PRIVACY AND COOKIE POLICY

Date of last update: 16.03.2026

This Privacy and Cookie Policy describes how Finextwin LLC (a company incorporated under the laws of Georgia, with its registered office at Georgia, Tbilisi, Ilia and Nino Nakashidze Street No. 1, Building 3, Apartment 3), also referred to in this Policy as “we”, “our” or “us”, collects, uses, stores, processes and transfers information related to your use of the website https://finextwin.com, the submission of inquiries through feedback forms, email and other communication channels, as well as in connection with the provision of our services.
This Policy has been drafted taking into account the requirements of the General Data Protection Regulation of the European Union (GDPR), the Law of Georgia “On Personal Data Protection”, as well as other applicable rules and principles in the field of personal data protection, confidentiality and information security.
This Policy explains what personal data we may collect, how and why we collect it, how we use it, in what circumstances we may transfer it to third parties, how long we retain such information, what rights belong to you as a data subject and how you may exercise those rights.
Finextwin LLC provides international consulting, corporate, administrative and support services, including, without limitation, assistance with company registration, corporate changes, licensing, immigration procedures, as well as support to clients in their interaction with banks, payment institutions, registrars, licensing authorities and other counterparties depending on the nature of the specific request.
Finextwin LLC is not a bank, payment institution, electronic money institution or any other financial institution and does not carry out banking activities.
We strive to ensure transparent, lawful and fair processing of personal data and take reasonable technical and organizational measures to protect it. We may update this Policy from time to time to reflect changes in legislation, the nature of our services, the composition of the providers we use, the technical infrastructure of the website and our internal procedures. The current version of the Policy is published on the website https://finextwin.com.
If you have any questions regarding this Policy or the processing of personal data, you may contact us by email at: info@finextwin.com.


1. Definitions

1.1. Personal Data
“Personal Data” means any information relating to an identified or identifiable natural person. Such information may include first name, last name, email address, phone number, postal address, date of birth, citizenship, place of residence, identification document details, employment information, company-related information, IP address, online identifiers, location data, as well as any other information which, separately or in combination with other information, allows a natural person to be directly or indirectly identified.

1.2. Controller of Personal Data
For the purposes of applicable data protection legislation, including the GDPR, the controller of personal data processed in connection with this website is Finextwin LLC, a company incorporated under the laws of Georgia with its registered office at Georgia, Tbilisi, Ilia and Nino Nakashidze Street No. 1, Building 3, Apartment 3. This means that we determine the purposes and means of processing personal data collected through the website, during correspondence, when reviewing requests and in connection with the provision of services.

1.3. Processing of Personal Data
“Processing of Personal Data” means any operation or set of operations performed on personal data, whether by automated means or otherwise. Processing may include collection, recording, systematization, structuring, storage, adaptation, alteration, retrieval, use, transfer, disclosure, restriction, anonymization, deletion and destruction of personal data.

1.4. Data Subject
“Data Subject” means a natural person to whom the personal data processed by us relates.

1.5. User
“User” means any person visiting the website https://finextwin.com, using its functionality, submitting requests through website forms, by email or otherwise interacting with us.

1.6. Services
“Services” means the consulting, corporate, administrative, organizational and support services provided by Finextwin LLC, including, without limitation, assistance with company registration, corporate changes, licensing, immigration procedures, the preparation and coordination of documents, as well as support to clients in their interaction with registrars, banks, payment institutions, licensing authorities, consultants and other counterparties, where this is required by the nature of the request.

1.7. Cookies
“Cookies” means small text files that the website sends to the user’s browser and that may be stored on the user’s device for subsequent reading during repeated visits to the website or interaction with certain elements of the website.

1.8. Anonymized Data
“Anonymized Data” means information altered in such a way that it can no longer be used for the direct or indirect identification of a specific natural person without additional information.

1.9. Data Recipient
“Data Recipient” means a natural or legal person, public authority, institution, organization or other recipient to whom personal data may be disclosed in accordance with this Policy and applicable legislation.

2. Information We Collect

In order to ensure the operation of the website, review user requests, provide our Services, comply with applicable legislation, protect the rights and legitimate interests of the company, and ensure the security of our activities, we may need to collect certain information about you.

2.1. Information You Provide
This category includes information that you provide to us directly when using the website, requesting a consultation, submitting an inquiry, ordering Services, subscribing to newsletters, corresponding with us or providing documents and information in connection with a specific project.

2.1.1. Provision of Services
When you submit a request for the provision of Services, obtain a consultation, request assistance with company registration, licensing, corporate changes, immigration procedures, as well as assistance in interaction with banks, payment institutions, registrars or other counterparties, we may request your contact information and other information necessary for the initial assessment of the request, preparation of a proposal, organization of work and subsequent provision of the relevant Services.
Such information may include:

• first name and last name;
• email address;
• phone number;
• country of residence;
• address;
• company name;
• information about planned or ongoing activities;
• description of the request;
• other information necessary to assess the possibility of providing the Services.

Depending on the nature of the specific service, the requirements of counterparties, applicable legislation, internal verification procedures, as well as the need to comply with reasonable compliance measures, we may request additional categories of data.
Such data may include:

• identification documents, such as a passport, national identity card, residence permit or other similar documents confirming identity or legal status;
• corporate documents, including constitutional documents, certificates of registration, extracts from registers, information on ownership structure, directors, shareholders and ultimate beneficial owners, as well as other documents and information relating to the company’s activities;
• financial information that may be required for the preparation of documents, confirmation of payment, interaction with banks, payment institutions, registrars, licensing authorities or other counterparties;
• information on employment, professional or business activity, where this is necessary in connection with the provision of the service or compliance with reasonable verification procedures.

2.1.2. Communication with Us
If you contact us directly by email, through feedback forms on the website, through messengers or other communication channels, we may collect your name, email address, phone number, company name, message content, attached documents and other information that you voluntarily provide to us.

2.1.3. Payment Information
If payment is required in connection with the provision of Services, we may process a limited amount of data necessary for issuing invoices, confirming payment, accounting, internal document management and compliance with applicable legislation.
Payment for Finextwin LLC services is made outside the functionality of the website, on the basis of an issued invoice, contract or other agreed commercial terms. In relevant cases, certain data may be processed by banks or other financial institutions in accordance with their own rules, internal procedures and privacy policies.

2.1.4. Documents and Materials Submitted in Connection with the Provision of Services
We may receive and process documents, questionnaires, forms, copies of identification documents, corporate documents, letters, declarations, proof of address, compliance questionnaires, certificates and other materials that are necessary for the preparation, organization and provision of the relevant Services.

2.1.5. Marketing and Informational Communications
If you subscribe to our newsletters, request commercial materials or otherwise express interest in receiving news, updates, analytics or offers, we may process your contact details for sending such communications to the extent permitted by applicable legislation.

2.2. Cookies and Similar Technologies
We use cookies and similar technologies on our website to ensure the proper functioning of the website, analyze traffic and improve the usability of the website.
Information collected through cookies may include data on the frequency of visits, interaction with individual pages and elements of the website, navigation between pages, traffic sources, technical parameters of the device and browser, browser language, session settings, as well as other data related to the use of the website.

2.2.1. Necessary Cookies
Some cookies are technically necessary for the proper functioning of the website, the security of its operation, preservation of the session, protection against abuse and the provision of a basic user experience. Such cookies may be used without separate user consent to the extent permitted by applicable legislation.

2.2.2. Analytical Cookies
Analytical cookies help us understand how users interact with the website, which pages are visited more frequently, how users navigate through the website and how the content and functionality of the website may be improved. Where applicable, analytical cookies are used on the basis of the user’s consent expressed through the cookie notice and consent mechanism used on the website.

2.2.3. Cookie Management
The user may manage cookies through browser settings, as well as through the cookie notice and consent mechanism. Disabling or deleting certain cookies may affect the functionality of some website features.

2.3. Logs and Technical Data
We use log files, logs and other technical records to store information obtained as a result of your use of the website and related digital services. Such information helps us ensure security, analyze traffic, identify errors, investigate incidents, prevent abuse, improve the stability and performance of the website.
Information contained in logs may include IP address, browser type, operating system, device, internet service provider, date and time of visit, entry and exit pages, information on navigation, user actions on the website, referrer, time spent on pages and other technical data.
Depending on the circumstances, some of this information may be considered personal data within the meaning of applicable legislation.

2.4. Information from Partners and Third Parties
In certain cases, we may receive personal data from our partners, contractors, consultants, service providers, registration agents, banks, payment institutions, compliance providers, as well as other third parties, where this is necessary for the provision of Services, compliance with legislation, performance of reasonable verification procedures, protection of the rights and legitimate interests of the company, or improvement of our activities.
Such sources may include, without limitation:

• public databases, public and commercial registers, sanctions lists, politically exposed persons databases, identity verification databases, compliance sources and similar sources used to assess a person’s status, company structure, the existence of restrictions, risk factors or other circumstances relevant to a specific request;
• banks, payment institutions, registration agents, notaries, lawyers, accountants, corporate secretaries and other counterparties involved in the provision of Services;
• analytical platforms and other technical services, if such tools are actually used on the website or in communication with users;
• other sources with respect to which we have reasonable grounds to believe that the information was collected and provided to us lawfully.

2.5. Anonymized and Aggregated Data
We may use anonymized, aggregated, statistical and other data that does not directly identify a specific user for analysis, reporting, market research, improvement of website interfaces, assessment of website performance, prevention of security threats, improvement of the Services and other lawful business purposes.

3. How We Use Information

We use the information collected depending on the nature of our relationship with you, the specific request, the Service provided, technical necessity, legal obligations and our legitimate interests.

3.1. We use information to review user requests, prepare proposals, provide consultations, organize and support the provision of Services, including assistance with company registration, corporate changes, licensing, immigration procedures, preparation and coordination of documents, as well as support in interaction with banks, payment institutions, registrars, licensing authorities and other counterparties.

3.2. We may use information for client identification, internal verification, risk assessment, compliance with the requirements of counterparties, banks, payment institutions, registration agents, licensing authorities and applicable legislation, as well as for the prevention of fraud, abuse and other unlawful acts.

3.3. We use information to communicate with you, including responding to requests, informing you about the progress of the provision of Services, requesting additional documents and information, sending payment notifications, organizational and service messages, as well as messages regarding changes in documents, terms and policies.

3.4. We may use information to send emails, confirmations, reminders, notifications, service messages, commercial offers, news, analytical and marketing materials, where such processing is permitted under applicable legislation and based on an appropriate legal basis.

3.5. We use information to support the operation of the website, analyze traffic, ensure information security, prevent abuse, identify technical issues, investigate incidents and improve digital infrastructure.

3.6. We use information for internal analytics, improvement of the quality of the Services, assessment of client needs, optimization of business processes, staff training and enhancement of client experience.

3.7. We may use information to protect our rights and legitimate interests, settle claims, resolve disputes, comply with the requirements of competent authorities, as well as comply with applicable legislation.


4. How We Disclose and Transfer Information

We may transfer, disclose or otherwise provide access to personal data to third parties to the extent necessary to achieve the purposes of processing, provide Services, comply with legislation, ensure security and ensure the proper functioning of the business.
Depending on the nature of the transfer, certain recipients may act either as persons processing data on our behalf or as independent recipients or independent controllers within the scope of their own obligations and procedures.

4.1. Service Providers
We may provide information to providers and contractors who help us ensure the functioning of our activities. Such persons may include hosting providers, IT contractors, software providers, cloud services, document storage services, email management platforms, CRM systems, analytical platforms, infrastructure protection services, accounting and administrative services.
Such persons receive access only to the information that is reasonably necessary for the performance of their functions and are required to comply with applicable confidentiality and data security requirements.

4.1.1. Providers Outside the EU/EEA
Some service providers may be located outside the European Union or the European Economic Area. In such cases, international data transfers are carried out subject to applicable legal grounds and reasonable safeguards, as described in more detail in Section 10 of this Policy.

4.2. Banks, Payment Institutions and Other Financial Counterparties
If the nature of the Services involves assistance to a client in opening a bank or payment account, reviewing an application, undergoing verification or interacting with the relevant institution, we may transfer the necessary data to banks, payment institutions, electronic money institutions and other financial counterparties.
Such organizations generally process data as independent recipients or independent controllers in accordance with their own rules, internal procedures and privacy policies.

4.3. Compliance Providers and Verification Services
We may use third-party services, databases and partners for identity verification, reasonable due diligence procedures, sanctions screening, verification of company structure, status of persons, source of funds, as well as other verification procedures, where this is necessary due to the nature of the request, the requirements of counterparties or applicable legislation.

4.4. Public Authorities and Authorized Organizations
We may disclose personal data to public authorities, courts, law enforcement authorities, registrars, licensing authorities, tax authorities, regulators and other authorized organizations, where this is required by law, pursuant to an official request, for the fulfillment of disclosure obligations, protection of rights or compliance with applicable regulations.

4.5. Professional Advisers and Business Partners
Depending on the nature of the Services, we may transfer data to lawyers, auditors, tax advisers, accountants, corporate secretaries, notaries, registration agents, immigration advisers and other professional participants, where this is necessary for the provision of Services on your instructions, in your interests or for the proper organization of the service provision process.

4.6. Corporate Changes
In the event of business restructuring, sale of assets, merger, acquisition, transfer of part of the business, change in corporate structure or another similar event, personal data may be disclosed to potential or actual acquirers, advisers and other involved persons, subject to confidentiality and reasonable safeguards.

5. How We Protect Information

We understand the importance of keeping personal data secure and intact, as unauthorized access, loss, alteration, destruction or disclosure of information may cause harm to data subjects, our clients, partners and the company itself.
For this reason, we implement reasonable physical, technical, administrative and organizational security measures aimed at protecting personal data against accidental loss, unauthorized access, unlawful disclosure, alteration, destruction, compromise, leakage or other unlawful handling.
Such measures may include access controls, use of secure data transmission channels, encryption, authorization controls, internal access policies, regular review of access rights, use of secure infrastructure, backup procedures, technical monitoring, incident response measures, contractual obligations with providers and employee training on confidentiality and data security matters.
Despite the measures taken, no method of data transmission over the internet and no data storage system can guarantee absolute security. The user should also take reasonable precautions, including verifying the authenticity of the website, protecting their devices, using strong passwords and exercising caution when transmitting documents and data.
If you become aware of a possible compromise of your data, suspicious activity or any other security-related issue, please notify us immediately at info@finextwin.com.


6. Retention of Personal Data

We retain personal data only for the period necessary to achieve the purposes for which such data was collected, unless a longer retention period is required or permitted by applicable legislation, contractual obligations or the requirements of counterparties, as well as accounting, tax, compliance or other mandatory rules.
The retention period may vary depending on the category of data, the nature of our relationship with you, the status of the Services provided, the source of the information and the legal obligations applicable to the particular situation.
In particular:

• data related to user requests, correspondence and the initial assessment of a potential project may be retained for the period reasonably necessary to respond to the request, continue business communication, prepare a proposal and protect the legitimate interests of the company;
• contractual, accounting, payment and administrative documents may be retained for the period established by applicable legislation, as well as for an additional period reasonably necessary to protect the company’s rights and resolve potential disputes;
• data obtained in connection with client identification, internal verification, compliance procedures and interaction with banks, payment institutions, registrars, licensing authorities and other counterparties may be retained for the period required by applicable legislation, the requirements of the relevant institutions, contractual obligations or internal control procedures;
• contact details used for marketing and informational communications may be retained until consent is withdrawn, marketing communications are opted out of, the relevant activity is terminated, or until the expiry of the period during which we have a valid legal basis for such processing;
• technical information, logs, cookies and analytical data may be retained for the period necessary to ensure security, system administration, analysis of website functioning and compliance with reasonable internal retention periods.

Upon expiry of the applicable retention period, personal data is deleted, destroyed, anonymized or converted into a form that does not permit identification of the data subject, unless further retention is required by law.


7. Legal Basis for Processing and Legitimate Interests

Our legal basis for the collection, use, processing and transfer of personal data depends on the context and the specific purpose of the processing.

7.1. Consent
We may process personal data on the basis of your consent in cases where such consent is required or constitutes an appropriate legal basis. This may relate, for example, to the receipt of marketing communications, the use of analytical cookies, as well as other situations where applicable legislation requires prior consent.

7.2. Performance of a Contract and Pre-Contractual Measures
We may process personal data where this is necessary for preparing a proposal, responding to your request prior to entering into a contract, entering into a contract, performing a contract, supporting the provision of Services, issuing invoices, organizing document flow, coordinating actions with counterparties and performing other actions related to contractual relations.

7.3. Legal Obligation
We may process personal data where this is necessary to comply with obligations established by law, regulations, requirements of regulatory authorities, accounting and tax rules, disclosure obligations, applicable compliance obligations and other mandatory requirements.

7.4. Legitimate Interest
We may process personal data where such processing is necessary for the purposes of our legitimate interests, provided that such interests do not override your fundamental rights and freedoms. Such legitimate interests may include ensuring the security of the website and infrastructure, prevention of fraud and abuse, risk management, protection of the rights and interests of the company, internal analytics, improvement of the Services, business administration and reasonable promotion of our Services to the extent permitted by law.

8. Rights of the Data Subject

As a data subject, you have certain rights in relation to your personal data to the extent provided by applicable legislation, including the GDPR.

8.1. Right of Access
You have the right to request confirmation as to whether we process your personal data, as well as to obtain access to such data and related information about its processing.

8.2. Right to Rectification
You have the right to request the correction of inaccurate personal data and the completion of incomplete data, where applicable.

8.3. Right to Erasure
You have the right to request the deletion of your personal data in cases provided by law, including where the data is no longer necessary for the purposes of processing, consent has been withdrawn and there are no other legal grounds for processing, or where the data has been processed unlawfully.

8.4. Right to Restriction of Processing
You have the right to request restriction of the processing of your data in cases established by law, for example for the period of verification of the accuracy of the data or the lawfulness of the processing.

8.5. Right to Data Portability
Where processing is based on consent or a contract and is carried out by automated means, you may have the right to receive the data you have provided in a structured, commonly used and machine-readable format, as well as to transmit it to another controller where technically feasible.

8.6. Right to Object
You have the right to object to the processing of your data where such processing is based on our legitimate interest, as well as to object to processing for direct marketing purposes.

8.7. Right to Withdraw Consent
Where processing is based on consent, you have the right to withdraw such consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before such withdrawal.

8.8. Right to Lodge a Complaint
You have the right to lodge a complaint with the competent data protection authority at your place of residence, work or the place of the alleged infringement if you believe that your rights have been violated.
To exercise the above rights, you may contact us at info@finextwin.com. We may request additional information necessary to confirm the identity of the applicant and may refuse to comply with a request in whole or in part in cases provided by applicable legislation.


9. Automated Processing and Decision-Making

We may use automated tools, technical algorithms, databases and other means of automated processing for security purposes, internal analysis, risk assessment, detection of fraud, suspicious activity and other circumstances relevant to the provision of Services and protection of the legitimate interests of the company.
At the same time, we do not rely exclusively on fully automated decisions without human involvement in cases where such decisions may produce legal effects concerning the data subject or otherwise significantly affect their rights and freedoms, except where expressly permitted by applicable legislation.


10. International Data Transfers

As Finextwin LLC provides international consulting, corporate, administrative and support services, and may interact with counterparties, service providers, registrars, banks, payment institutions, licensing authorities and other persons located in different jurisdictions, your personal data may be transferred outside your country of residence, as well as outside the European Union and the European Economic Area.
Such international transfer may take place where this is necessary:

• for reviewing your request and preparing a proposal;
• for providing the Services ordered;
• for preparing and coordinating documents;
• for interacting with counterparties chosen by you or objectively necessary for the provision of the Service;
• for complying with applicable legislation;
• for ensuring the operation of the service providers and technical infrastructure used by us.
• Where personal data is transferred to jurisdictions where the level of data protection may differ from that in your country, we seek to use appropriate mechanisms and reasonable safeguards, which may include:
• transfer to jurisdictions recognized as providing an adequate level of protection, where applicable;
• the use of contractual data protection mechanisms, including standard contractual clauses, where appropriate;
• assessment of the nature of the transfer and applicable risks;
• internal policies and contractual obligations with data recipients;
• other legally permissible grounds for data transfer, where applicable to the particular situation.

11. Provision of Data and Consequences of Refusal

You are not obliged to provide us with personal data in all cases. However, if certain data is necessary for reviewing a request, preparing a proposal, entering into a contract, preparing documents, undergoing verification, interacting with counterparties or providing a specific Service, failure to provide such data may result in our inability to provide the relevant Service in full or in part, or in our inability to continue work on your request.


12. Marketing Communications

We may send you marketing, informational and analytical materials in cases where this is permitted by applicable legislation and based on an appropriate legal basis, including your consent where such consent is required.
You may opt out of receiving marketing communications at any time by using the relevant link in the email, where available, or by sending a request to info@finextwin.com.
Opting out of marketing communications does not affect the receipt of service, organizational, legal and other messages necessary for contract performance, support of your request, provision of Services or compliance with legislation.


13. Third-Party Websites and External Links

The website may contain links to third-party websites, services and resources, including Finextwin LLC pages on social media, which are not controlled by Finextwin LLC. We are not responsible for the content, security, privacy policy or data processing practices of such third-party websites and services. Before using a third-party resource, we recommend reviewing its own rules and policies.


14. Privacy of Minors

Our website and our Services are not intended for children and minors who have not reached the age allowing them to independently provide valid consent to the processing of personal data under applicable legislation.
We do not knowingly collect or process personal data of children without an appropriate legal basis and, where required, without the consent of a legal representative. If you become aware that a child has provided us with personal data without the appropriate authorization, please notify us immediately by email at info@finextwin.com.


15. Changes to the Policy

We may amend, supplement and update this Privacy and Cookie Policy from time to time in order to reflect changes in legislation, the requirements of regulatory authorities, the composition of the providers we use, the nature of the Services, the operation of the website and the company’s internal processes.
The updated version of the Policy is published on the website and becomes effective from the moment of its publication, unless otherwise expressly stated in the new version. Where required by law or by the nature of the changes, we may additionally notify users by other means.


16. Contact Information

If you have any questions, comments, requests or complaints regarding this Policy, your personal data, the manner of its processing, the use of cookies, the transfer of data to third parties or the exercise of your rights, you may contact us at:
Finextwin LLC
Email: info@finextwin.com
Website: https://finextwin.com