I. GENERAL PROVISIONS

UAB SEVEN SEAS EUROPE, a private limited liability company incorporated under Lithuanian law, listed within Lithuanian Register of Legal Entities with the registration number of 304632897 (hereinafter the Company) is committed to protecting the privacy and security of the Client’s personal information. Company want to share how Company treat personal information about the Client that Company receive in connection with the Client’s use of our CompanybPlatform (the “Platform”).

This policy, together with the General Terms and Conditions and any other Ancillary agreements betCompanyen the Client and the Company constitute an entire legal agreements the Client accepts and consents to when visiting our Platform and/or using our Services (as defined in the General Terms and Conditions) among other things consenting to our use of the Client’s personal information as set out in this Privacy Policy. Any definitions used within this Privacy Policy shall have the meaning as defined in the General Terms and Condition .

This policy sets out the basis on which any personal data Company collect from the Client, or that the Client provides to us, will be processed by us. For legal purposes, the data controller is UAB SEVEN SEAS EUROPE, with registration number 304632897 and registered office at Olimpiečių st. 1-5, LT-09235 Vilnius, Republic of Lithuania. Company for any Data Protection related issues may be contacted by email at: [email protected].

Although Company operate internationally, the Company is organized under the laws of the Republic of Lithuania. The servers that host this Platform and any data collected from the Client are in Lithuania, and any personal details the Client provides to us will be processed by Company in Lithuania. If Company transfer personal data out of the European Economic Area, Company shall ensure that Company have in place measures which provide an adequate level of protection as required by applicable laws and regulations. All information Client provides to us is stored on our secure servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted. Where Company have given the Client (or where the Client has chosen) a password that enables the Client to access certain parts of our Platform, the Client is responsible for keeping this password confidential. Company ask Clients not to share the passwords with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although Company do our best to protect Clients personal data, Company cannot guarantee the security of it. When using any social/personal interaction features (if made available by the Company) Clients must ensure that they do not submit any personal data that they do not want to be seen, collected or used by others.

II. INFORMATION COMPANY COLLECT

a. INFORMATION THE CLIENT SUBMITS TO US

This is information the Client give us about the Client by filling in forms on the Platform, or by corresponding with us. It includes information the Client provide when the Client register to use the Platform, open an Account, enter into any transaction on the Platform (such as purchase of Electronic Money, Payment Transaction and/or Redemption transaction and others), when the Client report a problem with the Services, or the Platform.

If the Client contact us, Company will keep a record of that correspondence (if contacted via e-mail or any other means made available on the Platform).

The information the Client give us may include: Client’s full name, Client’s billing address, date of birth, e-mail address, phone number or any other identifier for communication (like skype name, CompanyChat account identifier, etc.), details of Client’s bank account including the bank account number, IBAN, copies of identification documents (collected for the Know Client’s Customer purpose are defined in the General Terms and Conditions), copies of documents required to prove source of funds, personal description and photograph and any other information the Client provide us in order to prove Client’s eligibility to use our services.

b. INFORMATION COMPANY COLLECT ABOUT THE CLIENT AND THE DEVICE

Each time the Client visit the Platform (and in some cases disregarding if the Client access Client’s account on the Platform or not) Company will automatically collect the following information:

Technical information: the internet protocol (IP) address used to connect Client’s device to the Internet, Client’s login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

Information about Client’s visit: full uniform resource locators (URL), services the Client vieCompanyd or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page;

Transaction details: date, time, amounts, currencies used, exchange rates, Recipient details and details about other third parties involved in transactions (senders and receivers of funds from Client’s Account).

Details of Client’s visits to the Platform: transaction details relating to Client’s use of Services, including who the Client has sent funds or Electronic Money to, foreign exchange transactions the Client has entered into, the time, date and location of the place the transaction was entered into.

c. INFORMATION COMPANY RECEIVE FROM OTHER SOURCES (THIRD PARTY INFORMATION)

Company closely work with fraud prevention agencies and user third-party databases in order identify possibly fraudulent transactions as Companyll as to identify our customers; sources of funds and complete any other Compliance procedures as requested by laws and regulations. By agreeing to this Policy, the Client consent that Company may carry out various searches and checks to identify all information required for regulatory purposes. For avoidance of doubt Company clearly state hereby that will receive information about the Client from third parties Company use to verify Client’s identity.

III. COOKIES

Company use cookies to distinguish the Client from other users of the Platform. This helps us to provide the Client with a good experience when the Client use the Platform and allows us to improve our services. For detailed information on the cookies Company use and the purposes for which Company use them, see our cookie policy https://sevenseasfinance.com/cookie-policy

IV. RIGHTS OF ACCESS

Following laws and regulations, the Client has the right to access the personal information Company hold about the Client. The Client can exercise this right by contacting us on [email protected]

At any time, the Client can request that Company modify or delete Client’s personal information with the words “UPDATE MY INFORMATION” in the subject line.

To protect Client’s security and privacy, Company will take reasonable steps to verify Client’s identity prior to making changes to Client’s personal information or satisfying a request for access to that information.

V. HOW COMPANY USE THE INFORMATION COMPANY COLLECT

Company uses data about the Client (contact and personal data, usage history, etc.) that Company collect from the Client through the Platform in order to provide the Client with, and develop and improve, the services on our Platform.

Company uses the personal information about the Client that the Client provide to us for our internal purposes such as responding to Client’s requests for information or materials, delivering newsletters to the Client, contacting the Client, assessing Client’s application for a position with Company and entities related to Company, processing and completing orders, processing Client’s payment, administering Client’s account, administering and developing our business relationship with the Client or the company the Client represent and to provide the Client with administrative communications regarding Client’s account.

Company also uses Client’s personal information to communicate with the Client, such as, for example, newsletters, press releases, or information relating to products, offers, or programs that may be of interest the Client. Please see the section on opting in and opting out for more information.

VI. WHO DO COMPANY SHARE INFORMATION WITH?

Company will not disclose Client’s personal information to third parties except as set out in this Privacy Policy or if the Client has consented to such sharing. Company may share the personal information about the Client that the Client provide to us with trusted companies Company have hired to provide services for us, such as sending out our newsletters, fulfilling orders the Client may submit, or collecting and processing information on our behalf.

These companies – our vendors – are contractually bound to use personal information that Company share with them only to perform the services Company have hired them to provide and to have appropriate technological and organizational measures including security in place to protect such personal information.

If the Client enable third party services to be directly integrated into Client’s account (for example Facebook Connect), the Client agree that Company may pass Client’s account information to the providers of such services to enable them to provide the Client with the services which the Client has requested. Company does not exercise any control over such service providers, such service providers process Client’s account information independently and in accordance with Client’s own privacy policies.

Company may also share Client’s personal information if the business of Company is transferred to another entity by way of merger, sale of the company’s assets, or otherwise. If the Client consent, Company may share Client’s information with Company related entities and selected third parties so that they may provide the Client with or contact the Client regarding information and materials that may be of interest the Client. Please refer to the section below on opting in and out.

Company may share Client’s personal information with a third party if Company are required to do so to comply with applicable law or a court order, or if it is reasonable to do so, to enforce our Terms and Conditions or to assist with a legitimate investigation (for example, in relation to suspected fraud or third party intellectual property infringement).

VII. THE NON-PERSONAL AGGREGATE DATA COMPANY COLLECT

Company may also collect and group demographic and preferences information, responses to surveys and other personal information that Company collect from the Client into an aggregate, anonymous form for disclosure to our existing or potential business partners, affiliates, sponsors or other third parties. However, please be assured that this aggregate data will in no way identify the Client as an individual or any other visitors to the Platform.

Company may collect general, non-personal, statistical information about the use of the Platform, such as how many visitors visit a specific page on the Platform, how long they stay on that page and which hyperlinks, if any, they “click” on. Company collect this information using “cookies” and other tracking technologies.

Company collect this information to determine which areas of the Platform are most popular and to enhance the Platform for visitors. As with other aggregated data, Company may disclose such data to our existing or potential business partners, affiliates, sponsors or other third parties, but this aggregate data will in no way identify the Client as an individual or any other visitors to the Platform.

VIII. OPTING IN AND OUT

When the Client submit personal information to us through the Registration Page on this Platform, the Client consent to receiving additional information from Company. If the Client decide that the Client do not want to receive information such as promotion and marketing messages, the Client are given the option to opt out of receiving these messages from us. Company will not send the Client information from third parties and/or partners unless the Client specifically consent to this.

IX. LINKS TO OTHER PLATFORMS AND PLATFORM ACCOUNTS

For Client’s convenience, the Company’s Platform may from time to time include links to third-party Platforms whose information practices may be different than ours. Visitors should consult the other Platforms’ privacy policies, as Company have no control over information that is submitted to, or collected by, these third parties.

Platform Accounts are pages on certain websites operated by other companies (for example, the Company page on Facebook), where Company content is provided. The Terms and Conditions, this Privacy Policy, the Terms and Conditions and other applicable rules published on this Platform are binding on and apply to the users and visitors of Platform Accounts. Users and visitors should carefully read the terms and conditions and privacy policies of such websites, over which Company has no control. Company has Platform Accounts on the following websites: Facebook, Google+, Twitter, Pinterest, The YouTube, and other social networks.

X. SECURITY OF INFORMATION

Company uses industry standard security measures to safeguard information concerning and submitted by the Client. Despite the security measures employed by Company, the Client should be aware that it is impossible to guarantee absolute security with respect to information sent through the Internet.

XI. DISCLOSURES

Company will, to the extent possible, control Client’s personal information, and, except as otherwise set forth in this Privacy Policy, Company will not disclose Client’s personal information to third parties. Although Company are committed to maintaining the confidentiality of Client’s personal information, if required by law or regulation, Company reserve the right to disclose such information without first obtaining Client’s consent.

XII. CHANGES TO THE PRIVACY POLICY

The Platform and services may change from time to time. As a result, it may be necessary for Company to make changes to this Privacy Policy from time to time. Company reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice by updating Company’s Platform.

Company ask that the Client please review the Privacy Policy periodically, and especially before the Client provide personal information. This Policy was last updated on the date indicated above. Client’s continued use of this Platform after any modification of this Privacy Policy shall constitute Client’s acceptance of the modified Privacy Policy.