Privacy policy

  1. Introduction
    1. This Privacy policy (“POLICY”) applies to the website ( or connected mobile applications (for instance, relevant iOS, Android and Microsoft apps) or related services (“WEBSITE”).
    2. The WEBSITE is a site operated by Pinceau B.V., legal entity incorporated and existing in accordance with the legislation of Netherlands, acting under the name Genezix BV, registered at the Chamber of Commerce with the number 20064966 (“we”, “us”, “our”, “Company”). We are registered at Wissinkweg 27, 8106PG Mariёnheem, Netherlands.
    3. This POLICY determines the manner in which we process personal data (information) collected from users of the WEBSITE (“user”, “you” or “your”).
    4. Personal data in this POLICY means information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    5. Processing of personal data means operation or set of operations, which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    6. This POLICY constitutes an integral part of Terms of use of the WEBSITE (which may be amended from time to time) published at WEBSITE (“TERMS”).
    7. This POLICY does not apply to services which can be offered on other sites (apps, portals, websites) not operated by the Company.
    8. We have specialized security team who constantly make every effort to prevent any unauthorized access and use of personal data.
    9. Your personal data are stored on secure servers in accordance with the applicable law.
  2. Legal overview
    1. User is entitled to withdraw his or her consent at any time; however, in certain cases it may prevent them from participating or engaging in certain WEBSITE related activities. Such withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
    2. By accepting this POLICY, you agree to being contacted by us or by our associates or third parties with marketing communications related to this WEBSITE regarding various offerings by way of e-mail or SMS or push-notifications (other forms of written communication), any of which you may unsubscribe from at any time by contacting us.
    3. Before permitting you to use the WEBSITE and if so required by applicable law, we may require you to provide additional information so that we can verify your identity or address. We may also obtain information about you from third parties such as identity verification services.
    4. We shall not be required to accept you as a counter-party, including acceptance as a user, and we may be unable to accept you as a client or investor until all Know-Your-Client and Anti-Money-Laundry documentation we require is duly executed and received, if required under applicable laws, and we reserve the right to reject your payments of any nature (donations, investments, payments, etc.) until it has received all necessary documentation, properly completed and duly executed.
    5. HEREBY you irrevocably declare:
      1. that you have read, understood, found satisfactory and fully accepted this POLICY and the TERMS;
      2. that you confirm that your affirmative consent for processing of personal data is given freely, clearly, specifically and unambiguously;
      3. that you consider TERMS and risk warnings and risk disclosures provided in the WEBSITE in any form as an integral part of this POLICY.
  3. Privacy notice
    1. As a general rule, we may collect only what we need and will not share your personal data with any third parties, unless otherwise directly indicated in this POLICY or the TERMS.
    2. We can collect the following data and information sent to us by your computer, mobile phone, or other access device:
      1. information you have provided to us through running the WEBSITE or mobile app relating to a directly or indirectly determined or determinable user (including, but not limited to personal data, such as your name, address, telephone number, email address details);
      2. information provided by other companies who have obtained your permission to share information about you to third parties (including personal data);
      3. information about your interaction with adverts and services such as registration, comments;
      4. information we collect (or may collect) using cookies;
      5. your IP-address;
      6. e-mails or other messages sent by users within WEBSITE or the Company’s platform;
      7. information regarding location of the device when you access and use the WEBSITE;
      8. device information including, but not limited to, identifier, name, and type, operating system, other technical information about users means of accessing the WEBSITE;
      9. other data including but not limited to: personal pages, gender, age and mobile number, billing information (invoice name, invoice number, payment card validity period, invoice address).
    3. We may request you to provide information that we, in our sole discretion, considers as required under applicable laws, regulations and (or) policies, and you should provide such information if you intend to continue use of the WEBSITE and (or) receiving new services or possibilities within the WEBSITE (i.e. in case further use of the WEBSITE or designed use of the WEBSITE is not possible in absence of such information).
    4. We may collect and use data and information for the following purposes:
      1. to provide our services;
      2. to improve Company’s services;
      3. to promote Company’s services (if needed further);
      4. for contacting the user;
      5. for interaction with external networks and platforms;
      6. for registration and authentication;
      7. for handling payments;
      8. for infrastructure monitoring;
      9. for managing contacts and sending messages;
      10. for analytics;
      11. to protect the WEBSITE and users;
      12. for interaction with support and feedback platforms;
      13. for managing support and contact requests;
      14. for user database management;
      15. to run, maintain and operate the WEBSITE (including for provision of services);
      16. to run promotion, contest, survey or other WEBSITE features;
      17. to comply with applicable laws or by-laws;
      18. to send users information they agreed (or have requested) to receive about topics we consider as interesting for them;
      19. to send users a service-related announcement (these communications are not promotional in nature).
    5. If we intend to process your personal data subsequently for a purpose other than stated in clause 3.4, we will prior provide you with the relevant information on such processing including the right to withdraw your consent to personal data processing for such purpose.
    6. Your personal data will be adequate, relevant and limited to what necessary in relation to the purposes for which they are processed as stated in clause 3.4.
    7. Information is collected and processed with or without automatic tools.
    8. We may process only personal data that we need and will not disclose (share, sell, trade, or rent) your personal data with any third parties, unless otherwise directly specified in this POLICY.
    9. The personal data may be freely provided by the user, or, in case of usage data, collected automatically when using the WEBSITE.
    10. We may share aggregated information not linked to any personal data regarding visitors and users with business partners, trusted affiliates and advertisers.
    11. We may disclose the user’s personal data when we believe that such disclosure is necessary:
      1. to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by us, whether or not a response is required by applicable law;
      2. for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of the WEBSITE or the related services;
      3. to reveal personal data upon request of public authorities;
      4. to protect our rights; or
      5. to protect the safety of members of the public and users of the service and (or) the WEBSITE.
    12. By giving us affirmative consent for personal data processing you provide us with the right to share your personal data (in the scope limited to the necessary to disclose) with:
      1. our banking partners;
      2. other users – only for the purposes and to the extent necessary for normal Company’s services use or function (including for making ratings, etc.) related to the commercial use of Company’s services;
      3. third parties, including its own subsidiaries and affiliated companies, which we may engage from time to time to preserve, analyze or otherwise store or manipulate data received[1];
      4. entities we plan to merge with or be acquired by;
      5. third party identification services providers for fraud prevention purposes;
      6. law enforcement, government officials, or other third parties when we believe in good faith that the disclosure of personal data is necessary to prevent physical harm or financial loss, to report suspected illegal activity or to investigate violations of TERMS; or
      7. other third parties only with your prior consent or direction to do so.
    13. We reserve the right to transfer personal data to a successor that has acquired such rights in result of sale or substantial sale of all of our assets to that successor.
  4. Maintenance of personal data
    1. We process personal data lawfully, fairly and in a transparent manner.
    2. We will collect personal data from users only if they voluntarily submit such information to us. By submitting your personal data, you agree to this transfer (including cross-border transfer), storing, or processing in accordance with the applicable law.
    3. We and third parties engaged by us to store and process your personal data on the servers in the EU and elsewhere in the world, where its respective facilities or its service providers are located. We or such third parties may be located in countries where the laws on processing personal data may be less strict than in your country. We ensure that your personal data will be stored or processed only within countries that provides an adequate protection of the rights of subject of personal data.
    4. While we cannot guarantee that loss, misuse or alteration to data will not occur, we make every effort to prevent such occurrences.
    5. Any other particularly sensitive information (such as credit card numbers collected for commercial transactions) is encrypted prior to transmission to us by user.
    6. The data is kept for the time necessary to provide the services requested by the user, or stated by the purposes outlined in this document, and the user can always request us to suspend or remove the data.
    7. We confirm that processing of personal data is carried out in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage with appropriate technical and organizational measures that are strictly necessary for processing of personal data.
    8. In some cases, the data (including personal data of the users) may be accessible to certain types of persons in charge, involved with the operation of the WEBSITE (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT-companies, communications agencies) appointed by us.
    9. We may be sometimes required to compare the personal data provided by the user to third party databases in order to verify its accuracy and confirm user’s identity to comply with relevant regulations.
    10. Users are entitled, at any time, to know whether their personal data has been stored and can consult with us to learn about their contents, origin and other information regarding its processing.
  5. Retention period
    1. We retain personal data for no longer than is necessary to fulfil the purposes for which the information was originally collected or as necessary to comply with our legal obligations, maintain accurate financial and other records, resolve disputes, and enforce our agreements.
    2. The processed personal data shall be destroyed, anonymized or depersonalized upon the achievement of the processing purposes or if it is no longer necessary to achieve them, unless otherwise provided by applicable law. If all these are not possible (e.g., when your data has been stored in backup archives), then Company will securely store your personal data and isolate it from any further processing until deletion is possible.
    3. Users are entitled, at any time, to know whether their personal data has been stored and can consult with us to learn about their contents, origin and other information regarding its processing.
  6. Changes in the Privacy policy
    1. From time to time we may make changes to this POLICY. If we make changes, we will post them on the WEBSITE (main page) to notify the users thereof.
    2. A user shall acknowledge and comply with all changes to the POLICY when using the WEBSITE after those changes posted.
    3. Further use of the WEBSITE (including by simply accessing and reviewing it) means that you accept and agree with any alterations made to this POLICY.
    4. You acknowledge and agree that it is your responsibility to review the POLICY periodically and become aware of modifications.
  7. Your rights
    1. You have the right to obtain confirmation as to whether or not your personal data is being processed, and, where that is the case, access to the personal data and the following information:
      1. the purposes of the processing;
      2. the categories of personal data concerned;
      3. the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
      4. where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
      5. the existence of the right to request from us rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
      6. the right to lodge a complaint with a supervisory authority;
      7. where the personal data are not collected from the data subject, any available information as to their source;
      8. the existence of automated decision-making.
    2. You have the right to obtain without undue delay the rectification of your inaccurate personal data.
    3. Taking into account the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
    4. You have the right to obtain from us the erasure of your personal data without a delay where on of the following grounds applies:
      1. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
      2. you withdraw your consent on which the processing is based and there is no other legal ground for processing;
      3. you object to the processing pursuant to clause 7.7 and there no overriding legitimate grounds for the processing, or you objects to the processing pursuant to clause 7.8;
      4. the personal data have been unlawfully processed;
      5. the personal data have to be erased for compliance with a legal obligation stated in the applicable law.
    5. You have the right to obtain restriction of processing where one of the following applies:
      1. the accuracy of the personal data is contested by you for a period enabling us to verify the accuracy of the personal data;
      2. the processing is unlawful and you oppose the erasure of the personal data and requests the restriction of their use instead;
      3. we no longer needs the personal data for the purposes of the processing, but they are required by you for the establishment, exercise or defense of legal claims;
      4. you have objected to processing pursuant to clause 7.7 pending verification whether our legitimate grounds override yours.
    6. You have the right to receive your personal data provided to us in a structured, commonly used and machine-readable format and have the right to transmit those personal data to another entity.
    7. You have the right to object at any time to processing your personal data when such processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority and for the purposes of legitimate interest pursued by us or a third party, except where such interests are overridden by such your interests or fundamental rights and freedoms which require protection of personal data.
    8. Where personal data are processed for direct marketing purposes, you have the right to object at any time to processing your personal data for such marketing.
    9. You have the right to lodge a complaint before relevant data protection authority or supervisory authority.
  8. Your responsibilities
    1. You are responsible for the security of the login information, such as usernames and passwords, which give you access to your private information maintained by us.
    2. Users are responsible for any third party personal data obtained, published or shared through the WEBSITE and confirm that they have the third party’s consent to provide the personal data to us. Hereby you indemnify us against any losses and (or) damages which may occur in case of your default in having respective consent.
  9. Children’s privacy
    1. If you are under 18 years old, you cannot use the WEBSITE and Company’s services and products.
    2. We do not knowingly solicit or process information from anyone under 18 years old.
    3. If we become aware that a person under the age of 18 has provided us with personal information, we will delete it immediately. We will not accept any responsibility in part of process and protection of respective personal data.
  10. Contact details
    1. Any questions, comments, requests or complaints concerning this POLICY and other materials from the WEBSITE shall be directed to our e-mail

¹ In all such cases, respective addresses will be required to treat all such data with the same degree of care as we and they will be prohibited from disclosing such data to any other person or party, except as otherwise provided for in this Policy.