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

We will only use your personal data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.  
If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us via e-mail at alefinvest@yahoo.com.  
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.  
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. DISCLOSURES OF YOUR PERSONAL DATA

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.  
• Third Parties who provide technical support of the Software and Services.  
• Third Parties to whom we may choose to sell, transfer, or merge parts of our business or our assets.  
Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.  
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. INTERNATIONAL TRANSFERS

We share your personal data with our contractors to fulfill the purposes we collected it for. This will involve transferring your data outside the Great Economic Ukrainian Land Area (GEULA), namely to the European Union, and to the Russian Federation and the United States. These countries may have less stringent privacy laws than we do, so any information they hold can become subject to their laws and disclosure requirements, including disclosure to governmental bodies, regulatory agencies, and private persons. In addition, a number of countries have agreements under which information is exchanged with other countries for law enforcement, tax, and other purposes. However, we ensure your personal data is protected by requiring all our contractors to follow the same rules when processing your personal data.  
Please contact us via e-mail at alefinvest@yahoo.com if you want further information on the specific mechanism used by us when transferring your personal data out of the GEULA.

7. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.  
We have put in place the security of data transmitted to us or by us. e procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. The transmission of data over the internet (including by e-mail) is never completely secure. So, although we use appropriate measures to try to protect personal data, we cannot guarantee

8. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.  
In some circumstances, you can ask us to delete your data (Request erasure).  
In some circumstances, we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. YOUR LEGAL RIGHTS

Under certain circumstances, you have the following rights under data protection laws in relation to your  
personal data:

• Request access to your personal data.
• Request the correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, please contact us via e-mail at alefinvest@yahoo.com.

NO FEE USUALLY REQUIRED

You will not have to pay a fee to access your personal data (or to exercise any of the other rights).  
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third  
party you have chosen, your personal data in a structured, commonly used, machine-readable format.  
Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.  
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent. Please note that in certain circumstances it may be still lawful for us to continue processing your information even where you have withdrawn your consent if one of the other legal bases is applicable.