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PERSONAL DATA PROCESSING AND THE PRIVACY POLICY

By registering as a user, hereinafter referred to as User, on the website at https://kviku.finance/ and entering into website user agreement, hereinafter referred to as “the Agreement”, the User confirms its complete and irrefutable consent (hereinafter referred to as the “Consent”) for its personal data processing by KVIKU Holding LTD, registration number: HE 382807, registered address: Gladstonos, 124, The Hawk Building, 1 floor, 3032, Limassol, Cyprus, e-mail address: support@kviku.finance, hereinafter referred to as the “KVIKU.FINANCE”, and for transfer of its personal data to the third parties in accordance with conditions indicated in present document. Hereby the User also confirms that all its personal information submitted to the KVIKU.FINANCE is valid and accurate.

  1. The User is informed that KVIKU.FINANCE as personal data processor in accordance with conditions of 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as the “GDPR”), is entitled to process all the User’s personal information received from the User, as well as to transfer it and to receive personal data and other information on the User from third parties, including state institutions, Credit information bureau or similar entities, debt collecting service providers, etc.), databases, limited access government information systems (for instance, Population Register, State Social Insurance Agency, etc.) with a purpose to evaluate solvency of potential or existing User and managing of KVIKU.FINANCE credit risk, as well as for in situations such information is necessary for the provision of its services. The legal basis for User’s data processing is a signed agreement for provisions of KVIKU.FINANCE services between the User and KVIKU.FINANCE and applicable laws and regulations.

  2. Types of User’s personal data processed by KVIKU.FINANCE:

a) Name, Surname;

b) Government issued identification number;

c) Gender;

d) Date and place of birth;

e) Residence and citizenship;

f) Home address;

g) Phone number;

h) E-mail address;

i) Employment and job title;

j) Income level;

k) ID card of Passport number, place and date of issue;

l) Copy of ID card or Passport;

m) Credit card details, bank account;

n) IP address;

o) Browser information;

p) Other sort of information given by User on voluntary basis.



  1. KVIKU.FINANCE collects and receives personal data from User in order to ensure the provision of its services to the User, including in these particular instances:

• During registration process. During registration as a User, the company KVIKU.FINANCE collects personal data provided in registration form which potential user fills in and sends to KVIKU.FINANCE electronically on the website https://kviku.finance/ (hereinafter referred to as the “Website”).

• During Website visits. When User visits the Website, common nonpersonal information (browser’s identifier, the Website’s visiting frequency, average time spent on the Website, viewed pages) shall be recorded automatically. Such information shall be used with the purpose to receive information on attractiveness of our Website and to improve its content and functionality.

• Entering the Website as a User. In situation when a person enters the Website as the User, we are entitled to obtain personal data, for instance, when this person uses our services.

• Cookies. If User has entered our Website, KVIKU.FINANCE is entitled to use cookies or equivalent technologies, which collect certain information on Website’s use when User has entered the Website, viewed it or used it. Cookies are informational files, which join computer or mobile device when they are used for visiting the Website. User is entitled to switch off cookies in its browser’s settings. However if cookies are switched off some services of the Website might become unavailable. The additional information on how to manage or delete cookies User can find at http://www.allaboutcookies.org/. More information about the cookie files used by KVIKU.FINANCE could be found at https://kviku.finance/#.

  1. The User gives its Consent for its personal data processing (both electronically and manually) for the purpose of KVIKU.FINANCE attaining its objectives such as keeping users records, offering, rendering and maintaining services, financial and statistical analysis, realization and protection of KVIKU.FINANCE and/or User’s rights arising from the Agreement. The User has the right to withdraw its consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

  2. KVIKU.FINANCE informs the User and User agrees that by giving the Consent User also agrees that KVIKU.FINANCE discloses the received personal data to the following persons:

    1. To companies and enterprises related to KVIKU.FINANCE or which directly or indirectly have obtained a significant share in the share capital of KVIKU.FINANCE, or in which KVIKU.FINANCE has obtained direct or indirect participation, insofar as such information is necessary for the performance of functions delegated to them or for the provision of services by KVIKU.FINANCE to its USERS and performance of the Agreement signed between KVIKU.FINANCE and User, including to:

      1. Kviku Holding Ltd, registration No НЕ 382807, legal address: Gladstonos, 124, The Hawk Building, 1 floor, 3032, Limassol, Cyprus

    2. any person related to the fulfilment of KVIKU.FINANCE commitments arising from the Agreement (including, but not limited, to communications service providers, IT service providers, payment intermediaries, credit institutions etc.), ensuring the recipient`s commitment to protect and not to disclose personal data received;

    3. outsourced service providers that KVIKU.FINANCE requires for the provision of its services, insofar as such information is necessary for the performance of functions delegated to them, ensuring the recipient`s commitment to protect and not to disclose personal data received;

    4. upon handing over (transferring) the claim, ensuring the recipient`s commitment to protect and not to disclose personal data received;

    5. third parties taking legal actions in connection with the debt collection from the User (for instance, debt collectors, lawyers, court bailiffs, insolvency administrators and other persons acting in accordance with the applicable laws), ensuring the recipient`s commitment to protect and not to disclose personal data received;

    6. legal, accounting and auditing service providers to KVIKU.FINANCE, ensuring the recipient`s commitment to protect and not to disclose personal data received.

  3. KVIKU.FINANCE will communicate any rectification or deletion of its personal data or restriction to process it to the User, unless this proves impossible or involves disproportionate effort.

  4. In all instances KVIKU.FINANCE discloses personal data of its User’s to persons mentioned in this document KVIKU.FINANCE ensures signing of a written non-disclosure agreement with the recipient ensuring the recipient`s commitment to protect and not to disclose personal data received in accordance with conditions of Article 46 of GDPR.

  5. The User has the right to receive the personal data which it has provided to KVIKU.FINANCE, in a structured, commonly used and machine-readable format and have the right to transmit that data to another data processor without any hindrance from KVIKU.FINANCE, where:

8.1. the processing is based on a consent or an agreement; and

8.2. the processing is carried out by automated means.

  1. In exercising its right to data portability, the User has the right to have the personal data transmitted directly from KVIKU.FINANCE to another, where technically feasible. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the KVIKU.FINANCE. The User confirms, that KVIKU.FINANCE is entitled to use the User’s (Investor’) postal address, e-mail, and/or telephone number indicated in the User’s profile to send commercial and promotional communications about KVIKU.FINANCE and/or products and special offers from KVIKU.FINANCE.

  2. KVIKU.FINANCE is entitled to call and to send text messages (SMS) to the telephone number indicated by the User, to send letters via e-mail to the e-mail address indicated by the User, as well as dispatch mail to the User’s postal address indicated by the User.

  3. The User has the right to refuse receiving the information sent by KVIKU.FINANCE indicated in this document by notifying KVIKU.FINANCE about such decision in the User’s profile or by any other means of communication agreed with KVIKU.FINANCE.

  4. The User agrees that right of KVIKU.FINANCE to process personal data is in force for the duration of the Agreement.

  5. By giving its Consent to KVIKU.FINANCE for personal data processing, the User confirms, that KVIKU.FINANCE is entitled to take actions mentioned herein in accordance with GDPR, as well as confirms that according to the GDPR regulation it is notified and possesses the information as follows:

13.1. on personal data processing controller (KVIKU.FINANCE);

13.2. on aims of its personal data processing;

13.3. on possible recipients of its personal data;

13.4. on its right of access to its personal data and possibility to amend it;

13.5. on legal basis of personal data processing;

13.6. on its right two times per year to obtain information on individuals and legal entities, who has received from KVIKU.FINANCE the information on the User in a particular period of time free of charge;

13.7. on date, when the User’s personal data were changed, removed or blocked last time;

13.8. on the sources used to gather personal data;

13.9. on its right to obtain all information on it, which was generalized in the personal data processing system, if laws and regulations do not prohibit to provide such information.

  1. In case User’s requests KVIKU.FINANCE to provide its data collected by it, KVIKU.FINANCE will take appropriate measures to provide any information without undue delay and in any event within one month of receipt of the User’s request. That period may be extended by 2 (two) further months where necessary, taking into account the complexity of the task. KVIKU.FINANCE will inform the User of any such extension within one month of receipt of the request, together with the reasons for the delay. Where the User makes the request by electronic form means, the information will be provided by electronic means where possible, unless otherwise requested by the User. Information will be provided free of charge. Where requests from the User are manifestly unfounded or excessive, in particular because of their repetitive character, KVIKU.FINANCE may either:

14.1. charge a reasonable fee taking into account the administrative costs of providing the information or communication or taking the action requested; or

14.2. refuse to act on the request.

  1. The User confirms, that it has obtained all the necessary representations from KVIKU.FINANCE as follows:

15.1. on legality and fairness of the personal data processing;

15.2. on personal data processing in order and in amount necessary for attainment of services provided by KVIKU.FINANCE;

15.3. on personal data filing method, which helps to identify the User in a particular period of time, which does not exceed the period necessary for attainment of existing targets only;

15.4. authenticity of the personal data with duly updates dependent on User’s actions considering its duty to inform KVIKU.FINANCE on any changes in the data provided to it.

  1. User has the right to communicate with Data Protection Officer on data protection issues by e-mail: support@kviku.finance

  2. If User and KVIKU.FINANCE cannot resolve a complaint on data protection issues, User may lodge a complaint with a supervisory authority

  3. KVIKU.FINANCE will communicate any User’s personal data breach, in case such occurs, to the User without undue delay.

  4. In accordance with the conditions of applicable laws of Cyprus KVIKU.FINANCE shall keep User's identification data, account information, correspondence, User's research data for at least the minimum period allowed and/or required by applicable laws of Cyprus. Information on the agreements between KVIKU.FINANCE and the User should be kept by KVIKU.FINANCE for at least the minimum period allowed and/or required by applicable laws of Cyprus. Accounting records and accounting organization documents should be kept by KVIKU.FINANCE for the minimum period allowed and/or required by applicable laws of Cyprus.