years from the date of our final response to you. These terms may be extended until the final settlement of the dispute between the parties.

Your data may be provided to: supervisory authorities, lawyers, pre-trial investigation institutions, public authorities, courts, other entities with a legitimate interest or your consent.

3.4. Debt management

If the user is indebted, Profitus will be able to collect the following data: Identity Data, Contact Data,Payment Data, as well as details of your payments, services used and debt.

Data will be processed for 10 years from the date of the debt occurrence. If legal proceedings are initiated for the recovery of the debt, the time limit may be extended by 24 months from the date on which the debt is recovered.

Your data may be transferred to: lawyers, pre-trial investigation institutions, courts, auditors, notaries, bailiffs, debt collection companies, companies that manage joint databases of debtors, providers of banking and financial services, public authorities, other persons with a legitimate interest or your consent.

You also confirm that you are informed and agree that if you breach your obligations to us, other user, Profitus, having notified you in advance, will have the right to provide your data to companies that manage joint databases of debtors.

This data is necessary for the performance of a contract with the user; also, such data is managed by Profitus for the purpose of legitimate interests of Profitus and third parties: to recover the debt for its own benefit or for the benefit of investors.

3.5. Direct marketing

We may call you, send you a message or write an e-mail, send a regular mail, contact you through Facebook, Google, LinkedIn and other social platforms informing you of our services, Projects and investment opportunities, offering you similar services to those you have already used or are interested in, or which you may find interesting; we may send you e-mails with surveys to evaluate the quality of our services. We may also instruct third parties to perform these actions or we may perform these actions having received your data from third parties.

We will only send you e-mails, messages or make phone calls with your separate consent given to us or our partners.

Please be advised that we may also use your personal information (such as the services you use, location, behaviour, etc.) to form an opinion on what may interest you and to display certain types of ads on our site accordingly.

We may also provide anonymised information to our advertising service providers to promote our services and products. Such anonymised information would be used to help our advertising service partners create targeted campaigns relevant to a particular group of our customers.

Your data will be processed for 1 year from the end of the business relations with us. You have the right at any time to waive the processing of your data for direct marketing purposes.

Your e-mail as well as anonymised information about you may be provided to third parties that provide marketing services on online search engines, social networks, etc. Such third parties have their own privacy policies and you may at any time directly disagree with the processing of your data in accordance with their privacy policies.

The above-mentioned data are processed in the legitimate interests of Profitus: to inform you about our services that are relevant and necessary to you, receive information from you for the assessment of quality of our services.

Based on your personal data, your personal data may also be profiled for direct marketing purposes in order to provide you with personalised solutions and offers (i.e. instead of general messages, you will only be sent information on topics of interest to you). You may at any time revoke your consent to the processing of personal data by automated means, including profiling, or disagree with it.

If you no longer want your personal data to be processed for direct marketing purposes, including profiling, you can e-mail us at rinkodara@profitus.lt and disagree with your personal data being processed for direct marketing purposes and/or that only automated, including profiling, processing of your personal data is excluded, without giving reasons for disagreement. If you no longer wish to receive survey questionnaires by e-mail, you can unsubscribe at any time by contacting us by e-mail info@profitus.lt or by clicking the opt-out link in the e-mail.

3.6. Statistical purposes

Any data you provide or collected by us, other than your Identity Data, Contact Data, may be processed for statistical purposes. We will process your data in such a way that no one will no longer be able to identify you once the data have been included in the statistical evaluation.

Personalised data about your device, location, behaviour, etc. may also be processed for statistical purposes.

Data may be obtained from you or from other sources of data specified in this Privacy Policy, as well as through cookies as indicated in Section 7 of this Policy.

You acknowledge that you are informed that you have the right at any time to waive the processing of your data for statistical purposes; however, Profitus would be entitled to continue such processing, provided that it can prove that the data are processed for legitimate reasons, which are more important than your rights and legitimate interests.

These data are processed to fulfil the legal obligation of Profitus (provision of statistical data on the website and to the supervisory authority as provided for in the Law on Crowd-funding); they are also necessary for the legitimate interests of Profitus to monitor the scope, sources, popularity of the service, the volume of website traffic and other statistics.

Data may be provided to visitors of Profitus’ website, as well as to the Bank of Lithuania.

The data is processed during the period of Profitus’ activity.

3.7. Administration of events/competitions

Profitus can organise events/competitions that you can participate in, so Profitus can manage the following data for the purpose of administration of the event/competition and for contacting you on the event/competition: Identity Data, Contact Data.

Data can be obtained from both you and event /competition organisation partners.

The data is processed for the legitimate interests of Profitus: to organise, manage the event/competition, to contact its participants about the event/competition.

The data is processed one month after the end of the event.

In the case of a competition, we will keep the data for this purpose for a maximum of 2 years from the end of the competition, and in case of winning – for a maximum of 10 years after the prize is handed over.

 

4. HOW WE MANAGE YOUR DATA

Your data is processed both automatically and by physical means, which also includes automated decision making and profiling for different processing purposes.

Automatic decision-making and profiling can be used to verify your identity, to check your data in international databases, to monitor your operations and transactions, activity, and for other aspects. Such actions are mandatory under the current regulation of the prevention of money laundering and terrorist financing and are necessary for the commencement of business relations with the user.

Profitus implements appropriate measures to protect your rights, freedoms and legitimate interests, including the right to claim human intervention.

Your personal data is protected against loss, unauthorized use, and changes. We have introduced physical and technical measures to protect all information we collect for the purpose of providing our services. Please note that although we take appropriate steps to protect your information, no site, online operation, computer system, or wireless connection is completely secure.

 

5. PROFITUS' PARTNER SERVICES

You can get Profitus’ partner services through the Platform. In this context, you can find links to third-party websites on the Platform. Please note that such websites have their own privacy policies that you should be familiar with. We are not responsible for their policies and activities because we do not control them.

If you use such services, you must provide your data to such partner and agree to their terms of service or we may transfer your data for the purpose of providing you with certain services at your request. In this case, Profitus will only be the intermediary between you and the service provider and will not be responsible for the suitability of the service.

On Profitus’ website, there may also be third-party promotional banners, links to their sites and services that Profitus does not control, that is why we are not responsible for the security and privacy of information collected by third parties.

 

6. YOUR RIGHTS 

You have the following rights:

i. Know (be informed) about your data processing (right to know).

ii. Access your data and know how they are processed (right of access).

iii. Request to rectify or, in the light of the purposes of the processing of personal data, to have incomplete personal data completed (right to rectify). Please note that we may need to verify the correctness of your new data.

iv. Errase your data or restrict your data processing activities (with the exception of storage) (right to errase and the “right to be forgotten”) if there are good reasons for this. Please note that we may not be able to process your claim to errase data because of legal regulation in all cases.

v. Right to require the data controller to restrict the processing of personal data for one of the legitimate reasons (right to restrict).

vi. Right to portability of the data you have provided to us (right to transmit).

vii. Right to object to the processing of personal data or to cancel the consent when these data are processed or intended to be processed in the interest of Profitus. In this case, Profitus will cease processing your data unless it has evidence that it has legitimate reasons to continue processing the data. When data processing is related to direct marketing, you have the right to object at any time, and Profitus will stop processing your data for direct marketing purposes.

viii. Right to file a complaint to the State Data Protection Inspectorate. We would be grateful if you contact us before and give us an opportunity to settle the dispute with you peacefully.

You may enforce your rights under the Description of the Implementation of the Rights of Data Subject Rights.

 

7. COOKIES 

When you visit our website, we want to provide content and features that are tailored to your specific needs, we also want to better understand your behaviour and improve our products and services accordingly. This requires cookies. These are small items of information that are automatically created while browsing the site and are stored on your computer or other terminal device. They help us recognise you as a visitor to a previous website, save your site history and customise content accordingly. Cookies also help ensure the smooth running of websites, monitor the duration, frequency of visits to websites, and collect statistical information about the number of visitors to websites.

We use the following cookies on our website:

Functional cookies. Cookies are very important for the functioning of our website and electronic services, and they ensure a smooth user experience. For example, if the user so desires, he/she does not need to enter his/her name, surname or other data each time he/she connects.

For usage analysis. We use cookies for the accumulation of statistics on the number of users who have visited our websites and on the use of electronic services as well as the assessment of advertising performance. We may collect information, for example, from e-mails and newsletters sent for marketing purposes to find out whether e-mails were opened and prompted users to take any action, for example, whether the user click on the link on the e-mail to our website.

For marketing targeting. With cookies, we can also collect information to provide specific browser advertising or content by creating different target groups.

All information about cookies used on the site, their purpose, validity and the data used is provided in the table below.

NameSupplierExpiryDescription
__zlcmidPROFITUS1 dayRemember the settings
AWSALBPROFITUS7 daysTechnical cookie for faster browsing
CAKEPHPPROFITUSuntil the browser is closedTechnical cookie
csrfTokenPROFITUSuntil the browser is closedProtection against csrt attacks
_fbp
facebook.com
1 dayUsed on Facebook to provide promotional products such as third party offers
_ga
google.com2 yearsUsed by Google Analytics to separate users
_gat_gtaggoogle.com1 minute

Used to control the number of queries. This cookie can also be called _dc_gtm_<property-id>

_gidgoogle.com24 hours
Used by Google Analytics to separate users

How to manage and delete cookies

When you use the browser to access our content, you can configure your browser to accept all cookies, reject all cookies, or be notified when a cookie is downloaded.

Each browser is different, so if you don’t know how to change your cookie settings, check out its Help menu. Your device’s operating system may contain additional cookie controls. If you do not want information to be collected through cookies, use the simple procedure available in many browsers, which allows you to opt out of cookies. To learn more about how to manage cookies, visit: http://www.allaboutcookies.org/manage-cookies/.

However, please be noted that in some cases deleting cookies may slow down the speed of web browsing, restrict the functionality of certain website features, or block access to the site.