4th day of June,2023
- This document (hereinafter - “Policy”) (i) defines the policy of Earnie OÜ, a company registered under the laws of Republic of Estonia and having its registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Vesivärava tn 50-201, 10152 (hereinafter - “We”) “Data Controller”), with respect to processing of personal data.
This Policy applies to information We collect:
- during provision of services.
- In email, text, and other electronic messages between you Us.
- Through mobile and desktop applications you download from Our website https://earnie.finance/ru and/or Mobile App Earnie, which provide dedicated non-browser-based interaction between you and Us.
- When you interact with Our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.
- Please read this Policy carefully to understand Our policies and practices regarding your information and how We will treat it. If you do not agree with Our policies and practices, you should not use Our services. By accessing or using Our services, you agree to this Policy. This Policy may change from time to time. Your continued use of the Services after We make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
- Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to Our services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our services or through any of its features, register on Our services, make any purchases through Our Services, use any of the interactive or public comment features of Our Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If We learn We have collected or received personal information from a child under 18 without verification of parental consent, We will delete that information. If you believe We might have any information from or about a child under 18, please contact Us and We will endeavor to delete that information from Our databases.
PERSONAL DATA PROCESSING PRINCIPLES, TERMS, AND CONDITIONS
- We will process your personal data in accordance with the procedures stipulated by Personal Data Protection Act of Estonia dated 12.12.2018 and all regulations issued for the purpose of its application (hereinafter- “relevant regulations”) on a fair and lawful basis.
- We will process your personal data strictly for the purposes defined in this Policy and such processing will be limited to the attainment of such specific, pre-defined, and lawful purposes. We will undertake not to allow any personal data processing that is inconsistent with the purposes for which such data is collected as listed in this Policy. The personal data that we collect in the mobile app is not excessive relative to the declared purposes for which the same is processed.
- We will store your personal data in a form that makes it possible to identify you as a personal data subject for no longer than the purposes of personal data processing require unless the relevant regulations require otherwise. Unless the relevant regulations require otherwise, We will destroy your personal data once the purposes of processing are achieved in accordance with Our procedures, or if processing of your personal data for such purposes is no longer necessary.
INFORMATION WHICH WE COLLECT AND USE
- In the course of operating the Services and providing the Products, We collect or receive the following types of information:
- Personal Information
When you register to become Our client, you will be asked to provide Us with certain information about you, such as, your name, date of birth, Tax ID number, citizenship, visa information, home address, telephone number, email address, bank account number, bank routing number, bank account login credentials, bank name, employment status, job position, whether you are a "politically exposed person” and other information as appropriate for Our legitimate business needs (collectively and together with information referenced in Sections 2 through 6 below, the "Personal Information").
- Nonpublic Personal Information
When you register to become aOur client and at certain times following initial registration during the provision of Our services to you, We will also collect your nonpublic personal information which means (i) any information you provide to Us to obtain a financial product or service from us, (ii) any information about you resulting from any transaction involving a financial product or service between Us and you, or (iii) any information We otherwise obtain about you in connection with providing a financial product or service to you ("Nonpublic Personal Information" or "NPI"). NPI is a subset of Personal Information and shall be considered Personal Information under this Policy.
- Initial Questionnaire Information
When you register as a client, you can be asked to provide information about yourself such as, your name, age, etc., (collectively, the "Initial Questionnaire Information"). Initial Questionnaire Information may be updated or modified following initial registration during the provision of Our services to you. Initial Questionnaire Information is a subset of Personal Information and shall be considered Personal Information under this Policy.
- Card and Bank Information
- Transaction Information
When clients wish to make a purchase, sale or any other transaction through Our websites or/and mobile apps, they must provide Us with certain information about the transaction they are seeking to execute. Such information is collectively called the "Transaction Information." Transaction Information is a subset of Personal Information and shall be considered Personal Information under this Policy.
- Geolocational Information
Certain features and functionalities of Our services may be based on your location. In order to provide these features and functionalities while you are using a mobile device, We may, with your consent, automatically collect geolocation information from your mobile device, wireless carrier, or certain third-party service providers. Such information is collectively called the "Geolocational Information." Collection of such Geolocational Information occurs only when our app is running on your mobile device. You may decline to allow Us to collect such Geolocational Information, in which case We will not be able to provide certain features or functionalities to you.
- Other Information.
We may automatically collect or receive additional information about you, your use of Our services, your interactions with Us and Our advertising, as well as information regarding your computer or other devices used to access Our services (collectively, the "Other Information"). Such Other Information may include, but is not limited to, the following:
- From Your Activity
- IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or device;
- Browser type and language;
- Referring and exit pages and URLs;
- Date and time; and
- Details regarding your activity on the Services, such as search queries and other performance and usage data.
- About Your Device
- Type of device;
- Universally Unique Identifier ("UUID");
- Advertising Identifier ("IDFA" or "AdID");
- Operating system and version (e.g., iOS, Android or Windows);
- Wireless carrier; and
- Network type (WiFi, 3G, 4G, or LTE).
- We may, from time to time, ask you to participate in surveys on Our services. Participation in these surveys is completely voluntary. These surveys may be conducted by Our third-party service providers. Such third-party service providers are authorized to use your information only as necessary to provide these services to us. We will use survey results to continue to improve Our services and the products. We will use your personal information from Our surveys to send you information about Our products and services and about third-party products and services. We may combine your survey information with other data We have about you. We may also anonymize and aggregate the survey information and sell it to third parties.
- We may also collect Personal Information and information about your transactions with Us and those you engage in with Our affiliates, unaffiliated third parties, banking verification services and information from consumer reporting agencies. We may further collect information about you from third-party data sources, such as brokers, banks and government databases. We may combine data We collect about you from third-party data sources with data We collect from you and may use and share such data as described in this Policy. All information We collect and/or receive from such third- party sources is collectively referred to as "Third-Party Information."
LEGAL REASONS FOR OUR PERSONAL DATA PROCESSING
- We will process your personal data solely and exclusively subject to there being legal reasons under the relevant regulations, and such legal reasons are as follows:
- your consent for personal data processing with respect to marketing and research activities between Us and you (such as promotion of Our services and products or other marketing interaction and studies);
- your consent for personal data processing with respect to your personal data shared though the Our mobile app or otherwise;
- compliance with applicable laws, including, without limitation, those that assign the Our functions, powers, and duties as data controller;
- exercise of Our or third parties rights and legitimate interests in accordance with the relevant regulations.
PURPOSES OF PERSONAL DATA USAGE
- We will use personal data shared by you for the following purposes:
- to provide and improve Our services and products;
- to help Us improve the content and functionality of Our services and products;
- to provide trade recommendations;
- to advise you about your portfolio;
- to solicit your feedback;
- to inform you about Our products and services and those of third parties;
- to administer and protect our business, Our websites and mobile apps, (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- to deliver relevant websites and mobile apps’ content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
- to make suggestions and recommendations to you about goods or services that may be of interest to you.
- You also authorize Us to use and/or share Information as described below.
- We will access, use, and share the Information as required to fulfill Our contractual obligations to you or subsequent requests for support by you
- To track your purchases, match your purchases with the Other Information We have about you and provide suggestions to you about potential product recommendations, services recommendations, trade recommendations, saving money, and other financial services and offers that We believe may help you;
- We like many businesses, sometimes hires other companies to perform certain business-related functions on Our behalf. Examples of such functions include website hosting, mailing information, maintaining databases, ID verification, processing applications, processing payments and completing transactions. When We employ another company to perform a function of this nature, We only provide it with the information that it needs to perform its specific function. These companies are authorized to use your Information only as necessary to provide these services to us;
- We may share some or all of your Information with any other companies that We control, are controlled by, or are under common control with us;
- As We develop Our businesses, We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, launch of a new subsidiary, dissolution, or similar event, the Information may be part of the transferred assets and you will be notified via email and/or a prominent notice on Our services of any change in ownership or uses of your Personal Information, as well as any choices you may have regarding your Personal Information;
- In an ongoing effort to better understand Our clients,Our services and products, We may analyze certain Information to compile information about Our client demographics, interests and behaviors and to create data analytics on an aggregate basis. This aggregate information does not identify you personally. We may share this aggregate information with Our affiliates, agents, business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the services, the services and our products and services to current and prospective business partners and investors and to other third parties for other lawful purposes;
- We may disclose your Information if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend Our rights or property, (iii) act in urgent circumstances to protect the financial security of users of the services or the public against fraud or other harm, or (iv) protect against legal liability;
- We may share your Information with third parties, including but not limited to third-party market research firms for analysis purposes and to help such third parties generate market research data for Us which will not identify you personally. Such third parties will provide Us market research data to help Us better segment Our client base and understand what products and services would likely work best for Our clients.
INTERACTIVE DATA COLLECTION TECHNOLOGIES
- To collect the website browsing and user behavior data, such technologies as cookies (browser cookies and Flash cookies) and web beacons are used on the Our website. We and third-party vendors, acting under an agreement with Us, passively collect and use data variously, including:
- Via a browser: certain data is collected by most browsers, e.g., your Media Access Control (MAC) address, computer type and operating system version, Internet browser type and version, and your location. We may collect such information as, for example, your device type and identifier, if you access the website from a mobile device. Such information is shared with Us when you access the Our websites.
- Using Cookies: Cookies are small text files stored on your computer. Cookies allow the Us to collect such information as the browser type, time spent on Our website, web pages viewed, and language preferences.
- We will use this data to improve Our website operation, ensure security, facilitate browsing, display information more efficiently, and customize your experience of using the Site.
- IP address: IP address is a numerical label your Internet provider assigns to your computer automatically. The IP address is identified and logged in Our server files each time a website visitor accesses Our website; web pages viewed, and time spent on the Our Website are also logged. Collection of IP addresses is a common Internet practice with many websites collecting such data automatically. We may use IP addresses for such purposes as, for example, to assess the website traffic, for server diagnostics and website administration.
- Device Information: We may collect your mobile device data, e.g., the unique device identifier.
PERSONAL DATA PROCESSING PROCEDURES, TERMS, AND CONDITIONS
- This Policy applies to collection, recording, classification, capture, storage, revision (updating, modification), retrieval, use, transfer (sharing, accessing), cross-border transfer, blocking, deletion, and destruction of personal data collected by Us on Our websites or mobile applications with the use of automation tools. The source of your personal data is you. We do not collect personal data about you from a third-party.
- We will process your personal data automatically without making any decisions that have any legal implications or otherwise affect your rights and legitimate interests based solely on personal data automated processing.
- We will ensure that databases used for collection, recording, classification, capture, storage, revision (updating, modification) and retrieval of personal data are in compliance with relevant regulations.
- We will keep your personal data collected on Our Websites and mobile apps confidential.
- We may delegate the processing of your personal data to a third party, subject to relevant regulations.
- We can transfer your personal data collected on Our websites and mobile apps in the following events:
− you have authorized such transfer;
− such transfer is required to achieve any purposes of an international treaty or a law, or to fulfill and discharge Our functions, powers, and duties under applicable laws; or
− such transfer is required to perform an agreement to which you are party.
- We will share personal data collected on the Our Websites and mobile apps only if We have entered into an agreement with the recipient of personal data under which such third party receiving personal data from Us undertakes to keep personal data confidential and to adhere to the personal data processing principles and rules defined by the relevant regulations and agreement with Us.
- We can share personal data (including by cross-border transfer to countries that do or do not provide an adequate level of protection of personal data subjects’ rights) with the following third parties:
− Our affiliates;
− third-party vendors of such services as website hosting and administration, data analytics, infrastructure maintenance, IT services, services delivered by email or regular mail, audit services, and other services, if such data is needed for such persons to be able to provide the same; and
− in the event of Our restructuring, merger, sale, creation of a joint venture, or winding up of, transfer of its assets or shares in full or in part (including in connection with bankruptcy or court proceedings).
- We will share personal data collected on the Our websites and mobile applications within the scope which We may in our discretion deem necessary or appropriate:
to effectively achieve purposes listed in clauses 11 and 12 above;
pursuant to requirements of the laws applicable to Us;
to protect the Our and Our affiliates’ business;
in response to requests from the government authorities;
to facilitate any court proceedings; or
− to protect your rights and Our rights and our affiliates’, confidentiality, security, or property.
- When processing personal data, We will make sure that personal data is accurate (assuming such data is true without having to verify the same), sufficient, and, where necessary, fit for purposes of its collection and usage. We will take appropriate measures to delete or update incomplete or inaccurate data, including in the events referred to in this Policy.
- We will apply appropriate managerial, technical, and administrative arrangements to protect personal data received on Our website in accordance with relevant regulations and other applicable laws.
PERSONAL DATA PROCESSING TERM AND TERMINATION
- We will store personal data collected on Our Websites and mobile apps for as long as necessary for the purposes of this Policy unless longer storage is necessary or permitted by relevant regulations or other laws applicable to Us.
- We may terminate personal data processing once the purposes of such processing have been attained or where such processing is found to be illegitimate.
- If processing of personal data collected on the Our websites or mobile apps is found to be illegitimate (on receipt of your or your representative's query, on receipt of a request from an authorized agency, or following an internal audit) or if personal data is found to be inaccurate, We will block or procure the blocking of such personal data that is processed illegitimately on receipt of such query or request for as long as such personal data processing is verified:
- if the inaccuracy of personal data is confirmed based on the information you, your authorized representative, or an authorized agency may provide in any form in writing or based on any other documents pursuant to relevant regulations, We shall update such personal data or procure the same to be updated within fifteen (15) business days of receipt of such data and unblock the same;
- if the illegitimate personal data processing is confirmed, We shall terminate such illegitimate processing within five (5) business days of confirmation of the illegitimate processing or delete such personal data within ten (10) business days of confirmation of the illegitimate processing. We shall notify you, or your representative, or the authorized agency, if the legitimacy of processing was verified at the request of such agency, of remedying any such violations.
- If you revoke your consent, We shall terminate personal data processing immediately, except when continued processing of such personal data is required by relevant regulations or other laws applicable to Us, and in any event We shall notify you of the outcome of such revocation.
- If the purposes for which personal data collected on Our Website or mobile apps have been attained, We shall terminate personal data processing and destroy personal data within thirty (30) days of when the purposes of processing have been attained, unless your consent received by Us provides for a different deadline. If personal data collected on theOur website may not be destroyed by such deadline, We will block such personal data and ensure that the same destroyed within six (6) months, unless the relevant regulations or other laws applicable to Us, your consent for personal data processing, or an agreement to which you are a party, require otherwise.
ADMINISTRATOR. CONTACT DETAILS
Citizen of the State of Israel (passport 9316941, date of issue: 9th of January, 2022)
2222735 Israel, Nahariya, Levi Ashkol street 39 flat 3