Privacy Policy

Last Updated: 03 December, 2024

Introduction and Scope

This Privacy Policy outlines how Fintax (“we,” “us,” and “our”) manages your Personal Data in relation to:

The services we provide to you (“Services”);
Other pre-contractual or contractual relationships between you and Fintax, excluding employment-related connections (“Relations”);
Services provided to or by an entity you represent or work for (“your entity”) or relationships maintained by your entity with Fintax.
In compliance with data protection laws, we address your data subject requests for information we hold, as detailed in Section 3 of this Policy.

In this Privacy Policy, “Personal Data” refers to any information that allows us to identify you, as explained below in the section on Personal Data we process.
This Policy applies to the handling of the Personal Data of prospective clients, vendors, or other business partners (individuals) for which Fintax is responsible and qualifies as a controller under the General Data Protection Regulation (2016/679/EU) (“GDPR”) or similar regulations. It includes data collected and maintained by or on behalf of investment funds managed by Fintax.
We may collect your Personal Data through various channels, including sales processes, phone calls, forms submitted by you or your entity, emails, other communication methods, and during business events.
Your Personal Data may be collected directly or indirectly from your entity.
This Privacy Policy does not apply to corporate company information unless it contains the Personal Data of individuals or qualifies as Personal Data under applicable local laws.
Please refer to our Personal Data Protection Policy for information on how we handle personal data as a processor.
When we refer to “Fintax” or “we,” we are talking about Fintax company with registration number 45484528, registered address: Ukraine, 18029, Cherkasy region, Cherkasy city, Heroiv Maidanu St., building 5/1, responsible for managing your Personal Data.

Personal Data We Process

At Fintax, we process the following types of Personal Data related to you in connection with providing Services or managing Relations:

Contact Details: Includes your name, address, phone number, email address, and any other contact information you provide.
Personal Characteristics: Includes information such as your gender, profession, job title, entity name, and marital status (if displayed on national ID cards) or other characteristics required to identify you as a client, vendor, business partner, or their representative or employee, under applicable local laws.
Communication Data: Includes your requests, complaints, or any communications made on your behalf. This data includes interactions through email, telephone, in-person, or other means.
Contractual Data: If you are a party to a contract with us, providing the necessary Personal Data to identify you as a contracting party is required to complete the contract. Failure to provide this data may prevent the contract’s conclusion.

Providing Personal Data for communication or contact purposes is voluntary. However, failure to provide necessary Personal Data may delay delivering Services, maintaining Relations, or responding to your requests or complaints.

Providing Personal Data for marketing purposes is voluntary and does not affect your access to Services.

Purposes for Which We Use Your Personal Data

Fintax collects, uses, and processes your Personal Data for the following reasons, all based on lawful grounds. We may use your information for the same purposes described below if we already possess it.

Performance of Agreements: We use your Personal Data to meet our commitments under any agreements with you or your entity. This includes providing the necessary information or Services as requested and addressing your inquiries, requests, or complaints.
Marketing Purposes (With Your Consent): For potential clients, we may use your Personal Data to send marketing materials, such as newsletters, promotional offers, updates, or news, via email, other electronic methods, or phone. We will only do this with your explicit consent, which you can withdraw at any time.
Compliance with Legal Obligations: We may use your Personal Data to comply with legal requirements. This includes keeping proper business records, conducting identification procedures, performing risk assessments, responding to legal requests from authorities, and adhering to applicable laws and regulations.
Legitimate Business Interests: For current clients, we may use your Personal Data to promote our Services based on your previous interactions, contact you for marketing or business purposes, and manage agreements.

We use your Personal Data to analyse and enhance our Services, understand you or your entity as a customer, and deliver relevant advertising based on your historical usage.

Additionally, we employ your Personal Data to operate and grow our business, improve our Services, generate aggregate statistics on Service users, support security and fraud prevention efforts, and perform internal functions such as troubleshooting and data analysis.

Your Personal Data may also be used to maintain system integrity, support business operations, follow company policies and procedures, and facilitate corporate transactions allowed by law, such as mergers, sales, reorganisations, or acquisitions.

How We Share Your Personal Data

Fintax may share your Personal Data with various parties for the following purposes:

Within Fintax: Your Personal Data may be shared among our internal departments for administrative, management, analytical, and other business purposes. Each department ensures your data is protected and may require additional consent. Your Personal Data will only be used for marketing within Fintax if you have explicit consent.
Service Providers and Partners: We may engage third-party vendors to provide services on our behalf, which may involve accessing your Personal Data. This includes:

Business Partners: Such as legal and financial firms or subcontractors involved in providing Services.
Suppliers: Including IT service providers.
Marketing and Advertising Firms: Conducting activities on our behalf.
Analytics Providers: Such as Google Analytics to help improve and optimise our website. These service providers enter into data processing agreements with us and adhere to relevant data protection laws. They are contractually obligated to protect your data and only process it according to our instructions. They are not allowed to use your Personal Data for their own purposes.

Third Parties in Legal Situations: We may disclose your Personal Data if required by law, regulatory obligations, court orders, or legal processes or to protect our rights, safety, or those of our affiliated companies.
Corporate Transactions: Your Personal Data, including information about our clients, may be disclosed in connection with corporate transactions such as mergers, sales, asset transfers, acquisitions, bankruptcies, or similar events.
Other Third Parties with Your Consent: We may disclose your Personal Data to other third parties if you have provided consent or requested us to do so.

International Transfers of Your Personal Data

Fintax operates globally, so we may need to transfer your Personal Data to countries outside your home country. It is essential to be aware that the privacy laws in these countries might not offer the same level of protection as those in your country of residence. To manage this, Fintax and our third-party partners implement various measures to comply with relevant laws and provide adequate security for your Personal Data, especially when transferring it outside the European Economic Area (EEA).
Third-Party Transfers: We enter legally required agreements for transferring Personal Data to third parties outside the EEA. These agreements often include the latest standard contractual clauses approved by the European Commission or relevant supervisory authorities to protect your data during international transfers.
Request for Documentation: If you would like to receive documentation showing the safeguards in place for international transfers of your Personal Data, you can request this from the Fintax entity that collected your data or by emailing us at contacts@fintax-ua.com.

Security

Fintax is dedicated to protecting your Personal Data and uses reasonable measures to ensure its security. We implement appropriate technical, physical, and organisational safeguards to protect against unauthorised or unlawful use, modification, access, disclosure, destruction, and loss of your Personal Data.

Encryption: We use encryption technologies to maintain the confidentiality of your data where necessary.
Access Control: Access to Personal Data is restricted to authorised personnel, ensuring that only those with proper permissions can access it.
Employee Awareness: We prioritise raising awareness among our employees through comprehensive information security and privacy protection training. Our employees are trained to protect Personal Data and comply with relevant policies and procedures.
Principle of Least Privilege: Access to Personal Data is granted based on the principle of “Least Privilege,” ensuring that individuals only access the data necessary for their specific job functions.
Third-Party Compliance: We require any third parties processing Personal Data on our behalf to adhere to confidentiality, integrity, and availability standards, further ensuring the protection of your data.

Data Retention

At Fintax, we keep your Personal Data for as long as necessary to fulfil the purposes for which it was collected and used, including providing Services and meeting legal requirements. We will retain the data accordingly if a more extended retention period is needed for legal reasons.

Our data retention practices follow the laws of the countries where your data is processed. Typically, we retain data for ten (10) years unless specific laws or policies dictate otherwise.

Your Rights

Depending on applicable laws, you can request access to, correct, or delete your Personal Data, limit or object to its processing, and request data portability.
To exercise any of these rights, please email us at contacts@fintax-ua.com.
In your request, specify which right you wish to exercise and provide details about the Personal Data you want to access, correct, delete, or restrict. We will respond to your request quickly and in line with applicable laws.
Please note that we may need to keep some Personal Data for recordkeeping purposes or to complete transactions initiated before your request.
If your Personal Data is processed based on your consent, you can withdraw your consent at any time by contacting us at the email address above. However, this will not affect the legality of the processing before you withdraw your consent.
If you believe that the collection or use of your Personal Data violates this Privacy Policy or applicable laws, please get in touch with us to address your concerns.

Changes to this Privacy Policy

We retain the right to modify or update this Privacy Policy as needed to comply with legal requirements, adapt to changes in our organisational or technical practices, or for other reasons. Should any significant changes impact how your Personal Data is used, or if the changes are otherwise necessary, we will notify you in advance.

Contact Us

If you have any questions regarding this Privacy Policy or how we handle your Personal Data, or if you want to exercise your rights, please reach out to us:

Email: contacts@fintax-ua.com
Website: https://fintax-ua.com/contact

Please include details about your query in your email.