PRIVACY POLICY

Finextwin
Date of last update: 16.01.2025

Preamble
This Privacy Policy (hereinafter referred to as the "Policy") describes the procedures for collecting, using, storing, transferring, and protecting personal data by Finextwin (hereinafter referred to as the "Company," "we," "our," "us").
The Company operates in accordance with applicable legal standards, including the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong and, where applicable, the General Data Protection Regulation (GDPR) of the European Union.
This Policy applies to all users who interact with our website at https://finextwin.com (hereinafter referred to as the "Website") and/or use our products and services.

1. Definitions

1.1. Personal Data - any information relating to an identified or identifiable natural person.
1.2. Data Subject - a natural person to whom the Personal Data relates.
1.3. Data Processing - any operation performed on Personal Data, including collection, storage, use, dissemination, and deletion.
1.4. Data Controller - Finextwin, which determines the purposes and means of processing Personal Data.
1.5. Data Processor - a third party processing Personal Data on behalf of the Data Controller.
1.6. Cookies - small text files stored on a user's device to support the functionality of the Website and analyze user experience.

2. Collection of Personal Data

2.1. Information provided directly by the user:
2.1.1. Full name.
2.1.2. Email address and phone number.
2.1.3. Country of residence.
2.1.4. Identity documents (passport, national ID card, driver’s license).
2.1.5. Financial information (bank account details, payment cards, transaction history).
2.1.6. Company information, including incorporation documents and beneficial ownership data.
2.2. Information collected automatically:
2.2.1. IP address of the device.
2.2.2. Device type, browser, operating system.
2.2.3. Navigation routes and user behavior on the Website.
2.2.4. Cookies.
2.3. Information obtained from third parties:
2.3.1. Payment systems and financial institutions.
2.3.2. Providers of AML/KYC verification services.
2.3.3. Public databases and government registries.

3. Purposes of Processing Personal Data

3.1. Provision of the Company's products and services.
3.2. Conclusion and execution of contracts.
3.3. AML/KYC verification procedures.
3.4. Compliance with legal obligations.
3.5. Conducting marketing and informational communications (subject to user consent).
3.6. Performing analytical and statistical research.
3.7. Ensuring security and fraud prevention.

4. Legal Grounds for Processing

4.1. Consent of the Data Subject.
4.2. Necessity for the performance of a contract.
4.3. Compliance with legal obligations.
4.4. Legitimate interests of the Company, provided they do not override the fundamental rights and freedoms of the Data Subject.

5. Transfer and Disclosure of Personal Data

5.1. Personal Data may be transferred to the following categories of third parties:
5.1.1. Hosting and IT service providers.
5.1.2. Financial institutions and payment systems.
5.1.3. AML/KYC verification service providers.
5.1.4. Legal consultants and subcontractors.
5.1.5. Competent governmental authorities, based on legal grounds.
5.2. Transfers are made only under conditions ensuring the confidentiality and security of the Personal Data.

6. International Transfer of Personal Data

6.1. The Company may transfer Personal Data to other countries, including jurisdictions outside the European Economic Area (EEA).
6.2. Personal Data may be transferred only if one of the following grounds is present:
6.2.1. An adequacy decision has been issued for the recipient country.
6.2.2. Standard Contractual Clauses (SCC) have been signed.
6.2.3. Explicit and informed consent of the Data Subject has been obtained.
6.3. Where necessary, the Company implements additional technical and organizational measures to ensure data protection.

7. Retention of Personal Data

7.1. Personal Data is retained for as long as necessary to achieve the purposes of processing or to comply with legal requirements.
7.2. Minimum retention periods:
7.2.1. AML/KYC documents - at least 5 years.
7.2.2. Financial documentation - as required by applicable law.
7.2.3. Marketing data - until consent is withdrawn.
7.3. Upon expiry of retention periods, data will be securely deleted or anonymized.

8. Protection of Personal Data

8.1. The Company applies a comprehensive set of technical and organizational security measures.
8.2. The implemented measures include:
8.2.1. Use of data encryption.
8.2.2. Restricted access to data.
8.2.3. Regular security audits and system updates.

9. Data Subject Rights

9.1. The Data Subject has the right to:
9.1.1. Request access to their Personal Data.
9.1.2. Request the rectification of inaccurate or incomplete Personal Data.
9.1.3. Request the deletion of Personal Data where permitted by law.
9.1.4. Restrict the processing of their Personal Data.
9.1.5. Object to the processing of their Personal Data.
9.1.6. Exercise the right to data portability.
9.1.7. Withdraw previously given consent.
9.1.8. Lodge a complaint with a supervisory authority.

10. Cookie Policy

10.1. We use cookies for the following purposes:
10.1.1. To ensure the functionality of the Website.
10.1.2. To improve the user experience.
10.1.3. To collect analytical data for internal statistical purposes.
10.1.4. To personalize marketing offers.
10.2. Types of cookies we use:
10.2.1. Strictly necessary cookies.
10.2.2. Functional cookies.
10.2.3. Analytical cookies.
10.2.4. Marketing cookies.
10.3. Users can manage their cookie settings through their browser settings.

11. Terms of Service

11.1. Use of the Website and the Company's services is governed by this Policy and the Terms of Service.
11.2. Ordering services via the Website implies the user's consent to the terms of Personal Data processing.
11.3. The Company reserves the right to unilaterally amend the Terms of Service.
11.4. Detailed Terms of Service are available on the Website.

12. Amendments to the Policy

12.1. The Company reserves the right to amend this Policy at any time.
12.2. Amendments take effect upon their publication on the Website.
12.3. In case of material changes, users will be notified via email or through the Website.

13. Contact Information

For exercising your rights or any inquiries regarding the processing of Personal Data, you may contact us at:

• Email: [email protected]
• Phone: +1 814 300 8857
• Address: 367-375 Queen's Road Central, Sheung Wan, Hong Kong