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PRIVACY POLICY

Date of Effect: 18.03.2024.

PREFACE

Greetings from InHodlo! This Privacy Policy (“the Policy”) explains how we process (e.g., collect, use, etc.) and protect your personal data. We kindly request you to read this document carefully. By using our digital platform https://inhodlo.io ("the Website") and the services we provide therein, you agree to the terms of this Policy. If you have any concerns or questions, please reach out to us using the contact information provided in Section 15.

DATA CONTROLLER

UAB “Verator”, registry code: 306092631, registered address: Eišiškių Sodų 18-oji g. 11, LT-02194 Vilnius, Lithuania (also “Company”, “we” or “InHodlo”) is the data controller responsible for ensuring that your personal data is processed in compliance with personal data protection laws (e.g., the General Data Protection Regulation (the “GDPR”).

PERSONAL DATA CATEGORIES PROCESSED

For the goals set in our Privacy Policy, we handle various personal data types. Below are the main kinds of personal data we gather and process:

(a) Contact Data: Your basic contact information, such as email, phone number, and residence address.
(b) Identity Data: Data that proves who you are, like your date of birth, ID number, full name, and information from identification documents.
(c) Account Information: Includes your account usage details like login credentials, settings, username, and activities.
(d) Authentication Data: Data for verifying and identifying users, such as usernames, biometric data, and other identification information.
(e) Regulatory Compliance Data: Data we need to comply with laws and regulations, like Anti-Money Laundering, sanctions, and tax information.
(f) Device Data: Information about the device you use for accessing our services, including your IP address, type of device, and browser details.
(g) Order Data: Information related to your order history and details.
(h) Payment Information: Necessary details for making payments, including your credit card or bank account information, payment method, and balance.
(i) Transaction Data: Details of your transactions with us, including the history and specifics of those transactions.
(j) Financial Information: Data about your financial transactions and condition.
(k) Marketing Data: Information about your preferences for marketing.
(l) Support Data: Information from customer support interactions, useful for solving problems and improving service.
(m) Communication Records: Information from your communications with us, including submitted forms, inquiries, and email exchanges.
(n) Surveillance Records: In certain places, we might collect video records and metadata for security reasons.
(o) Entity-Related Information: Information concerning the legal entity you represent, such as its official name, registration information, and applicable legal identification numbers.

SOURCES OF DATA

We collect and process your personal information through multiple methods, including:
(a) Direct Engagement: Information is gathered when you sign up, conduct transactions, or directly interact with our services or Website.
(b) Third-Party Sources: Information also comes from third-party service providers assisting in our service delivery and from publicly accessible sources, including during payment transactions.
(c) Cookies and Similar Technologies: Data is also received through cookies during your Website interactions.

PURPOSES AND LEGAL GROUNDS FOR PROCESSING PERSONAL DATA

We handle personal data based on specific reasons and legal foundations, aiming for complete transparency and responsibility. Below, we summarize these reasons and the legal justifications we rely upon:

(a) Purpose: Setting Up and Managing Your User Account (explanation: We use personal data to create and look after your account with us, including setting up login details, managing your settings, and keeping track of your activities.). Legal Ground: Need for a contract.
(b) Purpose: Forming Agreements and Providing Our Services (explanation: Processing your information is crucial for making agreements with you and delivering the user experiences you expect.). Legal Ground: Need for a contract.
(c) Purpose: Verifying and Authenticating User Identities (explanation: It is essential for our platform's security and meeting legal duties to check who our users are and ensure they are who they say they are, keeping our environment safe from unauthorized use.). Legal Ground: Legal requirements and our legitimate interests.
(d) Purpose: Communicating with You and Offering Customer Support (explanation: We use your data to send important updates and provide support, making sure you're well-informed and any concerns are promptly addressed.). Legal Ground: Need for a contract and our legitimate interests.
(e) Purpose: Preventing Fraud and Service Misuse (explanation: It is vital to process data for preventing and addressing fraud or misuse of our Website and services.). Legal Ground: Legal requirements and our legitimate interests.
(f) Purpose: Processing and Managing Your Orders (explanation: To cater our user needs, we handle your information for processing and managing your purchases, ensuring transactions and order tracking are smooth. Legal Ground: Need for a contract.
(g) Purpose: Complying with Specific Legal and Regulatory Obligations (explanation: We follow laws and regulations specific to our industry, like Anti-Money Laundering and tax laws, ensuring we operate legally and securely.). Legal Ground: Legal requirements and tasks carried out in the public interest.
(h) Purpose: Handling Transactions (explanation: Processing transaction-related data is key to managing purchases or other financial dealings, also including fraud prevention to protect both our users and platform.). Legal Ground: Need for a contract and our legitimate interests.
(i) Purpose: Risk Management and Business Decision Making (explanation: We process information for assessing risks and making business decisions, crucial for our services' safety and efficiency, including risk evaluation and business planning.). Legal Ground: Need for a contract, legal requirements, and our legitimate interests.
(j) Purpose: Handling Claims and Settling Disputes (explanation: We process data to manage claims and resolve any disputes, ensuring issues are settled fairly and maintaining positive customer relations.). Legal Ground: Need for a contract, legal requirements, and our legitimate interests.
(k) Purpose: Enhancing and Developing Our Services (explanation: We analyze feedback, metrics, and current trends to continuously improve and evolve our services, aiming to enhance your user experience.). Legal Ground: Our legitimate interests.
(l) Purpose: Solving Technical Problems (explanation: Addressing technical issues ensures our platform runs smoothly and reliably, enhancing your user experience.). Legal Ground: Need for a contract.
(m) Purpose: Maintaining Overall Service and Information Security (explanation: Protecting our services, information, and assets against unauthorized access and threats is essential for safeguarding your data and our platform's integrity.). Legal Ground: Need for a contract, legal requirements, and our legitimate interests.
(n) Purpose: Delivering Marketing Materials and Customized Content (explanation: We tailor marketing and content to your preferences and interactions, enhancing your engagement and experience on our platform.). Legal Ground: Your consent and our legitimate interests.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We assure you that your personal data will neither be sold nor leased to external parties. Nonetheless, it may be necessary to share your details with reliable partners who contribute to our service delivery, including activities like payment processing and offering customer service. Furthermore, legal obligations may compel us to release your information to governmental bodies.

PROTECTING YOUR PERSONAL DATA

Protecting your personal information is a critical priority for us. We adopt a thorough strategy to keep your data safe, using both technology and careful organizational practices to guard its confidentiality and integrity. Our security actions include strong encryption to shield your data when it Is sent or stored; tight controls to limit who can see personal information; regular training for our team on staying secure; and working with trusted third parties that meet strict security standards, like those needed for payment processing (e.g., the Payment Card Industry Data Security Standard (PCI DSS)).

However, it is important to remember that keeping your personal information safe is a joint effort. We encourage you to follow good security habits, such as creating strong, unique passwords; keeping your passwords and login details private; avoiding public Wi-Fi for important tasks; updating your devices; and being cautious of suspicious emails or messages.

MOVING DATA ACROSS BORDERS

Your personal data may sometimes be sent to and processed in places beyond the European Economic Area (EEA). In these situations, we ensure that the transfer meets the required data protection standards, including those set by the GDPR. We use various methods like adequacy decisions, Standard Contractual Clauses (SCC), or other legal protections to make sure your data is properly protected.

YOUR RIGHTS OVER YOUR PERSONAL DATA

According to laws like the GDPR that protect your data, you have several rights over your personal information:
(a) Access: You can ask to see the personal information we have about you and get a copy of it.
(b) Correction: If any of the personal data we hold is wrong or incomplete, you are allowed to have it corrected.
(c) Deletion: In certain situations, you can ask us to delete your personal data.
(d) Restriction of Use: You can request that we only use your data in limited ways in specific cases.
(e) Objection to Use: You have the right to say no to us using your data for certain purposes, like for sending you marketing materials.
(f) Portability: You can ask for a copy of your data in a format that is easy to read and use elsewhere, meaning you could give it to a different company if you wanted.
(g) Withdraw Consent: If you have given us permission to use your data, you can take back that permission at any time, though this will not impact anything that we have already done with your permission.

Please note that there might be some rules or legal reasons that could delay or affect your ability to use these rights right away. We might also need to check who you are before we can help, just to keep your data safe.

If you want to use any of these rights or if you need more information, you can reach out to us using the contact information provided in Section 15.

STORAGE AND RETENTION OF PERSONAL DATA

We keep your personal data only as long as needed to meet the goals mentioned in this Privacy Policy, or longer if the law requires it. How long we keep data depends on legal rules, what kind of data it is, and why we collected it. Sometimes, we might have to keep your information for more reasons, like following legal rules or sorting out disagreements. When we do this, we will make sure we are following all the necessary laws, including the GDPR. If there is no legal reason to keep your data and it is no longer needed for its original purpose, we will safely get rid of it. Also, whenever possible, we will make the data anonymous, which means we will remove any details that could identify you, making sure the data cannot be linked back to you.

DATA PROVISION REQUIREMENTS

It is necessary to provide certain information, marked as required, to ensure our services work properly and are available to you. If you do not provide this required information, you may not be able to use some of our services, like creating an account or making transactions. There is also information that you can choose to provide or not. It Is up to you to decide what extra information you want to share with us. You can change your preferences for this optional information in your account settings or by reaching out to our support team later. Not providing optional information will not stop you from accessing our main services and features.

AUTOMATED DECISION MAKING AND USER PROFILING

We do not use automated decision-making processes that could affect your legal rights. However, to make your experience better, we do use profiling. This means we customize the content and recommendations you see, based on your preferences and past activities, always making sure to be transparent about it.

HANDLING DISPUTES AND COMPLAINTS

We strive to address any concerns regarding your data processing. However, if you are dissatisfied, you have the right to lodge a complaint with the national data protection authority in Lithuania – the State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija).

POLICY MODIFICATIONS

This Policy may be revised to reflect our evolving practices. Any changes will be posted on our Website and we advise regular reviews of this Policy. Significant amendments will be communicated through your provided contact details or other appropriate communication means.

FURTHER ASSISTANCE

For more information or if you need assistance, please contact us at support@InHodlo.io. Your privacy and satisfaction with our services are of utmost importance to us.

Help Center

InHodlo OÜ, Reg.Nr. 14922967, Address at Harju maakond, Tallinn, Kristiine linnaosa, A. H. Tammsaare tee 47, 11316

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