Privacy Policy

This privacy policy (hereinafter – the Privacy Policy) determines the data collected by UAB Hodler’s legal entity code 304159704 (hereinafter – HODL Finance or we) when visitors use and navigate this website of HODL Finance (hereinafter – the Website), as well as means and sources wherefrom such data is obtained, and the legal basis for processing of personal data and measures, which have been taken by HODL Finance to protect the collected data.

The controller of the data provided on or through the website is HODL Finance. If any questions regarding this Privacy Policy or your data protection arise, you may contact us by e-mail: [email protected]

  1. THE PROCESSING OF PERSONAL DATA FOR DIRECT MARKETING PURPOSES
    1. HODL Finance processes your e-mail for direct marketing purposes.
    2. The basis for the processing of your personal data for direct marketing purposes is consent. We process your personal data only after obtaining your explicit consent to such processing.
    3. Your personal data can be processed in the following way: you can receive a newsletter about HODL Finance offers and other news.
    4. Personal data collected for direct marketing purposes will be stored for 3 years after consent is obtained. After this term, your personal data processed by HODL Finance will be immediately destroyed.
    5. You have the right to refuse our newsletters at any time. You can do this by clicking on a special link at the bottom of our newsletters or by informing us in writing.
  2. THE PROCESSING OF PERSONAL DATA UPON VISITORS’ REQUESTS
    1. HODL Finance also processes your data when you contact us by e-mail or mail.
    2. The purpose of processing your data is:
      1. To ensure timely and appropriate processing of your requests.
      2. To contact you regarding any information you provide.
      3. To protect our interests.
    3. The basis for the processing of your personal data upon your request is consent which is expressed through your active actions – submitting a request.
    4. Personal data collected for the abovementioned purposes will be stored for up to 3 years depending on the data and other circumstances. Longer periods of personal data retention may be applied where:
      1. There is a reasonable suspicion of an unlawful act which is subject to investigation.
      2. Your data is necessary for the proper resolution of the dispute, complaint or claim.
      3. HODL Finance has received complaints related to you, or if HODL Finance has noticed any violations committed by you.
      4. It is necessary for back-up copies or related purposes of functioning of information systems of HODL Finance.
      5. It is mandatorily required by applicable laws.
    5. THE PROCESSING OF PERSONAL DATA ON THE WEBSITE
      1. Each time you access or visit the website, the following technical personal data may be automatically collected: IP address, access date and time, webpage name and URL, device operating system data, information about the Internet provider, geo-location data, language settings and other relevant data.
      2. HODL Finance may also collect and use cookies. A cookie is a file containing an identifier that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. We use cookies to ensure the efficient and safe operation of the website and to analyse your habits so that the website is comfortable, efficient and tailored to meet your needs and expectations.
      3. Most browsers allow you to refuse cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can, however, obtain up-to-date information about blocking and deleting cookies via this link: http://www.allaboutcookies.org/.
      4. Please note, that required and analytical cookies are a condition of website use. If you opt out of these cookies, we cannot be sure how the website will work.
    6. DATA TRANSMISSION TO THIRD PARTIES
      1. In the light of investigations or other cases provided by law, your personal data may be submitted to law enforcement, and judicial or pre-trial institutions without any specific consent.
      2. Additionally, particular technical data pertaining to your visits to the website (such as IP address, data collected or placed on devices by  cookies, technical information of the browser, other information related to your browsing activities, etc.) may be transferred or made available to  entities in the EEA as well as outside the EEA for  purposes related to statistics, analysis and other related purposes. Please note that  personal data in non-EU countries may be subject to less protection than in the EU. The company will carefully assess the conditions under which such data will be processed and stored after transfer to the above entities.
      3. HODL Finance also uses services provided by third parties (such as third-party data centres, servers, website design, administration services, online traffic and website analysis, statistics, direct marketing services, etc.) that may require access to your personal data to the appropriate extent. In this case, we ensure that the data processors comply with the obligations of confidentiality and adequate personal data protection.
    7. THE RIGHTS OF WEBSITE VISITORS
      1. You have the following rights:
        1. The right of access to your personal data. You have the right to receive  confirmation that HODL Finance is processing your personal data as well as the right to access your personal data processed and information about the purposes of processing, the categories of data being processed, the categories of data recipients, the period of data processing and the sources of data.
        2. The right to rectification. If you think that data processed by HODL Finance is inaccurate or incorrect, you have the right to request that this data be modified, clarified or corrected.
        3. The right to erasure (right to be forgotten). When there are circumstances specified in certain legal acts (when the processing of personal data is illegal, the basis of processing of data has disappeared, etc.), you have the right to request that HODL Finance erase your personal data.
        4. The right to a restriction of processing. When there are circumstances specified in certain legal acts (when the processing of personal data is illegal, you contest the accuracy of the data, etc.), you also have the right to request that HODL Finance restrict the processing of your data.
        5. The right to data portability. You have the right to transfer your data processed by HODL Finance with your consent and by automated means to another controller.
        6. The right to disagree with the processing of your personal data if it is processed on a legitimate interest basis, unless there are legitimate reasons for such processing or for the purpose of claiming, enforcing or defending legal requirements.
        7. The right to revoke your consent to process your personal data. If we have no other legal basis for the processing of personal data, we will cease processing of personal data immediately after the cancellation / revocation of the consent provided by you.
      2. In case you deem that your rights have been violated, you have the right to file a complaint to the State Data Protection Inspectorate, A. Juozapavičius st. 6, LT-09310 Vilnius. However, we strongly recommend that you contact us first.
      3. By implementing appropriate technical and organisational measures, HODL Finance protects your personal data from loss, misuse, unauthorised access, disclosure or alteration.
    8. FINAL PROVISIONS
      1. By using our services and/or browsing the website, you agree to the terms of this Privacy Policy.
      2. This Privacy Policy may, from time to time, be updated by HODL Finance. We will inform you about the updates by submitting a new version of the Privacy Policy.