PRIVACY POLICY

Kviku Holding Ltd. registration number: HE 382807, registered address: 28, Sofouli street, Chanteclair building, 3rd floor, office 307, Nicosia, 1096, Cyprus (hereinafter Kviku Finance) along with its subsidiaries/affiliates (hereinafter Kviku Group) respect your right to privacy and so are being transparent about how we collect, process and share your personal data and how you can exercise your privacy rights.

This Privacy Policy only applies to personal data that we collect through our website at kviku.finance (Website). By using or accessing our website or by providing personal data to us on or through the website, you consent to the collection, use, transfer and disclosure of that information in accordance with this privacy policy and applicable law.

Categories and sources of Personal Data

The following describes how we process data relating to identified or identifiable individuals (“Personal Data”), including the categories of Personal Data, its sources, and the purposes for which we process that data.

The term ‘personal data’ is the entryway to the application of the General Data Protection Regulation (GDPR). Only if a processing of data concerns personal data, the General Data Protection Regulation applies. It doesn't apply to the processing of personal data of deceased persons or of legal persons. The term is defined in Art. 4 (1). Personal data is any information which is related to an identified or identifiable natural person.

The categories of Personal Data we collect and process:

• Identity Data
  including, but not limited to information such as your name and surname; gender; date of birth, age and/or age range; account login details, including your user name and password, or other account-related information; ID or other official document details.
• Contact Data
  that relates to information about how we can communicate with you, such as email, phone numbers, physical addresses, social media profiles.
• Transaction data
  including, but not limited to the bank account number, card number, amount of transactions, time, investments, disbursements claimed, concluded assignment agreements data.
• Due diligence data
  such as source of funds, identifying documents data, sanction lists and other risk-based procedures data.
• Device/Network Data
  IP Address, online user ID, browser/ operating system, application logs, browsing data, URLs of referring/exit pages, device identifiers, time and duration of website access, time zone.
• Cookies and Other Tracking Technologies
  Kviku Finance and our third-party partners, such as our advertising and analytics partners, use cookies and other tracking technologies (e.g., web beacons, device identifiers and pixels) to provide functionality and to recognize you. For more information, please see our Cookie Policy, which includes information on how to control or opt out of these cookies and tracking technologies.

Sources of Personal Data we collect and process:

During the interaction between Kviku Finance and you, we collect and process data from various sources. We collect information about you when you provide it to us, when you use our services, and when other sources provide it to us.

Data you provide to us:
When you register an account or contact our support team, you provide us with your contact and billing information, your personal details and your ID documents data, photocopies, preferences and other profile information.

Information we collect automatically:
When you access our website, we collect data about or generated by the device(s) you use (your IP address, operating system, browser version), and your website-behavior.

Information other sources provide to us:
We receive information from third-party services such as advertising and market research, from our related companies social media, public databases, our business partners, as well as the information from other sources permitted by law.

Processing of Personal Data

According to the GDPR, processing means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction (Article 4 (2)). Being an entity that determines the purposes and means of the Personal Data processing, Kviku Finance acts as a controller.

We and all of our employees apply all diligence and security measures required by the law at processing user's personal data to ensure that it is only done for a purpose and to protect user's personal data against inadvertent or unauthorised use, disclosure or destruction.
We enable access to the user's personal data only to

• our employees with whom a non-disclosure agreement is concluded;
• a third person, who processes the data on behalf of us, with whom a non-disclosure agreement is concluded.

We exclude any access of the unauthorised third persons to user's personal data and our database containing such data.

When you use our website, we process your Personal Data in specific contexts and for certain specified purposes, as well as for our general business purposes.

• data on user's usage of the website. When you browse our website, we automatically collect and process Device/Network Data. We use this data as necessary to initiate or fulfill your requests for certain features or functions, such as keeping you logged in, delivering pages, etc. In addition to Device/Network Data, we may also collect and process Contact Data, Identity Data and Cookies or other Tracking technologies. We may also use this information in connection with our legitimate business interests.
• user identification and conclusion of agreement(s). In order to fulfill our regulatory obligations, identify users and conclude the agreement(s), Identity data, contact data and transaction data are collected and processed.
• due diligence. We use third-party websites as well as perform customer Due diligence ourselves in order to identify user (Identity data), source of funds (Due diligence data, Transaction data) and to comply with proper AML/CTF Policy together with anti-money laundering and counter terrorist financing law in force, and to conclude the agreement(s).
• interaction with the user. We process certain Identity data, Contact data and certain Transaction data as necessary in connection with our legitimate business interest in personalizing our services, sending informational letters, providing you with newsletters, promo and bonus programs. You may withdraw your consent to receive such information at any time but this does not mean withdrawal of consent to the processing of personal data in general.

We retain Personal Data for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law.

Purposes of Personal Data processing:

We process personal data for our legitimate business purposes, to fulfil our obligations arising from the User Agreement as well as from Assignment Agreement or provided for in the applicable law. Our main purposes in connection with collection, storage processing of user's personal data are as follows:

• in connection with providing our services, and fulfilling our contractual obligations to you
• to maintain the quality and stability of, and generally improve, our website
• to secure our services, and prevent fraud
• to personalize our services, and in connection with marketing and advertising
• to compile aggregate statistics regarding the use of the services, and for research and market analysis
• to verify your identity and other information you provided to us
• to make transactions
• to comply with the law, and for other purposes in the public interest
• to prevent and detect fraud and other illegal or criminal activity
• to update the records we hold about you from time to time

Transfer and disclosure of personal data

Your personal information may be transferred to, and processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective). Specifically, our website servers are located in Germany, and Kviku group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries. Whether such transfer is required by law or contractual obligations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy.

Your rights and obligations related to the personal information

Under the GDPR and corresponding legislation, you may have the following rights:

• You are entitled to request information from us about the personal data collected by us, about the persons to whom we have transferred your personal data at any time. We are entitled to refuse from provision of the above specified information in cases and scope provided by the law.
• You are entitled to withdraw previously given consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent.
• You are entitled to request termination of the personal data processing, and we are obliged to terminate processing of your personal data if you have duly performed all obligations of the agreements in force related to the services we provide.
• You shall be fully responsible for correct and valid personal data during the use of the website. You must inform us immediately about the changes in your personal data, incorrectness or invalidity by delivering to us the correct and valid personal data to replace the incorrect and/or invalid ones.
• You are entitled to contact or file a complaint with regulators or supervisory authorities about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.

Any questions or request for termination of processing of data must be submitted to the following email address: support@kviku.finance

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business requirements. We will post any privacy policy changes on this page. We encourage you to review this privacy policy whenever you use our services to stay informed about our Personal Data practices.