Nextury Funds
PRIVACY POLICY
This privacy policy (hereinafter - the Policy) sets out the main conditions for the processing of personal data collected through the mobile application "Nextury Funds" (hereinafter - the Mobile Application) and through it. We inform you that the controller of personal data is UAB "Nextury Ventures", legal entity code 303213451, registered office address Gedimino pr. 20, Vilnius, Lithuania (hereinafter - Data Controller or us). If you have any questions regarding the protection of your personal data or this Policy, you can contact us by email at fondai@nextury.com. When processing your data, we follow not only this Policy, but also the General Data Protection Regulation, the Law on Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania and other applicable legal acts and instructions and recommendations of supervisory institutions. When processing your personal data, we adhere to the principles of lawfulness, fairness, transparency, limitation of the scope and time of data processing (reduction), accuracy, we do not collect, require data subjects to provide and do not process data that is not necessary. This Policy may be updated. In such cases, the updated version of the Policy is published in the Mobile Application.
1. Processing of personal data for the purpose of providing services
1.1. The Mobile Application is designed to monitor the performance of Nextury investment funds (e.g. "Nextury Technology Fund" or "Nextury Asia Technology Fund") (hereinafter - the Funds), your transactions as an investor in the Funds, investment units held, their value and other related information. The data controller processes the personal data of users of the Mobile Application, i.e. persons who have acquired investment units of the Funds.
1.2. The data controller manages the personal data necessary to provide such a service - basic personal data (name, surname, year of birth, age, etc.), contact details (phone number, email address), account login details, information on transactions made by the Fund investor and other personal data that you provide to us.
1.3. We process your personal data on the basis of a service provision agreement in order to provide you with the services offered by the Mobile Application. The source of the relevant personal data processing is the data subject - the data is obtained directly from you.
1.4. The legal basis for this data processing is the performance of the contract you have concluded with us.
1.5. This personal data of yours is stored from the moment you create a personal account until you use the Mobile Application (have a personal account).
1.6. We will process your personal data for the purpose of providing services until you use the Mobile Application (unless applicable law establishes a longer data retention period).
2. Processing of personal data for direct marketing purposes
2.1. In order to provide news related to the activities of the Funds and other news, the Data Controller may send information to the information channel you have chosen (e.g. by email). In the latter case, the Data Controller processes your provided personal data for direct marketing purposes.
2.2. For direct marketing purposes, the Data Controller manages your basic personal data (name, surname), contact details (phone number, email address, etc.) and other personal data you provided to us.
2.3. The source of the relevant personal data processing is the data subject, i.e. you provide your personal data in the Mobile Application, which the Data Controller processes for the aforementioned purpose.
2.4. The legal basis for the processing of this data is your consent.\
2.5. The storage period for this personal data of yours is 3 years from the provision of such data to the Data Controller, the day, unless you revoke your consent before the deadline expires.
2.6. The data controller, in accordance with Article 69(2) of the Law on Electronic Communications, may also process existing customer data for direct marketing purposes on the basis of the legitimate interest of the data controller.
2.7. You have the right to unsubscribe from the information sent to you at any time. You can do this by contacting us in writing (by email fondai@nextury.com).
3. Processing of personal data when you submit requests
3.1. If you contact the Data Controller by email, phone or any other means, the Data Controller processes the personal data you provide in order to administer the requests received, ensure the quality of the services provided, if necessary - comply with various legal requirements and defend the Data Controller's interests. The legal basis for the processing of this data in the prescribed cases is the legitimate interest of the Data Controller.
3.2. When submitting a request, please adhere to at least the minimum requirements for the protection of personal information - do not specify excessive personal data that is not necessary for the intended purpose, i.e. the presentation of the request, complaint, letter or application.
3.3. Your personal data submitted to the Data Controller along with the request are usually stored for up to 3 years. The retention period may depend on the content and nature of the personal data provided to the Data Controller, as well as other circumstances. If this is necessary for the defense of the rights and legitimate interests of the Data Controller (or other persons), the proper administration of requests, the examination of a complaint or the resolution of a dispute, as well as in other cases specified in legal acts - your personal data may be stored for a longer period of time.
4. Cookies used in the Mobile Application
4.1. When you visit our Mobile Application, we may process your network data using cookies and / or other similar technological solutions.
4.2. Cookies are small files (data files) that are sent to and stored on your device (phone). With their help, our Mobile Application can "remember" your actions, choices, transactions and other actions performed in our Mobile Application.
4.3. Only remote login session assurance cookies are used in our Mobile Application.\
4.4. You can find more useful information about cookies, their control and removal on the website www.allaboutcookies.org.
5. Data recipients
5.1. In carrying out its activities, the Data Controller may involve certain service providers (for example, companies providing data storage services, companies creating and maintaining software, companies providing telecommunications services, etc.) to whom your personal data may be transferred. Your personal data is transferred to the relevant service providers only when and to the extent necessary for the provision of their services.
5.2. The data recipient may also provide your personal data to the following data recipients:
5.2.1. state institutions and registers;
5.2.2. courts, notaries, bailiffs, law enforcement agencies, etc.;
5.2.3. other third parties related to our service provision and / or having a legal basis to receive this data.
5.3. In all cases, reasonable efforts are made to ensure that the implementation of legal requirements does not result in the loss or illegal use of personal data.
6. Your rights as data subjects
6.1. You, as data subjects, have the following rights:
6.1.1. to access your personal data and how they are processed;
6.1.2. require the rectification of incorrect, inaccurate or incomplete data;\
6.1.3. require the erasure of your personal data ("right to be forgotten");
6.1.4. require the restriction of the processing of your personal data;
6.1.5. require the transfer of your personal data to another data controller or provide it to you directly in a convenient form;
6.1.6. object to the processing of your personal data if they are processed on the basis of legitimate interest;
6.1.7. withdraw consent given to the processing of your personal data.
6.2. Please submit requests regarding the exercise of your rights as data subjects to us in writing by email fondai@nextury.com.\
6.3. If you believe that your personal data is being processed unlawfully or your rights related to the processing of personal data are being violated, please contact us by email fondai@nextury.com. Your requests will be fulfilled or your requests will be rejected, indicating the reasons for rejection, within 30 calendar days from the date of submission of the request. The specified 30 calendar day period may be extended by another 30 calendar days, with prior notice to you, if the request relates to a large amount of personal data. The response to the request will be provided by e-mail. After examining the request, we will notify you of the results and actions we have taken to fulfill your request, or we will provide information on further actions you can take if your request has not been fulfilled or satisfied.
6.4. You also have the right to apply to the State Data Protection Inspectorate if you believe that your personal data is being processed in violation of your rights and legitimate interests arising from applicable legal acts. You can contact the State Data Protection Inspectorate in accordance with the procedures for submitting and examining complaints established by the Inspectorate, which you can find at this link: https://vdai.lrv.lt/lt/veiklos-sritys- 1/complaint-handling.
6.5. However, before contacting the State Data Protection Inspectorate, we encourage you to contact the Data Controller immediately. In this way, we can together find the most efficient and optimal solution for both parties. Atgal