Nextury Asset Management

Privacy Policy

Nextury Asset Management Privacy Policy: How personal data is collected, used, and stored, and what rights data subjects have.

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Privatumo Politika – Nextury Asset Management

Chapter I

General Provisions

This document (the „Privatumo politika") sets out the main principles and procedures for the collection, processing, and storage of your Personal Data by UAB Nextury Asset Management (data registered in the Register of Legal Entities of the Republic of Lithuania, legal entity code 304045309, registered office address: Gedimino Ave. 20-35, LT-01102 Vilnius, Lithuania, email: info@nextury.am ) ( the Company) when you use the Company’s website at https://nextury.am/ the “Website”).

This Privacy Policy is intended to inform you about the conditions for the processing of Personal Data by the Company. This Privacy Policy also applies to Website Accounts.

You may review and print this Privacy Policy at any time on the Website. You will be informed about any future changes and/or additions to this Privacy Policy by the publication of the updated version on the Website.

The Website may contain links to websites operated by other individuals, companies, or organizations. The Company emphasizes that it is not responsible for the content of such websites and/or the methods they use to ensure privacy protection. Therefore, before providing any information about yourself, you should review the rules, privacy policy, and other documents of the relevant website.

When processing Personal Data, the Company complies with the Regulation, the Law on the Legal Protection of Personal Data of the Republic of Lithuania, the Law on Electronic Communications of the Republic of Lithuania, and other directly applicable legal acts governing the protection of Personal Data, as well as instructions and recommendations issued by competent authorities.

Chapter II

Definitions

Personal Data

Any information related to a natural person, the data subject, whose identity is known or can be directly or indirectly identified using the relevant data.

Recipient of Personal Data

A legal or natural person to whom your Personal Data is disclosed, including companies related to the Company (parent and subsidiary companies), as well as partners with whom the Company cooperates to enable you to use the Website.

Controller of Personal Data

The Company.

IP Address

A unique number assigned to every computer connected to the internet, known as an Internet Protocol (IP) address. Since these numbers are usually assigned by country blocks, an IP address can often be used to identify the country from which the computer is connected to the internet.

Browser

A program that helps you access websites on the internet using a personal computer, phone, or other device.

Internet Protocol (IP) address and internet service provider used to connect the device to the internet, browser type and version, time zone settings, browser plug-in type and version, operating system and platform, login location, font encoding, and the full Uniform Resource Locator (URL). Uniform Resource Locator (URL)).

Regulation

Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Small files placed on your computer, phone, tablet, or other device when you visit the Website, which help the Website recognize your device. This term includes not only cookies but also similar technologies, such as flash cookies.) naudojimą.

Direct Marketing

Any activities that enable the Company to offer services or send any other information to you by mail, phone, or other direct means, for the purpose of informing you or obtaining your response, as well as all related services.

Rules

The Company’s Personal Data Processing Rules together with all appendices forming part of them.

Processing

Any operation performed on your data, including collection, recording, storage, modification, granting access, making inquiries, transferring, and other actions.

Chapter III

Principles of Personal Data Processing

In its activities, the Company follows these main principles of Personal Data processing:

17.1

Personal Data is collected for defined and lawful purposes.

17.2

Personal Data is processed accurately and fairly.

17.3

Personal Data is processed lawfully, meaning only when:

17.3.1. the data subject gives consent;
17.3.2. a contract is concluded or performed where the data subject is one of the parties;
17.3.3. the Company is required by law to process Personal Data;
17.3.4. Personal Data must be processed for the legitimate interest pursued by the Company or a third party receiving the Personal Data, provided that the interests of the data subject do not override those interests.

17.4

Personal Data is updated on an ongoing basis.

17.5

Personal Data is stored no longer than required for the established purposes of processing.

17.6

Personal Data is processed only by employees who have been granted such right.

17.7

All information about processed Personal Data is confidential.

Chapter IV

Nature of the Information Collected

The Company may collect and process the following Personal Data:

18.1 · Basic Information

Name, surname, personal identification number, date of birth, address / registered office address, telephone number, email address, signature.

18.2 · Information on Services and Investments

Information about the services provided, investments made and the duration of their use, as well as information related to compliance with legal requirements.

18.3 · Information on Consent to Direct Marketing

Information about your consent or refusal to receive advertising information, including news, programme offers, promotions, invitations to events and similar communications; participation in opinion surveys; use of your data; and disclosure of your data to third parties. Direct marketing offers will be provided to persons under the age of 14 only with the consent of their parents or other legal guardians.

18.4 · Communication and Customer Service Information

Data about browsing on the Company’s websites and self-service platforms, collected through cookies and similar technologies; information related to correspondence with the Company through self-service platforms, email, customised applications and similar channels; your enquiries and the Company’s responses regarding matters to be resolved.

18.5 · Other Data

Data collected from other lawful sources that do not fall within the categories listed above, including information about survey participants.

Chapter V

Purposes of Data Processing

The Company respects your right to privacy. The Company uses the collected data in order to provide its services and carry out its activities, as well as to provide support, send notifications, offers and information, and protect its own rights and interests and those of third parties. The purposes of processing information are as follows:

19.1

For the conclusion and performance of a contract, including the provision of services, ensuring their quality, customer support and provision of information.

19.2

For direct marketing and general information about services, provided that you have not opted out of receiving such communications.

19.3

For accounting purposes.

19.4

For compliance with legal obligations, such as the prevention of money laundering, investor verification and similar requirements.

19.5

For the administration and improvement of the Company’s website, maintaining its security and ensuring that the content is presented on your device in the most efficient manner.

19.6

For the performance of legal obligations established by applicable laws.

19.7

For other purposes for which the Company has the right to process Personal Data, where the Company has obtained the data subject’s consent, where the processing of Personal Data is necessary for the Company’s legitimate interests, or where the Company is required to process such data under applicable laws.

Chapter VI

Methods of Data Collection

Information about you is obtained and collected in the following ways:

20.1

Information Provided by You

You provide information to the Company yourself, for example, by completing the Company’s applications, whether online or in paper form, investor questionnaires, contracts and/or other documents; electronically on our website; by submitting enquiries; by post, email, telephone or other means of communication, where such information is required to be provided by applicable laws or where you provide such information voluntarily.

20.2

Automatically Collected Information

Information is collected automatically when you use the Company’s website. In this way, your login data is recorded. Most automatically collected information is collected through cookies and other similar technologies. For more details, please see Section 10 of this Privacy Policy.

20.3

From Third Parties

On the basis of your consent, the Company may receive information about you from third parties, such as Google, Inc.

Chapter VII

Duration of Data Processing

The Company processes Personal Data only for as long as necessary to achieve the Company’s purposes, without prejudice to the Personal Data retention periods established by the laws of the Republic of Lithuania.

If the laws of the Republic of Lithuania do not specify a retention period for certain processed documents or other information, the Company processes Personal Data only for as long as necessary to achieve and implement the purposes set out in this Privacy Policy, taking into account the legal basis for the retention of Personal Data, the legitimate purpose and the principles of Personal Data processing. Upon expiry of the Personal Data retention period, the Personal Data shall be destroyed in accordance with the procedure established by applicable laws.

Chapter VIII

Data Transfer

When providing services and carrying out its activities, the Company may, in certain cases, transfer Personal Data to third parties.

In order to ensure the functionality of its services and Website, the Company also uses third-party services. The transfer of Personal Data to such data processors providing services to the Company shall be limited to the minimum extent necessary to ensure the provision of third-party services.

For the purposes set out in this Privacy Policy, the Company may transfer your data to the following data recipients:

25.1

Data processors that provide services and process Personal Data on behalf of, in the interests of and upon the instruction of the Company, for example, IT service providers and similar service providers. Data processors process Personal Data only in accordance with clearly provided instructions and undertake to ensure appropriate protection, confidentiality, and organisational and technical measures meeting security requirements in respect of the Personal Data received from the Company for processing, as set out in more detail in the agreements concluded between the Company and the data processors, or subcontractors where the Company’s consent has been obtained, regarding data processing.

25.2

Other data controllers that provide services to the Company and process your data in their own name, determining the principles of Personal Data processing, appropriate technical and administrative measures, retention and destruction periods, and ensuring the confidentiality of your Personal Data.

25.3

Entities entitled to receive information under applicable legal requirements, for example, courts, state and municipal authorities and similar bodies, only to the extent necessary for the proper compliance with applicable laws.

25.4

Other third parties on another lawful basis or with your consent, which may be obtained for a specific case.

The data processors to whom the Company transfers your Personal Data may be established outside the Republic of Lithuania, the European Union or the European Economic Area. Data shall be transferred to such processors only where this is permitted under applicable legal requirements and only after taking all necessary measures to ensure the protection of privacy.

Chapter IX

What Rights Do You Have?

You have the following rights:

27.1

To contact us and discuss any questions arising in relation to the processing of Personal Data carried out by the Company.

27.2

To receive confirmation from the Company as to whether Personal Data relating to you is being processed and, where such Personal Data is being processed, to access the Personal Data being processed and the related information.

27.3

To receive the Personal Data that you have provided yourself and that is processed on the basis of your consent or for the performance of a contract, in writing or in a commonly used electronic format, and, where possible, to request that such data be transferred to another service provider.

27.4

To request the correction of your Personal Data where the data is incorrect or inaccurate, or to request that incomplete data be supplemented.

27.5

To request the deletion of your Personal Data as a client of the Company where such data is processed on the basis of your consent and you withdraw the relevant consent. This right shall not apply where the Personal Data requested to be deleted is also processed on another legal basis, such as where processing is necessary for the performance of a contract or for compliance with an obligation under applicable laws.

27.6

To request the restriction of the processing of your Personal Data, for example, for the period during which the Company assesses whether you have the right to request the deletion of your Personal Data and whether such deletion is practically possible.

27.7

To object to the processing of your Personal Data for the purposes of the legitimate interests of the Company or third parties, where the processing of Personal Data is based on legitimate interests, except where there are legitimate grounds for such processing or where the processing is necessary for the establishment, exercise or defence of legal claims.

27.8

To object to the processing of your Personal Data for direct marketing purposes, including profiling related to such direct marketing.

27.9

To object to a decision based solely on automated processing, including profiling, where such decision produces legal effects concerning you or similarly significantly affects you. This right shall not apply where such decision-making is necessary for entering into or performing a contract with you, is permitted under applicable laws, or where you have given your explicit consent to such decision-making.

27.10

To withdraw your consent to the processing of Personal Data.

You may exercise your rights by submitting a specific request to the contact information provided in this Privacy Policy. Information related to the exercise of your rights is provided free of charge. The Company will, no later than 1 month after receiving the request, provide information about the actions taken in response to the request to exercise your rights or indicate the reasons for inaction.

The deadline for providing the requested information may be extended by an additional two months, if necessary, depending on the complexity and number of requests. When a request is submitted electronically, the information shall also be provided electronically.

A request for the enforcement of rights may be refused or subject to a fee if the request is manifestly unfounded or excessive, as well as in other cases specified in regulatory acts.

If you believe that your personal data is being processed in a manner that infringes upon your rights and legitimate interests under applicable law, you have the right to file a complaint regarding the processing of your personal data with the State Data Protection Inspectorate (https://vdai.lrv.lt/).

The Company recommends that you contact the Company first before filing a formal complaint (info@nextury.am) in order to find an appropriate solution to the problem.

Chapter X

Use of Cookies on the Website

In order to improve the user experience on its website, the Company may use cookies—small pieces of text information that are automatically created when browsing the website and stored on the visitor’s computer or other end device. Cookies allow us to recognize that you have previously visited the website, help us collect statistical data on website traffic, and enable users to navigate the website more conveniently. The Company processes de-identified Personal Data using cookies.

Essential cookies

Essential cookies are necessary for browsing and using the website and its features. Without essential cookies, it would be impossible to provide certain pages of the website, and the website would not function as smoothly as it should. Essential cookies do not collect any information for marketing purposes and do not track where you have visited on the website.

Additional cookies

Additional cookies allow us to tailor your website experience to your needs. These cookies are used to remember your preferences regarding language, country, or other browser settings, and to provide personalized or enhanced features so that you do not have to re-enter all this information the next time you visit the website. Additional cookies provide the Company with information about how often you visit the website, how much time you spend on it, and how frequently you use the website’s features. This allows the Company to improve the website’s structure and navigation to make it as user-friendly as possible.

Cookies are used. If you do not agree to have Google cookies stored on your computer or other device, you can change your web browser settings to disable all cookies, delete them all, or enable/disable them individually; however, please note that in such cases, some website features may not function as intended. For more information about the Google cookies used on the website, including information on cookie usage and removal, please visit the website www.allaboutcookies.org.

Chapter XI

Updating Personal Data

The Company ensures that your Personal Data is accurate and up to date; therefore, the Company kindly asks you to notify us of any anticipated changes regarding your Personal Data processed by the Company.

Chapter XII

Contact Information

Please feel free to contact us at the addresses below if you have any questions, requests, or comments regarding the Company’s Privacy Policy or our data processing practices:

info@nextury.am

Contact Persons

Director Valdas Grigonis

Phone

+370 621 26443

Address

20–35 Gedimino Ave., LT-01102 Vilnius, Lithuania

Chapter XIII

Final Provisions

This Privacy Policy is effective as of the date of its publication on the website. You will always be notified of any changes and/or additions to the Privacy Policy—which the Company reserves the right to make at any time—via the website and/or email.