Privacy Policy
Introduction
- 1. Protection of personal data is very important to us and we take it very seriously. This Privacy policy conducts the principles that are being followed by UAB GAINS Associates to ensure your Personally Identifiable Information’s safety and what measures are taken, who has access to it and what it is used for.
- 2. You will be asked to confirm that you have read this Privacy Policy and understand the terms according to which UAB GAINS Associates shall process your personal data.
- 3. Like most companies, UAB GAINS Associates collects data when you use our services, visit our website. If you want to buy our service from our websites or to get more information about it, then sharing your personal data with us is necessary.
- 4. We process personal data in compliance with applicable personal data protection laws, in accordance with the Regulation (EU)2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data, the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation)(GDPR) as well as the Personal Data Protection Act of Lithuania and other applicable laws.
- 5. The purpose of this Privacy Policy is to inform You about the following: - who is responsible for the protection of your information;
- the types of Personal Information we may collect about You and how they may be used;
- the sources from which we gather information about you;
- our use of information regarding IP addresses;
- any disclosure of the Personal Information to third parties;
- your ability to correct, update and delete your Personal Information; and
- the security measures we have in place to prevent the loss, misuse, or alteration of the Personal Information under our control. - 6. UAB GAINS Associates respects your right to control your privacy. It is important for us that you can exercise your rights. Below you will find details on how to do this. UAB GAINS Associates process lawfully, fairly, and in a transparent manner in relation to you. Your personal data is being processed for the purpose of:1. account establishment; performance of the Services (sale and purchase, transfer of funds, payment collection …);
2. prevention of money laundering and terrorist financing (implementation of KYC);
3. crime prevention implementation of international sanctions;
4. services support; quality assurance;
5. direct marketing; use of the company’s social networks accounts;
6. proper and secure operation of the Platform; - 7. Please be aware that we can update our Privacy Policy and, in that case, we will notify you about the amendments
Terms and definitions
1. Controller: Natural or legal person, public entity, agency or other body which alone or in cooperation with others determines the objectives and means of the processing of personal data; if the objectives and means of such processing are determined in the law of the Union or the Member State, the specific criteria for the Responsible Processor or for assigning the one may be established in the law of the Union or the Member State;2. “Consent” of the data subject: Voluntary, specific, conscious and unambiguous statement by which the Data Subject in the form of an application or by explicit consent, agrees with the processing of his/her personal data;
3. Data subject: Identified or identifiable natural person whose data is processed;
4. Personal data: Any information concerning an identified or identifiable natural person (“data subject”); identifiable natural person means a person who can be identified directly or indirectly, in particular on the basis of identifying attribute, including name, personal identification code, location information, network identifier, or on the basis of one or more physical, physiological, genetic, mental, economic, cultural or social characteristics of the natural person;
5. Processing of personal data: Automated or non-automated operation or set of operations, including collection, documentation, organizing, structuring, storing, customizing and modifying, querying, reading, using, transferring, distributing, or making otherwise available, joining or combining, restricting, deleting or destructing of personal data or set of them;
6. Processor: Natural or legal person, public entity, agency or other body processing personal data on behalf of the controller;
7. Profile analysis: Any automated processing of personal data involving the use of personal data for the assessment of certain personal aspects of the natural person. In particular, for analyzing or forecasting aspects related to the performance, financial situation, health, personal preferences, interests, reliability, behavior, location or movement of the natural person concerned;
8. Recipient: Natural or legal person, public entity, agency or other body to whom personal data is disclosed, whether or not it is a third party. The public entities which can obtain personal data as a result of specific inquiry in accordance with the law of the Union or the Member State, are not deemed to be recipients; these public entities process such data in accordance with applicable data protection standards in the basis of the processing purposes;
9. Set of data: Any organized set of personal data from which data can be derived on the basis of certain criteria, regardless of whether the set of data is functionally or geographically centralized, decentralized or distributed;
10. Third party: Natural or legal person, public entity, agency or body, excluding the Data Subject, Controller, Processor and persons who can process personal data under the direct responsibility of the Controller or Processor;
Data controller
1. The controller for your personal information is UAB GAINS Associates,J. Jasinskio g. 16B, LT-03163, Vilnius, Lithuania, email address: contact@gains-associates.com2. Should you have any questions about how we process your Personal Information, or should You wish to exercise any of your rights as a data subject, you can contact us, using the contact details provided above.
Categories of personal data and purposes for processing
1. UAB GAINS Associates may collect the following information about you upon signing up for an account:- Email address;
- Name;
- date of birth;
- place of birth;
- nationality;
- country code;
- gender;
- home address;
- password;
- phone number;
2. The legal basis for processing the personal data listed in section 4.1. is Article 6(1)(b) in the GDPR or Article 6(1)(f) in the GDPR.- Name;
- date of birth;
- place of birth;
- nationality;
- country code;
- gender;
- home address;
- password;
- phone number;
3. UAB GAINS Associates may collect the following information to carry out the KYC/AML procedure:
- passport;
- driver’s license;
- national identity card;
- state ID card;
- taxpayer identification number (TIN);
- passport number;
- information about Your visa;
- proof of Your address / country of residence for tax purpose;
- declaration about sources of funds and/or sources of wealth;
- signature;
- selfie;
- any other information which UAB GAINS Associates is required to ask from You based on applicable AML related legal acts.
4. The legal basis for processing the personal data in section 4.3. is Article 6(1)(c) in the GDPR or Article 6(1)(f) in the GDPR (the legitimate interest of UAB GAINS Associates to reduce risks related to its customer relations).- driver’s license;
- national identity card;
- state ID card;
- taxpayer identification number (TIN);
- passport number;
- information about Your visa;
- proof of Your address / country of residence for tax purpose;
- declaration about sources of funds and/or sources of wealth;
- signature;
- selfie;
- any other information which UAB GAINS Associates is required to ask from You based on applicable AML related legal acts.
Log Data
1. We collect information that your browser sends whenever you visit our Service (hereinafter “Log Data“) The purpose of collecting log data is to examine, if necessary, any incidents regarding your account.2. This Log Data may include information such as your computer’s Internet Protocol (IP) address, browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages and other statistics.
6. Disclosure of personal data
1. We do not sell, trade, or otherwise transfer to outside parties your personally personal data unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you. Those parties will sign a confidentiality agreement before personal data is disclosed to them.2. The third party includes our KYC partner Blockpass who will have the necessary KYC information.
3. When UAB GAINS Associates discloses personal data to third parties, UAB GAINS Associates does this only if there exists a suitable legal basis for the disclosure. UAB GAINS Associates ensures that all relevant data protection related legal acts are complied with.
4. In certain cases, UAB GAINS Associates discloses your personal data to its co-operation partners who are acting as data processors for UAB GAINS Associates and partner service provider Blockpass. These can be co-operation partners who are offering accounting, IT support, marketing or other services to UAB GAINS Associates.
5. With any questions regarding your information please contact contact@gains-associates.com.
7. Your rights regarding the processing of Your personal data
1. You have the following rights as a data subject, considering the relevant conditions stipulated in applicable data protection laws:- right to access – your right to obtain from UAB GAINS Associates a confirmation as to whether or not Personal Information concerning You is being processed, and, where that is the case, access to the Personal Information;
- right to the erasure of your Personal Information (“right to be forgotten”) in accordance with article 17 of the GDPR;
- right to the correction of any inaccurate Personal Information;
- right to the restriction of our processing of your Personal Information;
- right to data portability in accordance with article 20 of the GDPR;
- right to object to the processing of your Personal Information, including, but not only, to data processing for marketing purposes, in accordance with article 21 of the GDPR;
- right to withdraw your consent for data processing, in cases where the legal basis for the processing of your Personal Information is your consent;
- right to obtain from us restriction of processing where one of the grounds set out in article 18 of the GDPR applies;
- right to not be subject to an automated individual decision-making, including profiling in accordance with article 22 of the GDPR.
2. You can exercise the above-mentioned rights by sending an email to us at: contact@gains-associates.com- right to the erasure of your Personal Information (“right to be forgotten”) in accordance with article 17 of the GDPR;
- right to the correction of any inaccurate Personal Information;
- right to the restriction of our processing of your Personal Information;
- right to data portability in accordance with article 20 of the GDPR;
- right to object to the processing of your Personal Information, including, but not only, to data processing for marketing purposes, in accordance with article 21 of the GDPR;
- right to withdraw your consent for data processing, in cases where the legal basis for the processing of your Personal Information is your consent;
- right to obtain from us restriction of processing where one of the grounds set out in article 18 of the GDPR applies;
- right to not be subject to an automated individual decision-making, including profiling in accordance with article 22 of the GDPR.
3. You may also request the deletion of your Account and Personal Information by sending an email to us at: contact@gains-associates.com. UAB GAINS Associates will accept your request only when this is not inconsistent with its legal and regulatory obligations.
4. In addition to the above, you have the right to file a claim with your local supervisory authority or with a competent court, if You believe that UAB GAINS Associates has infringed your rights as a data subject. Information and contact details about local supervisory authorities can be found here:
https://edpb.europa.eu/about-edpb/about-edpb/members_en
8. Security of personal data
1. UAB GAINS Associates aims to protect the security of your information as much as we aim to protect our information and network. UAB GAINS Associates has implemented appropriate organizational and technical measures to ensure the safety of your personal data. This includes legal, organizational, technical, and physical security measures, such as latest security systems, two-factors authentication and passwords, ability to detect cyber security attacks and others threats to the integrity of the Platform.2. No transmission of information via email or other telecommunication channels or your access to the Platform or the Services through the internet could be fully secured. Therefore, you should take due care when you are accessing the Platform or suing the Service via internet or sharing confidential information via e-mail or other telecommunication channels.
9. Newsletters and Cookies
1. We offer electronic newsletters to which you may voluntarily subscribe at any time. UAB GAINS Associates has implemented appropriate organizational and technical measures to ensure the safety of your personal data. We will maintain the information sent via e-mail in accordance with applicable laws and regulations.2. The Website uses “cookies” to help personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. We may use cookies to collect, store, and track information for statistical purposes to operate our Website and Services. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the features of the Website and Services. To learn more about cookies and how to manage them, visit internetcookies.org.
10. Your responsibilities
1. You confirm that you have provided correct data about yourself in every required form and that afterwards, when changing or adding any data at the Platform, you will enter only correct data. UAB GAINS AssociatesI will not tolerate invalid, false or otherwise incorrect data and will pursue actions in accordance with is legal obligations;2. You are responsible for maintaining adequate security and control of every identification number, password, and/or any other code that you use to access the Platform. If you have not complied with this obligation, you assume the losses and undertake to reimburse the losses of other persons incurred as a result of your (in)action;
3. UAB GAINS Associates draws your attention to the fact that email address and any other contact information you have chosen to link to your account are used for your identification and communication. You undertake responsibility to protect these instruments and logins to them. You are responsible for password disclosure and for all operations performed after you use the password for a relevant account. We recommend to memorize your passwords and not to write them down or enter anywhere where they may be seen by other persons.
11. Accessing or correcting your Personal Information
1. You can access and change any Personally Identifiable Information we store through your “My Profile” page.2. UAB GAINS Associates has referred to the legal acts and public recommendations applicable in the European Union and locally such as compliance with legit limitation periods, as well as current business practice. Upon the end of retention period, your personal data is erased.