Privacy Policy

Our Privacy Policy outlines and explains how NjordX Finance OÜ (“NjordX Finance,” “We,” “Us,” “Our,”) uses, collects, discloses and/or protects the information provided by You when utilizing the products or services made available on Our Website (“Website.”)

Any and all Personal Information collected by Us is always handled in accordance with local data protection laws and the GDPR (General Data Protection Regulator). If and when required, NjordX Finance maintains registrations as a data controller with the relevant regulatory bodies.

It is Your responsibility to take the time to read and familiarize yourself with the contents of this Privacy Policy, as well as other notices that may be provided by us in the future. This Privacy Policy always supplements the contents of any other statements or notices.

‍

What Information Is Collected?

During the use of Our services offered by Our Website, You will be required to submit Personal Information. Personal Information is described as any information that could be used to identify You.

The following list is an overview of such Personal Information that We may collect and process when provided by You:

• Your name;
• Email address;
• Contact details, including phone numbers or addresses;
• Titles;Employers;
• Corporate contact details;
• Date of birth;Place of birth;
• Nationality;Country of residence;
• Personal document numbers and information;
• Personal photographs as provided on government-issued identification;Financial details such as bank account information needed to carry out service requests.

As You use Our Services and interact with Our Website, additional information may be processed, some of which may be considered personal information. The collection of such information is automated and can include:

• IP addresses;
• The browser used to access Our Website;
• The operating system of the device used to access Our Website.

All of the information collected, handled or processed by NjordX Finance is information that is strictly required in order to fulfil Our service obligations as permitted by law. Any other personal information, including data such as ethnicity, religion, political opinions or other such data is not collected.

‍

How Is The Personal Information Collected Used?

All of the personal information that We collect is processed in accordance with the relevant data protection laws and regulations that govern use of such personal information. Typically, processing of supplied data is justified based on the following condition:

• You have consented to Our use and processing of the relevant data;
• The data processing in question is required in order to enter the service agreement with You;
• The data processing in question is required as a result of regulations; or
• The data processing in question is in Our commercial interests and subject to Your data rights and interests.

We process the Personal Information that We collect in order to do the following:

• Provide You with the services requested from Us;
• Carry out the necessary investigations needed for the onboarding and vetting of new clients;
• Collect and analyze Website usage metrics.

Your personal information may be processed in either digital or hard copy form, both inside and outside the EU and EEA.

From time to time, We may send You direct marketing communications that We believe may be beneficial to You. These communications will be electronic in nature via email or telephone. While We will have obtained Your consent prior to sending direct marketing communications, You may opt out of receiving such communications by contacting us.

‍

Analytics

Our Website collects analytics that We may use in order to render services to You, improve Our services, identify and rectify any issues, provide new content based on user interest or monitor Website traffic and usage statistics.

In Your interactions with Our Website, including downloading files, We may, from time to time, leverage technologies in order to identify website visitors and monitor client engagement.

We may utilize Your IP address in order to tailor Our website appearance to Your preferences.

In the event that We utilize such information, these tools may be provided by third-party service providers. In these situations, We may provide Your personal information to these third-party service providers so that they may provide the requested service to Us.

‍

Cookies

Cookies are files generated while navigating the internet and stored on Your hard drive. These cookies contain data that may include anonymous identifiers.

Our Website may also use cookies. In the event that cookies are used, they will be managed by a control system that enables You to give or deny permissions pertaining to saving or storing cookies. You may also control cookie usage directly from the browser settings in order to have more control over the cookies that are allowed or denied.

‍

Personal Information Disclosure

The disclosure of Your personal information will always be limited to those employees or agents of NjordX Finance who require it for the purposes of rendering Our services, contacting You or in order to fulfil Our regulatory obligations.

In the event that We share Your personal information with any third-parties, such as for the purposes of due diligence, We will remain responsible for the ways that Your information is managed. We strive to ensure that third-party usage of Your personal information is consistent with the way that We handle it.

In certain cases, We will be required to disclose Your information to law enforcement or regulatory bodies. When We receive such requests, We will consider Your interests, although We may not be required to inform You of such requests.

‍

Personal Information Transfers Across Borders

Third-party service providers that handle service requests on Our behalf may be located in many different countries, and as such may be subject to regulations from different jurisdictions around the world. As a result of this, it is possible for Your personal information to be transferred both within and outside of the EU or EEA.

When You provide Us with Your personal information for the purposes of entering into a service agreement, You are consenting to having Your personal information transferred to jurisdictions that may not exercise the same level of care in handling Your data as Your home country.

‍

Retention of Personal Information

NjordX Finance typically keeps Your personal information for the duration required in order to fulfil Our service obligations to You. However, in certain cases We may retain Your information for longer periods of time. These include, but are not limited to, legal or accounting obligations We may be subject to.

Our retention procedures govern all of the data that We collect and retain. When Your information is no longer required to be retained, We will securely dispose of it and, when required by law, notify You of its disposal.

‍

Protection Of Your Personal Information

We will hold your Personal Information securely whilst it is under our control, including where it is processed by third party service providers on our behalf. We train our employees in respect of their obligations under applicable data protection laws, and will ensure that only relevant employees, contractors and agents have access to your Personal Information.

We take the security of our physical premises, our servers and the Website seriously and we will take all appropriate technical measures to keep them secure. We use recognised security procedures and tools in accordance with good industry practice to protect your Personal Information across all of these platforms.

Whilst we use all reasonable endeavours to protect your security in the manner described above, please be advised that data transmission over the Internet and the World Wide Web cannot always be guaranteed as 100% secure, and therefore that you use the Website at your own risk.

‍

Protection of Personal Information

Subject to applicable data protection laws, you may be entitled to the following rights in respect of your Personal Information:

• to obtain a copy of your Personal Information together with information about how, and on what basis that Personal Information is processed;
• to rectify inaccurate Personal Information we hold concerning you (including the right to have incomplete Personal Information completed);
• to request that we erase your Personal Information (in limited circumstances, where it is no longer necessary in relation to the purposes for which it was collected or processed);
• the processing is in our legitimate commercial interests, subject to your interests and fundamental rights.
• to object to processing of your Personal Information, subject to certain conditions;
• to withdraw your consent to our processing of your Personal Information (where that processing is based on your consent);
• to request that we transfer the Personal Information that we have collected to another data controller, or directly to you, under certain conditions.

In addition to the above, you have the right to lodge a complaint with an applicable supervisory authority. If you wish to investigate the exercising of any of these rights, please contact us using the details set out below.

‍

Privacy Policy Changes

Any changes made to this Privacy Policy will always be detailed on this web page in order to keep You informed of the information collected, the nature of its collection, conditions for its use and how information might be disclosed. In order to stay apprised of changes to this privacy policy as they’re made, please regularly visit this page.

‍

Links

This privacy policy governs the use of data collected from Our Website. In the event that links are made available to external sites, please note that We are not responsible for the collection or use of data that results from visits to these external sites. It is Your responsibility to read the privacy policy of each such website prior to using them.

‍

Conflict

In the event that there is a conflict between the conditions laid out in this privacy policy and the terms of any agreement or contract You have with us, the applicable provision of the contact will prevail. Nothing contained in this privacy policy will apply in the condition that it is incompatible with applicable and relevant data protection laws.

‍

Information And Contact Details

In regards to this website, Your data controller will be NjordX Finance OÜ. For any complaints, questions or in order to exercise Your rights where it pertains to the collection or use of Your personal information, please contact us via one of the following methods:

By email: legal@njordx.io

Estonian Data Protection Inspectorate

By post: 39 Tatari St., 10134 Tallinn

Telephone (from abroad add +372): 627 4135

By email: info@aki.ee