This privacy policy ("Privacy Policy") describes how Villa-Capital , as a data controller, collect, use and disclose personal data, and the steps we take to protect such personal data, provided by you or collected by us either on the website ("Website") or when you use the services or products that we provide or may provide in the future ("Services").

By using Website, our Services or any other related product you signify your acceptance of this Privacy Policy. Please read this Privacy Policy each time before using the Website or the Services and before submitting any information to us. If you do not agree with the terms of this Privacy Policy, do not access or use the Services, the Website or any other aspect of our business.

1. DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

1. identity data, such as, first name, last name and date of birth;
2. contact data, such as, email address, mailing address and phone number;
3. financial data, such as, bank account, payment card details and billing address;
4. transaction data, such as, details about payments to and from you and other details of the Services you have purchased from us;
5. profile data, such as, username, account number or password;
6. technical data, such as, the Internet Protocol (IP) address used to connect your computer to the Internet, your login information (if applicable), browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Website (including date and time), page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouseovers), methods used to browse away from the page and any information of yours related to contact our customer service team;
7. usage data, such as, information you viewed or searched for and information about how you use our Website and Services; and
8. marketing and communications data, such as, your preferences in receiving marketing from us and our third parties and your communication responses.
9. information from social media networks. If you log in to our Services using your social media account (for example, Facebook, LinkedIn or Google) we will receive relevant information that is necessary to enable our Services and authenticate you. The social media network will provide us with access to certain information that you have provided to them, including your name, profile image and e-mail address. We use such information, together with any other information you directly provide to us when registering or using our Services, to create your account and to communicate with you about the information, products and services that you request from us. You may also be able to specifically request that we have access to the contacts in your social media account so that you can send a referral link to your family and friends. We will use, disclose and store all of this information in accordance with this privacy policy.

We also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic or biometric data).

2. METHODS OF DATA COLLECTION

We use different methods to collect data from and about you including through:

1. direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email, skype and other messenger or otherwise. This includes personal data you provide when you apply for our Services, create an account on our Website, subscribe to our Service or publications, request marketing to be sent to you, enter a competition, promotion or survey, or give us some feedback, including report a problem with our Website;
2. automated technologies or interactions. As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies.
3. third parties or publicly available sources. We may receive personal data about you from public domain, third parties (such as, analytics providers, advertising networks, search information providers and providers of technical, payment and delivery services) or other websites we operate or the other services we provide.

Where we need to collect personal data by law, or under the terms of an agreement we have with you and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you, including to provide you with the Services. In this case, we may have to cancel the Services you have with us but we will notify you if this is the case at the time.

3. USE OF YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

1. where we need to perform the agreement, we are about to enter into or have entered into with you;
2. where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests;
3. where we need to comply with a legal or regulatory obligation.

Legitimate interest means the interest of our business in conducting and managing our business to enable us to provide you with the best Services and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate. Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.

Purpose or Activity	Type of data	Lawful basis for processing including basis of legitimate interest
To register you as our client and decide whether and on what terms to provide the Services	Identity, Contact and Financial	Performance of an agreement with you
To process and deliver the Services including, to (a) provide customer support and communicate with you, (b) manage payments and fees and verify transactions, (c) collect and recover fees owed to us, and (d) resolve disputes and enforce agreements entered between us	Identity, Contact, Financial, Transaction, Marketing and Communications	Performance of an agreement with you;
Necessary for our legitimate interests	To prevent and investigate prohibited or illegal activities or fraud, including, prevent money laundering and terrorist financing	Identity, Contact, Financial, Transaction
Performance of an agreement with you;	Necessary for our legitimate interests	To manage our relationship with you, including: (a) notifying you about changes to our Services, Website, general terms or this Privacy Policy and (b) asking you to leave a review or take a survey
Identity, Contact, Profile, Marketing and Communications	Performance of an agreement with you;	Necessary to comply with a legal obligation;
Necessary for our legitimate interests (to keep our records updated and to study how you use our Services)	To enable you to partake in a competition or complete a survey	Identity, Contact, Profile, Usage, Marketing and Communications
Performance of an agreement with you;	Necessary for our legitimate interests (to study how you use our Services, to develop them and grow our business)	To administer, customize, update, maintain, protect and improve the Website and the Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Identity, Contact, Technical and Usage	Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation);	Necessary to comply with a legal obligation
To deliver relevant Website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you	Identity, Contact, Profile, Technical, Usage, Marketing and Communications	Necessary for our legitimate interests (to study how you use our Services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Website, Services, marketing, customer relationships and experiences	Technical and Usage	Necessary for our legitimate interests (to define types of clients for our Services, to keep our Website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about Services that may be of interest to you	Identity, Contact, Technical and Usage, Profile	Necessary for our legitimate interests (to develop our Services and grow our business)

We may use your identity, contact, profile, technical and usage data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which Services and offers may be relevant for you (we call this marketing). You may receive marketing communications from us if you have requested information from us or purchased Services from us and, in each case, you have not opted out of receiving that marketing.

You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contact us at any time.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

4. COOKIES AND SIMILAR TECHNOLOGIES

Like most Internet sites, our Website may use cookies and similar technologies to enhance your user experience and provide customization and useful features to our Website and Services. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this Website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookie Policy.

5. DISCLOSURE OF YOUR PERSONAL DATA

Except as outlined in this Privacy Policy, your personal data will never be sold or disclosed with other companies or organizations for commercial purposes or otherwise.

We reserve the right at all times to disclose any personal data that we have collected when: (a) permitted or required by law; or, (b) trying to protect against, prevent, investigate actual or potential fraud, security issues, technical issues, unauthorized transactions or other violations; or (c) trying to enforce the applicable terms of service or other agreements; or (d) protecting against violations to the rights, property or safety of us, our users or the public as required or permitted by applicable laws; or (e) you have given your consent to do so. Finally, we may transfer personal data to a successor entity in connection with a corporate merger, consolidation, partial or total sale of assets, bankruptcy, or other corporate change.

We may disclose your personal data to our contractors (who may be located outside of the European Economic Area ("EEA")) to process it for us, for the purposes of processing transactions, collecting fees, identifying you, but also for improving your user experience, performing business support functions or other related tasks, based on our instructions and in compliance with the Privacy Policy and any other applicable confidentiality and security requirements. In addition, transfers to our contractors are covered by the service agreements with such contractors.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

1. we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
2. where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries;
3. where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

6. DATA SECURITY

We adhere to the generally accepted industry standards to protect your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Only our authorized employees, agents and contractors (who have agreed to keep personal data secure and confidential) have access to the personal data on a need to know basis.

We store and process data, including personal data, in the EEA and possibly in other countries through third parties that we use to operate and manage the Services. When you access or use our Websites or the Services, or otherwise provide personal data to us, you are consenting, on behalf of you and your authorized agents, (and representing that you have the authority to provide such consent) to the processing and transfer of personal data in and to the other countries which may have different privacy laws from your or their country of residence. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy.

Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password, which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

You agree and acknowledge that the Internet may be subject to breaches of security and that the submission of data over the Internet may not be secure. We strive to use acceptable means to protect any personal data you share with us, however we cannot guarantee its absolute security.

7. DATA RETENTION

We will retain your personal data only for so long as it is required for the purposes for which it was collected. This period may extend beyond the end of your relationship with us, but only for so long as is reasonably necessary for us to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations (e.g. taxation purposes), resolve disputes and enforce our agreements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

When your personal data is no longer required, we will destroy, delete or convert it into an anonymous form.

8. THIRD-PARTY LINKS

The privacy practices set forth in this Privacy Policy apply to the Website and Services only. If you link to other web sites (including sites that offer or use the Services or are promoted by us) or use the services of other service providers, please review the privacy policies posted at those web sites or by the relevant service providers.

9. AEG LIMITATIONS

We do not allow use of our Services and the Website by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

10. YOUR RIGTHS

Under certain circumstances, you have following rights under data protection laws in relation to your personal data:

1. right to request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it;
2. right to request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
3. right to request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
4. right to object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
5. right to request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
6. right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform an agreement with you; and
7. right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain Services to you. We will advise you if this is the case at the time you withdraw your consent.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

11. CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy unilaterally and without prior notice, but any changes will be posted on the Website. If we make changes that materially alter your privacy rights, we will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should stop using our Services, the Website or any other aspect of our business. Your continued use of the Website or our Services constitutes your agreement to all such changes.

This version was last updated on 30.08.2023 and historic versions can be obtained by contacting us.

12. CONTACT AND COMPLAINTS

For further information regarding the Privacy Policy and related practices or in case of any suspected infringement of your privacy, please contact us at admin@villa-capital.ltd or by post: Villa-Capital Holding OÜ , address Rotermanni tn 18, 10111, Tallinn, Estonia.

If you reside in the EEA, we will be the controller of your personal data provided to, or collected by, or processed in connection with our Services. You have the right to make a complaint at any time to the Estonian Data Protection Inspectorate (address 19 V ike-Ameerika St., 10129 Tallinn, Estonia, e-mail address admin@villa-capital.ltd, phone +44 7908 298814. We would, however, appreciate the change to deal with your concerns before you approach the Data Protection Inspectorate, so please contact us in the first instance.