PRIVACY POLICY
ESKETIT PLATFORM LIMITED (“we”, “our”, “us”, or “ESKETIT PLATFORM LIMITED”) respects the privacy of its users, visitors of the website and other individuals that interact with us, and is fully committed to protect their personal data and process it in accordance with the applicable data privacy laws. This Privacy Policy explains how ESKETIT PLATFORM LIMITED processes any personal data collected by us or provided to us when you are using the ESKETIT PLATFORM LIMITED, visiting www.esketit.com or otherwise.
By using the ESKETIT PLATFORM LIMITED and accessing this website or otherwise interacting with us, you agree to the terms set out in this Privacy Policy, Cookie Policy and other terms and policies posted on our website. If you do not agree to this Privacy Policy, you must leave this website and discontinue all use of any of our Services. Services.
1. INTRODUCTION
1.1. ESKETIT PLATFORM LIMITED is a company incorporated in the Republic of Ireland with registration number:673443, legal address: 77 LOWER CAMDEN STREET, DUBLIN,DUBLIN 2, D02 XE80,IRELAND, and it manages an internet website with the domain address www.esketit.com (the “Platform”) where natural persons and legal entities as investors may buy and sell claims against borrowers, that arise from loan agreements entered between lenders - ESKETIT PLATFORM LIMITED partners - and borrowers(“Services”).
1.2. ESKETIT PLATFORM LIMITED shall process Personal Data in accordance with the applicable data protection laws in respect of Data Subjects within the European Economic Area (“EEA”). ESKETIT PLATFORM LIMITED shall comply with the requirements of European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”).
1.3. The terms “Personal Data”, “Data Subject”, “Controller”, “Processor” and “Supervisory Authority” as used in this Privacy Policy shall have the same meanings as given in the GDPR.
2. INFORMATION WE COLLECT
2.1. ESKETIT PLATFORM LIMITED collects information from users, website visitors and other persons that interact with us. Some of this information constitutes Personal Data and in respect of such data ESKETIT PLATFORM LIMITED is the Controller.
Information you provide to ESKETIT PLATFORM LIMITED
2.2. When you create your User Profile on www.esketit.com you are required to provide us with the following information:
2.2.1. full name, date of birth, personal ID number and other data from your ID document;
2.2.2. e-mail address;
2.2.3. password;
2.2.4. payment information;
2.2.5. tax certificate, tax identification number;
2.2.6. phone number;
2.2.7. address;
2.2.8. due diligence data, such as origin of funds, status of politically exposed person, beneficiary of profits, other information obtained during due diligence process.
2.3. When you as a visitor of the website reach out to us using the contact information or contact form available on our website you provide us with:
2.3.1. name;
2.3.2. e-mail address;
2.3.3. phone number;
2.3.4. content of the message.
Information we collect automatically
2.4. When you are using ESKETIT PLATFORM LIMITED, we automatically collect the following information about your activity there: invested funds, investment criteria, transactions, incoming payments, claimed disbursements of money, information regarding the concluded assignment agreements, net annual return, selected currency, available funds.
2.5. When you are visiting www.esketit.com we automatically collect and process the following information that may contain your Personal Data: your device and browser information, pages you access, language preferences, device identifiers, operating system you are using, your location, mobile network information, standard web log data, and other information collected from cookies and similar technology we use on our website. Learn more about how we use cookies on our website by reading our Cookie Policy.
3. PURPOSES AND GROUNDS FOR PROCESSING PERSONAL DATA
3.1. ESKETIT PLATFORM LIMITED processes the collected information for the following purposes:
3.1.1. To conclude an agreement with you and to provide our Services to you;
3.1.2. To register you as a user and create your User Profile on ESKETIT PLATFORM LIMITED;
3.1.3. To verify your identity and to perform due diligence;
3.1.4. To communicate with user of ESKETIT PLATFORM LIMITED;
3.1.5. To communicate with potential users, partners and other persons interested in our Services;
3.1.6. To analyse and measure the use of ESKETIT PLATFORM LIMITED and our website in order to improve the quality of the Services and technical performance of ESKETIT PLATFORM LIMITED;
3.1.7. To analyse our commercial activities, statistical measurements, market research and evaluate the quality of our operations, services and products;
3.1.8. To develop and offer new services to our users;
3.1.9. To inform you about our Services;
3.1.10. To comply with applicable statutory obligations in the fields of AML, accounting, tax and other fields;
3.1.11. To protect legal interests of ESKETIT PLATFORM LIMITED, our partners, users and other persons, by means of, for example, enforcing our agreements, settling disputes complying with any applicable law and assisting law enforcement authorities.
3.2. ESKETIT PLATFORM LIMITED can only process your data when we have legal basis to do so. Grounds for processing are different depending on the specific type of data and purposes for processing such data. Note that some data may be processed for number of different purposes and legal grounds at the same time. Here are the legal bases for processing your Personal Data:
Performance of an agreement
When we are processing data for the purpose providing the Services to you the legal basis for such processing is the agreement concluded between ESKETIT PLATFORM LIMITED and its users.
Compliance with legal obligations
There are number of legal requirements that we need to comply with and therefore we process some of your data in order to comply with these requirements, for example, when we carry out due diligence and identify our users.
Legitimate interests
Processing of your Personal Data is necessary for pursuing legitimate interests of the ESKETIT PLATFORM LIMITED or the legitimate interests of third parties, provided those interests are not outweighed by your rights and interests.
Legitimate interests as basis for data processing include conducting our business, growing and improving it, informing existing and potential users about our Services, preventing fraud, ensuring security and solving technical issues on the Platform, complying with our contractual obligations towards our partners, supplies and service providers, enforcing legal claims and others.
Consent
Some Personal Data is processed on the basis of your consent. This is in cases when such information is not explicitly required by us, but you have chosen to provide us with such information. For example, when you decide to subscribe to out newsletter you are providing explicit consent to process you e-mail address. Note that you have the right at any time to withdraw your consent to processing data.
Legal basis of Personal Data processing are:
• Article 6 (1) (a) of the GDPR (your consent);
• Article 6 (1) (b) of the GDPR (performance of contract and taking steps prior to entering into a contract);
• Article 6 (1) (c) of the GDPR (compliance with a legal obligation);
• 6 (1 ) (f) of the GDPR (our legitimate interests to ensure smooth operation of the Website and quality of services, develop our Website and services, protect our property and interests);
• Article 9 (2) (a) of the GDPR (your consent in relation to special categories of personal data);
• Article 9 (2) (g) of the GDPR (reasons of substantial public interest on the basis of law);
• Article 13 (1) of the S.I. No. 336/2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (your consent to receive commercial communication).
4. RETENTION PERIOD
4.1. ESKETIT PLATFORM LIMITED retains Personal Data for as long as the purpose, for which it has been collected, still exists. When there is no purpose anymore ESKETIT PLATFORM LIMITED will cease to process data, unless ESKETIT PLATFORM LIMITED is required by law to store this data for longer.
4.2. Even after the initial purpose for Personal Data processing ceases to exist, e.g. you delete your User Profile and terminate the agreement with ESKETIT PLATFORM LIMITED, we may continue to store certain information as reasonably necessary to comply with our legal obligations, to resolve disputes, if any, to prevent fraud and abuse, to enforce our agreements, and/or to protect our legitimate interests.
5. SHARING PARSONAL DATA WITH THIRD PARTIES
5.1. For ESKETIT PLATFORM LIMITED to be able to provide you with our Services, we work with our cooperation partners that provide us with different kind of services that we require in our ordinary course of business. Therefore, we share your Personal Data with such service providers. They process your Personal Data on behalf of ESKETIT PLATFORM LIMITED.
5.2. We may share your Personal Data with providers of such services as server and hosting services, IT, communication and content delivery services, payment processing services, CRM and customer support software services, accounting services, legal and financial advisors, banks, among others.
5.3. All our service providers are able to demonstrate that they have implemented appropriate measures to ensure that Personal Data is processed in compliance with GDPR and other applicable laws and regulations.
5.4. We also share your Personal Data with our group companies, which ensure the same level of data protection and security as we do.
5.5. In some situations, we might have a legal obligation to share your information with public authorities or other third parties. We might share your information with third parties when it is in our legitimate interest, e.g. in case of any merger, sale of assets, transfer of undertaking, or otherwise restructuring the provision of the Service.
5.6. We always share only very limited amount of Personal Data with our service providers and other third parties and only when there is a legal basis to do so.
5.7. ESKETIT PLATFORM LIMITED and our group companies process your Personal data only within the EEA.
5.8. Personal Data may be transferred to our service providers and other recipients that are located outside of EEA. However, we transfer data only to such recipients outside the EEA that are located in a territory that has been acknowledged by the European Commission as ensuring adequate level of protection or otherwise are able to provide appropriate safeguards, and always provided that enforceable rights and effective legal remedies are available for Data Subjects.
6. YOUR RIGHTS
6.1. Individuals located in EEA have certain statutory rights in relation to their Personal Data. ESKETIT PLATFORM LIMITED respects these rights in respect of your Personal Data and once we receive your request to exercise any of these rights, we will review it and provide a response without undue delay.
6.2. Subject to any exemptions provided by law, you may have the right to request access to your Personal Data, to seek to update, delete or correct this data, to restrict or object to processing of your data, as well as right to portability of your Personal Data.
6.3. You can use these rights by reaching out to ESKETIT PLATFORM LIMITED by sending a request by e-mail [email protected] or by mail to our group company SIA "Esketit", registration number 40203276948, legal and correspondence address Strelnieku iela 8- 59, Riga, Latvia, LV-1010.
6.4. Besides, if you believe that we have unlawfully processed your Personal Data, you have the right to submit a complaint to us, to a respective data protection Supervisory Authority in your country or to Data Protection Commission (the Republic of Ireland), address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, phone: +353 (0)761 104 800.
7. PERSONAL DATA SECURITY
7.1. We have implemented necessary administrative, technical, and organisational measures that are reasonable and appropriate considering the potential risks and the nature of processing, to protect any information and Personal Data in our possession against any loss, theft, unauthorized use, disclosure, modification or any other unlawful use of it.
7.2. All of our employees and employees of our group companies that are involved in the processing of Personal Data have committed themselves to confidentiality obligations and shall not access or otherwise process Personal Data without authorization and if it's not necessary for the purposes such data was obtained in the first place.
7.3. Please be aware that, unfortunately, no electronic data transmission or storage system is completely secure, therefore we cannot guarantee absolute security of information. Nevertheless, we have implemented necessary measures for minimizing any such risks, and at the same time ask you to take care of the Personal Data processed via the Platform, set strong passwords for User Profile, limit access to devices and browser by signing out after the end of each session, and as possible avoid providing ESKETIT PLATFORM LIMITED with any sensitive information, that is not explicitly required by us.
7.4. In the event a Personal Data breach occurs, we will notify Data Subjects in compliance with the obligations set out in applicable laws and will provide reasonable assistance regarding the investigation of Personal Data breaches and the notification to the Supervisory Authorities.
8. PRIVACY POLICY CHANGES
8.1. We may occasionally amend this Privacy Policy and the amendments to this Privacy Policy shall enter into force and shall be applied from the moment they have been uploaded to our website. Therefore, we encourage you to check out website from time to time.
8.2. By continuing to use our Services or the Platform and website, or otherwise providing Personal Data to us, after the amendments to this policy have been implemented, you agree to the updated terms of Privacy Policy.
ESKETIT PLATFORM LIMITED (“we”, “our”, “us”, or “ESKETIT PLATFORM LIMITED”) respects the privacy of its users, visitors of the website and other individuals that interact with us, and is fully committed to protect their personal data and process it in accordance with the applicable data privacy laws. This Privacy Policy explains how ESKETIT PLATFORM LIMITED processes any personal data collected by us or provided to us when you are using the ESKETIT PLATFORM LIMITED, visiting www.esketit.com or otherwise.
By using the ESKETIT PLATFORM LIMITED and accessing this website or otherwise interacting with us, you agree to the terms set out in this Privacy Policy, Cookie Policy and other terms and policies posted on our website. If you do not agree to this Privacy Policy, you must leave this website and discontinue all use of any of our Services. Services.
1. INTRODUCTION
1.1. ESKETIT PLATFORM LIMITED is a company incorporated in the Republic of Ireland with registration number:673443, legal address: 77 LOWER CAMDEN STREET, DUBLIN,DUBLIN 2, D02 XE80,IRELAND, and it manages an internet website with the domain address www.esketit.com (the “Platform”) where natural persons and legal entities as investors may buy and sell claims against borrowers, that arise from loan agreements entered between lenders - ESKETIT PLATFORM LIMITED partners - and borrowers(“Services”).
1.2. ESKETIT PLATFORM LIMITED shall process Personal Data in accordance with the applicable data protection laws in respect of Data Subjects within the European Economic Area (“EEA”). ESKETIT PLATFORM LIMITED shall comply with the requirements of European Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regards to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (“GDPR”).
1.3. The terms “Personal Data”, “Data Subject”, “Controller”, “Processor” and “Supervisory Authority” as used in this Privacy Policy shall have the same meanings as given in the GDPR.
2. INFORMATION WE COLLECT
2.1. ESKETIT PLATFORM LIMITED collects information from users, website visitors and other persons that interact with us. Some of this information constitutes Personal Data and in respect of such data ESKETIT PLATFORM LIMITED is the Controller.
Information you provide to ESKETIT PLATFORM LIMITED
2.2. When you create your User Profile on www.esketit.com you are required to provide us with the following information:
2.2.1. full name, date of birth, personal ID number and other data from your ID document;
2.2.2. e-mail address;
2.2.3. password;
2.2.4. payment information;
2.2.5. tax certificate, tax identification number;
2.2.6. phone number;
2.2.7. address;
2.2.8. due diligence data, such as origin of funds, status of politically exposed person, beneficiary of profits, other information obtained during due diligence process.
2.3. When you as a visitor of the website reach out to us using the contact information or contact form available on our website you provide us with:
2.3.1. name;
2.3.2. e-mail address;
2.3.3. phone number;
2.3.4. content of the message.
Information we collect automatically
2.4. When you are using ESKETIT PLATFORM LIMITED, we automatically collect the following information about your activity there: invested funds, investment criteria, transactions, incoming payments, claimed disbursements of money, information regarding the concluded assignment agreements, net annual return, selected currency, available funds.
2.5. When you are visiting www.esketit.com we automatically collect and process the following information that may contain your Personal Data: your device and browser information, pages you access, language preferences, device identifiers, operating system you are using, your location, mobile network information, standard web log data, and other information collected from cookies and similar technology we use on our website. Learn more about how we use cookies on our website by reading our Cookie Policy.
3. PURPOSES AND GROUNDS FOR PROCESSING PERSONAL DATA
3.1. ESKETIT PLATFORM LIMITED processes the collected information for the following purposes:
3.1.1. To conclude an agreement with you and to provide our Services to you;
3.1.2. To register you as a user and create your User Profile on ESKETIT PLATFORM LIMITED;
3.1.3. To verify your identity and to perform due diligence;
3.1.4. To communicate with user of ESKETIT PLATFORM LIMITED;
3.1.5. To communicate with potential users, partners and other persons interested in our Services;
3.1.6. To analyse and measure the use of ESKETIT PLATFORM LIMITED and our website in order to improve the quality of the Services and technical performance of ESKETIT PLATFORM LIMITED;
3.1.7. To analyse our commercial activities, statistical measurements, market research and evaluate the quality of our operations, services and products;
3.1.8. To develop and offer new services to our users;
3.1.9. To inform you about our Services;
3.1.10. To comply with applicable statutory obligations in the fields of AML, accounting, tax and other fields;
3.1.11. To protect legal interests of ESKETIT PLATFORM LIMITED, our partners, users and other persons, by means of, for example, enforcing our agreements, settling disputes complying with any applicable law and assisting law enforcement authorities.
3.2. ESKETIT PLATFORM LIMITED can only process your data when we have legal basis to do so. Grounds for processing are different depending on the specific type of data and purposes for processing such data. Note that some data may be processed for number of different purposes and legal grounds at the same time. Here are the legal bases for processing your Personal Data:
Performance of an agreement
When we are processing data for the purpose providing the Services to you the legal basis for such processing is the agreement concluded between ESKETIT PLATFORM LIMITED and its users.
Compliance with legal obligations
There are number of legal requirements that we need to comply with and therefore we process some of your data in order to comply with these requirements, for example, when we carry out due diligence and identify our users.
Legitimate interests
Processing of your Personal Data is necessary for pursuing legitimate interests of the ESKETIT PLATFORM LIMITED or the legitimate interests of third parties, provided those interests are not outweighed by your rights and interests.
Legitimate interests as basis for data processing include conducting our business, growing and improving it, informing existing and potential users about our Services, preventing fraud, ensuring security and solving technical issues on the Platform, complying with our contractual obligations towards our partners, supplies and service providers, enforcing legal claims and others.
Consent
Some Personal Data is processed on the basis of your consent. This is in cases when such information is not explicitly required by us, but you have chosen to provide us with such information. For example, when you decide to subscribe to out newsletter you are providing explicit consent to process you e-mail address. Note that you have the right at any time to withdraw your consent to processing data.
Legal basis of Personal Data processing are:
• Article 6 (1) (a) of the GDPR (your consent);
• Article 6 (1) (b) of the GDPR (performance of contract and taking steps prior to entering into a contract);
• Article 6 (1) (c) of the GDPR (compliance with a legal obligation);
• 6 (1 ) (f) of the GDPR (our legitimate interests to ensure smooth operation of the Website and quality of services, develop our Website and services, protect our property and interests);
• Article 9 (2) (a) of the GDPR (your consent in relation to special categories of personal data);
• Article 9 (2) (g) of the GDPR (reasons of substantial public interest on the basis of law);
• Article 13 (1) of the S.I. No. 336/2011 - European Communities (Electronic Communications Networks and Services) (Privacy and Electronic Communications) Regulations 2011 (your consent to receive commercial communication).
4. RETENTION PERIOD
4.1. ESKETIT PLATFORM LIMITED retains Personal Data for as long as the purpose, for which it has been collected, still exists. When there is no purpose anymore ESKETIT PLATFORM LIMITED will cease to process data, unless ESKETIT PLATFORM LIMITED is required by law to store this data for longer.
4.2. Even after the initial purpose for Personal Data processing ceases to exist, e.g. you delete your User Profile and terminate the agreement with ESKETIT PLATFORM LIMITED, we may continue to store certain information as reasonably necessary to comply with our legal obligations, to resolve disputes, if any, to prevent fraud and abuse, to enforce our agreements, and/or to protect our legitimate interests.
5. SHARING PARSONAL DATA WITH THIRD PARTIES
5.1. For ESKETIT PLATFORM LIMITED to be able to provide you with our Services, we work with our cooperation partners that provide us with different kind of services that we require in our ordinary course of business. Therefore, we share your Personal Data with such service providers. They process your Personal Data on behalf of ESKETIT PLATFORM LIMITED.
5.2. We may share your Personal Data with providers of such services as server and hosting services, IT, communication and content delivery services, payment processing services, CRM and customer support software services, accounting services, legal and financial advisors, banks, among others.
5.3. All our service providers are able to demonstrate that they have implemented appropriate measures to ensure that Personal Data is processed in compliance with GDPR and other applicable laws and regulations.
5.4. We also share your Personal Data with our group companies, which ensure the same level of data protection and security as we do.
5.5. In some situations, we might have a legal obligation to share your information with public authorities or other third parties. We might share your information with third parties when it is in our legitimate interest, e.g. in case of any merger, sale of assets, transfer of undertaking, or otherwise restructuring the provision of the Service.
5.6. We always share only very limited amount of Personal Data with our service providers and other third parties and only when there is a legal basis to do so.
5.7. ESKETIT PLATFORM LIMITED and our group companies process your Personal data only within the EEA.
5.8. Personal Data may be transferred to our service providers and other recipients that are located outside of EEA. However, we transfer data only to such recipients outside the EEA that are located in a territory that has been acknowledged by the European Commission as ensuring adequate level of protection or otherwise are able to provide appropriate safeguards, and always provided that enforceable rights and effective legal remedies are available for Data Subjects.
6. YOUR RIGHTS
6.1. Individuals located in EEA have certain statutory rights in relation to their Personal Data. ESKETIT PLATFORM LIMITED respects these rights in respect of your Personal Data and once we receive your request to exercise any of these rights, we will review it and provide a response without undue delay.
6.2. Subject to any exemptions provided by law, you may have the right to request access to your Personal Data, to seek to update, delete or correct this data, to restrict or object to processing of your data, as well as right to portability of your Personal Data.
6.3. You can use these rights by reaching out to ESKETIT PLATFORM LIMITED by sending a request by e-mail [email protected] or by mail to our group company SIA "Esketit", registration number 40203276948, legal and correspondence address Strelnieku iela 8- 59, Riga, Latvia, LV-1010.
6.4. Besides, if you believe that we have unlawfully processed your Personal Data, you have the right to submit a complaint to us, to a respective data protection Supervisory Authority in your country or to Data Protection Commission (the Republic of Ireland), address: 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland, phone: +353 (0)761 104 800.
7. PERSONAL DATA SECURITY
7.1. We have implemented necessary administrative, technical, and organisational measures that are reasonable and appropriate considering the potential risks and the nature of processing, to protect any information and Personal Data in our possession against any loss, theft, unauthorized use, disclosure, modification or any other unlawful use of it.
7.2. All of our employees and employees of our group companies that are involved in the processing of Personal Data have committed themselves to confidentiality obligations and shall not access or otherwise process Personal Data without authorization and if it's not necessary for the purposes such data was obtained in the first place.
7.3. Please be aware that, unfortunately, no electronic data transmission or storage system is completely secure, therefore we cannot guarantee absolute security of information. Nevertheless, we have implemented necessary measures for minimizing any such risks, and at the same time ask you to take care of the Personal Data processed via the Platform, set strong passwords for User Profile, limit access to devices and browser by signing out after the end of each session, and as possible avoid providing ESKETIT PLATFORM LIMITED with any sensitive information, that is not explicitly required by us.
7.4. In the event a Personal Data breach occurs, we will notify Data Subjects in compliance with the obligations set out in applicable laws and will provide reasonable assistance regarding the investigation of Personal Data breaches and the notification to the Supervisory Authorities.
8. PRIVACY POLICY CHANGES
8.1. We may occasionally amend this Privacy Policy and the amendments to this Privacy Policy shall enter into force and shall be applied from the moment they have been uploaded to our website. Therefore, we encourage you to check out website from time to time.
8.2. By continuing to use our Services or the Platform and website, or otherwise providing Personal Data to us, after the amendments to this policy have been implemented, you agree to the updated terms of Privacy Policy.