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Appendix No. 2 to the User Agreement.
 Privacy policy.

1. This Privacy Policy is an integral part of the User Agreement, so before accepting the Privacy Policy, please make sure that you have studied, understood and accepted the entire text of the User Agreement. In case of disagreement with any of the terms of the Privacy Policy and / or User Agreement, please immediately stop using the FINHUB Website.

2. This Privacy Policy is determined including, but not limited to, the conditions and procedure under which each FINHUB Website User accesses and uses the FINHUB Website and the Services provided through the FINHUB Website, as well as the procedure and amount of data collection that FINHUB collects.

3.Personal data is processed by FINHUB in accordance with the legislation of the European Union on the protection of individuals in relation to the processing of personal data. In order to carry out its activities, as well as to counter any illegal actions using our services, FINHUB collects personal data related to visitors to its websites, as described in detail below.

4. Any visitors to the FINHUB website may be subject to data collection.

5. The data storage period, as a rule, is 1 year after the termination of interaction with the data subject, if necessary, data storage may differ no longer than is necessary for the purposes for which personal data is processed.

6. Subject to the conditions and conditions provided by applicable law:

  • You have the right at any time within three months from the receipt of the request to receive:

– Confirmation of whether your personal data is processed or not;

– Information, at least for the purpose of the processing operation, the relevant categories of personal data and recipients or categories of recipients to whom this data is disclosed;

  • You have the right to promptly rectify any inaccurate or incomplete personal data concerning you (right to rectification).

FINHUB may limit the application of your access right and right to rectification if such a restriction may be a necessary measure to provide guarantees – including but not limited to:

  • Prevention, investigation, detection and prosecution of criminal offenses; and
  • Protection of the data subject or the rights and freedoms of others.

To exercise these rights, you can contact FINHUB by e-mail.

7. In addition to the foregoing, you have the right to receive from FINHUB the deletion of your personal data when it is no longer needed in relation to the purposes for which it was collected (the right to delete).

You have the right to receive a processing restriction from FINHUB when:

  • You dispute the accuracy of your personal data;
  • Processing is illegal;
  • FINHUB no longer needs personal data for processing purposes; or

In addition, you have the right to:

  • Object for reasons related to your particular situation where the processing of personal data is illegal;

8. While you are visiting FINHUB, cookies may be sent. These cookies are anonymous and are used to track activity across domains for statistical reasons. Cookies are also used to optimize your visit (e.g. your language). To determine which cookies are used, please consult the FINHUB cookies.

9. In the event that you register, including but not limited to, as an investor, company creator, donor, on the FINHUB website, in this case, we collect and process basic identification data (such as name, contact details, position, description positions and date of birth, gender, ID number, IP address, signature, bank details, etc.), information about your participation in our credit and / or other investment operations (including, in accordance with standard market practice, professional education) . and biographical data) and, if you are an individual beneficiary of our credit and / or other investment products, relevant financial information (for example, regarding credit history, loans issued, guarantees and repayments). We also collect and process reference information about individual beneficiaries (and beneficial owners and other key persons associated with the beneficiaries), used to comply with customer requirements, anti-money laundering or sanctions (for example, information contained in a passport) or driver’s license. We may receive your personal data directly from you (or from a business or organization that you represent or with which you are associated), or from an intermediary involved in lending, other investment operations or consulting activities. If you are a physical beneficiary (or beneficial owner or other key person associated with beneficiary) of our credit and / or other investment products and advisory services, we may also collect some information about you from international sanctions lists and other publicly available sources.

10. We may disclose your personal data:

  • internally, to the relevant FINHUB services
  • the legal entity, organization (if any) with which you are associated, as well as intermediaries and other organizations involved in our operations, in the course of routine communication regarding our lending, other investment activities and consulting services
  • EU institutions (including the European Commission and the European Court of Audit) and government bodies in EU Member States, governing and supervisory bodies, as well as competent regulatory, judicial and tax authorities
  • third-party authorized persons, co-investors of our recipients of credit and / or other investment products and advisory services, which may also be located outside the EU and the European Economic Area.
  • our legal advisers
  • service providers who store and process your personal data on our behalf, subject to strict confidentiality and security conditions

11. We only store your data for as long as necessary for the purposes described in this privacy statement; Any personal data collected and processed in the context of this document will be stored by FINHUB for a maximum period of five years after the end of the implementation period or termination of the loan agreement and / or other investment activity concluded by FINHUB, or the closure of operations in the context of the provision of loans and / or other types of investment or advisory services, whichever is the longest; and seven years in respect of lending and / or other investment activities or advisory activities (after the end of the period of implementation or termination of the agreement concluded between FINHUB and a third party, authorized or termination of the operations of the grant agreement, whichever is longer) agreements with third parties; or

  • a maximum period of five years after the termination of a business relationship or the rejection of an application in the context of lending and / or other investment activities or advisory services

12. As part of its investigations, in order to identify and prevent fraud, corruption and any other prohibited actions, FINHUB collects identification data and professional data, which, if necessary, can be stored in FINHUB for up to seven years.

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