Privacy policy

INTRODUCTION

Welcome to Alef Invest's privacy policy.
Alef Invest respects your privacy and is committed to protecting your personal data. This privacy policy will
inform you as to how we look after your personal data when you use our Software and Services (collectively
“Products”) and tell you about your privacy rights and how the law protects you.

1. IMPORTANT INFORMATION AND WHO WE ARE

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how Alef Invest collects and processes your personal
data through your use of Products, including any data you may provide us when you communicate with
our support service.
Our Products are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy notice or fair processing
notice we may provide on specific occasions when we are collecting or processing personal data about
you so that you are fully aware of how and why we are using your data. This privacy policy supplements
the other notices and is not intended to override them.
Alef Invest is responsible for your personal data (collectively referred to as “we”, “us” or “our” in this
privacy policy). Our office is situated at Sadova str 9, apt#50, Novosilky, Kyiv-03027, Ukraine
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation
to this privacy policy. If you have any questions about this privacy policy, including any requests to
exercise your legal rights, please contact the DPO using the details set out below.

CONTACT DETAILS

Data Protection Officer - Oleksii Bondarenko
Email address: oleksiibondarenkoBAM@gmail.com
Postal address: Sadova street 9 apt#50, Kyiv-03027 Novosilky/Kyiv, Ukraine
Ceil: +380667907666.
You have the right to make a complaint at any time to the National Data Protection Authority in Ukraine
(https://www.dlapiperdataprotection.com/index.html). We would, however, appreciate the chance to deal
with your concerns before you approach the NDPAU so please contact us in the first instance.

CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

This version was last updated on
04/02/2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed
if your personal data changes during your relationship with us.

THIRD-PARTY LINKS

Our Software may include links to third-party websites, plug-ins, and applications. Clicking on those links
or enabling those connections may allow third parties to collect or share data about you. We do not control
these third-party resources and are not responsible for their privacy statements. We encourage you to
read the privacy policy of every third-party website, plug-ins, and applications you visit.

2. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person
can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store, and transfer different kinds of personal data about you which we have grouped
together as follows:

Information You Give Us: We receive and store the information you give us when communicating with
our support service. For example, you provide information when you communicate with us by e-mail, or
otherwise. As a result of those actions, you might supply us with such information as your name, address,
e-mail, phone numbers, wallet address, etc.

Automatic Information: We receive and store certain types of information whenever you use our
Products. For example, we use "cookies" and process anonymous usage statistics.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any
purpose. However, Aggregated Data is not considered personal data as this data does not directly or
indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the
percentage of users accessing a specific Software feature.

We do not collect any Special Categories of Personal Data about you (this includes details about your
race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade
union membership, information about your health, and genetic and biometric data). Nor do we collect any
information about criminal convictions and offenses.

3. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you. We will collect and process the following
data about you:

Information you give us. This is information about you that you give us by filling the forms or by
corresponding with us by post, phone, email, or otherwise. This includes the personal data you provide
when you communicate with our support services.

Automated technologies or interactions. As you use our Software, we may automatically collect
Technical Data about your equipment, browsing actions, and patterns. We collect this personal data by
using cookies, server logs, and other similar technologies.

4. HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and
  fundamental rights do not override those interests.
• Where we need to comply with a legal or regulatory obligation.

If you need details about the specific legal ground, we are relying on to process your personal data where
more than one ground has been set out in the table below.

CHANGE OF PURPOSE