This Privacy Policy governs the collection, use, maintenance, and disclosure of information that Komainu Holdings Limited (“Komainu Holdings”) and its subsidiaries and affiliates (together, “Komainu” or “we”) collects from its users.
1. PERSONALLY IDENTIFIABLE INFORMATION
2. NON-PERSONALLY IDENTIFIABLE INFORMATION
3. LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
4. YOUR RIGHTS OVER PERSONAL INFORMATION
5. WEB BROWSER COOKIES AND TRACKING TECHNOLOGIES
6. ANALYTICS & ADVERTISING
7. INFORMATION STORAGE AND RETENTION
8. INFORMATION
9. DATA-CONTROLLING ENTITY
10. MINORS
11. THIRD PARTY SITES
12. CHANGES TO THIS PRIVACY POLICY
13. CONTACTS
1. PERSONALLY IDENTIFIABLE INFORMATION
1.1 We may collect personally identifiable information from users in a variety of ways, including, but not limited to, when users visit our website (“Website”), register on the Website, use the Services, and in connection with activities, services, features, or resources we make available on the Website from time to time.
1.2 The personal information that we may collect from you will depend on your type of usage of our services and may include
(a) your name and title;
(b) address and email address;
(c) your date and place of birth;
(d) your citizenship(s);
(e) incorporation and controller information;
(f) information about your investor status;
(g) information about your source of funds;
(h) your KYC and CDD documentation;
(i) payment information;
(j) nature of the product or service requested;
(k) login details;
(l) location information;
(m) related information required for the supply of the Platform and other services to you.
2. NON-PERSONALLY IDENTIFIABLE INFORMATION
2.1 We may also collect non-personally identifiable information from users when they interact with the Website and our platform (“Platform”). This may include the browser name, type of computer or mobile device, and technical information about the means of connection, including, but not limited to, the operating system and internet service providers.
3. LEGAL BASIS FOR USING YOUR PERSONAL INFORMATION
3.1 The use of your personal information is necessary to perform the relationship between us. In order to use our services, we must be able to use your information to respond to your requests and provide the services.
3.2 We rely on your consent where required by law, for example in relation to direct marketing practices. You may withdraw consent at any time by contacting us using the details set out at the end of this Privacy Policy.
3.3 We may use your personal information for various legitimate interests, including the improvement of our products and services, meeting our legal, regulatory and ethical obligations, ensuring the security of our systems and managing the content of the Website. When processing personal information to meet these legitimate interests, we balance these against the fundamental rights and freedoms of data subjects and put in place robust safeguards to ensure that your privacy is protected.
3.4 We may use or disclose your personal information when required to do so by law, regulation or requests of a competent authority (for example, regulatory KYC and reporting obligations) or within the Komainu group of entities and its affiliates solely for the purposes set out above. Komainu will use reasonable endeavours to ensure the data is only accessible by those with a need for access.
3.5 Occasionally, we may have to process more sensitive personal data which requires special protection. We will only collect such data with your express consent in instances where it is necessary for compliance with legal or regulatory obligations.
4. YOUR RIGHTS OVER PERSONAL INFORMATION
4.1 Subject to applicable laws, you have rights regarding your personal information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the filing of a claim to your local data protection authority.
4.2 We encourage you to contact us to update your information in the event that it changes or is inaccurate. If you would like to discuss or exercise the rights in clause, please contact us using the details set out at the end of this Privacy Policy.
5. WEB BROWSER COOKIES AND TRACKING TECHNOLOGIES
5.1 Our Website may use “cookies” to enhance the user experience. Cookies are small pieces of information which are placed in your computer’s memory when you visit a website. When you enter our site our web server sends a cookie to your computer which allows us to recognise your computer. By associating the identification numbers in the cookies with other customer information then we know that the cookie information relates to you. We use cookies to improve your user experience and the quality of our site and services.
5.2 You may choose to set your personal web browser to refuse cookies, or to alert you when cookies are being sent. However, this may affect your use of the Website and Platform.
5.3 By continuing to use our Website and Platform without changing your settings, you consent to our use of cookies in accordance with this Privacy Policy.
6. ANALYTICS & ADVERTISING
6.1 Our services use Google Analytics, a web analytics service provided by Google, Inc (“Google”). Google Analytics uses cookies to help us analyse how users use our Website. The information generated by the cookie about your use of our services (including your IP address) will be transmitted to and stored by Google on servers in the United States.
6.2 Google is self-certified under the EU-US Data Privacy Framework (“DPF”).
6.3 Google will use this information for the purpose of evaluating your use of our services, compiling reports on service activity for service operators, and providing other services relating to services activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
6.4 Our services use PipeDrive to store the details of our customers. In the process of working with Pipedrive your data may transfer data to countries other than the one in which you live, including transfers to the United States. Pipedrive participates and complies with the DPF set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information of individuals in the European Union. Pipedrive Inc. has been certified by the Department of Commerce that it adheres to the DPF Principles.
7. INFORMATION STORAGE AND RETENTION
7.1 We adopt appropriate data collection, storage, and processing practices and security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal information, username, password, transaction information, and data stored on the Platform.
7.2 All personal information shall be dealt with in accordance with the Data Protection (Jersey) Law 2018, the General Data Protection Regulation (EU) 2016/679, UAE Federal Decree-Law No. [45] of 2021 on the Protection of Personal Data, and any other applicable data protection legislation or regulation.
7.3 We will retain your personal information for a period of time which enables us to:
(a) maintain business records for analysis and/or audit purposes;
(b) comply with record retention requirements under applicable law;
(c) defend or bring any existing or potential legal claims;
(d) deal with any complaints regarding the services.
7.4 We will delete your personal information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
8. INFORMATION DISCLOSURE
8.1 We may disclose personal information without notice to you if a law, regulation, search warrant, subpoena, court order, or regulatory notice permits or requires us to do so. We may also disclose personal information without notice to you to prevent fraud or abuse, or to protect the rights, property, or personal safety of one of our employees, users, service providers, or the public.
8.2 We may share your personal information with third party service providers to fulfil or enhance the service provided to you.
8.3 We may share your personal information with other employees, directors, or officers of any of our group entities.
8.4 We may share your personal information with any third party who purchases or to which we transfer all or substantially all of our assets or business. We will use all reasonable efforts to ensure that the entity to which we transfer your personal information uses it in a manner consistent with this Privacy Policy.
8.5 We may disclose otherwise confidential personal data or information if compelled to do so by laws and regulations applicable to us or our agents, whether in the EEA or elsewhere.
8.6 We shall not sell, trade, or rent your personal information to others.
9. DATA-CONTROLLING ENTITY
9.1 Komainu Holdings Limited is the ultimate data controller for the Komainu group of entities. In addition, certain other Komainu entities may act as a data controller if registered or regulated as such in the relevant jurisdictions.
10. MINORS
10.1 We are not structured or intended to attract any person under the age of 18.
11. THIRD PARTY SITES
11.1 Certain third party services, websites, or applications used to navigate to and from Komainu’s Website or Services have separate user terms and privacy policies that are independent of this Privacy Policy. We are not responsible for the privacy practices of these third party services or applications. We recommend carefully reviewing the user terms and privacy statement of each third party service, website, and/or application before use.
12. CHANGES TO THIS PRIVACY POLICY
12.1 It may become necessary to change the terms of the Privacy Policy from time to time as necessary to comply with law or for legitimate business purposes.
12.2 By continuing to use our services, you agree to remain bound by the Privacy Policy as amended. You acknowledge and agree that it is your responsibility to periodically review this Privacy Policy and check for any changes.
13. CONTACTS
13.1 If you have any questions about or any concerns or requests in relation to the Privacy Policy or our processing of your personal data, please contact us at privacy@komainu.com or your usual Komainu contact.
13.2 The appointed Data Protection contact for:
(a) Komainu Holdings;
(b) Komainu (Jersey) Limited (“Komainu Jersey”);
(c) Komainu UK Limited (“Komainu UK”);
(d) Komainu MEA FZE (“Komainu FZE”);
(e) Komainu Europe Limited (“Komainu Ireland”);
(f) Komainu Europe S.r.l (“Komainu Italy”); and
(g) Komainu Singapore Pte. Ltd. (“Komainu Singapore”),
can be reached at privacy@komainu.com.
13.3 Should you wish to report a complaint or feel that we have not addressed your concern in a satisfactory manner, you may contact:
(a) in the case of Komainu Holdings, Komainu Jersey, and Komainu Group Services, the Jersey Office of the Information Commissioner (enquiries@jerseyoic.org or breach@jerseyoic.org);
(b) in the case of Komainu UK, the UK Information Commissioner’s Office (https://ico.org.uk/make-a-complaint/);
(c) in the case of Komainu MEA, the UAE Data Office;
(d) in the case of Komainu Ireland, the Data Protection Commission of Ireland (https://forms.dataprotection.ie/contact);
(e) in the case of Komainu Italy, the Italian Data Protection Authority (https://www.garanteprivacy.it/web/garante-privacy-en); and
(f) in the case of Komainu Singapore, the Personal Data Protection Commission of Singapore (https://www.pdpc.gov.sg/Contact-Us).
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