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PRIVACY POLICY

The Privacy Policy may be made available in several languages, all versions are legally binding, but in the event of inconsistency between English version and a translated version English version prevails.

1. INTRODUCTION

  1. 1.1 The Privacy Policy establishes basic principles on personal data processing of TIMAU (hereinafter – TIMAU SPACE).
  2. 1.2 TIMAU SPACE takes the privacy of customers personal information very seriously. TIMAU SPACE is responsible for ensuring that personal information is collected and processed in line with the Personal Data Protection Act of the Republic of Latvia and the EU General Data Protection Regulation (GDPR).
  3. 1.3 The Privacy Policy forms an integral part of the Terms and Conditions and describes how we collect, process, disclose and transfer personal information that is provided to us during use of TIMAU SPACE services. Please check the Terms and Conditions for the meaning of capitalized terms.
  4. 1.4 The respective Policy is applicable if a Customer uses, has used or has intention to use consulting services provided by TIMAU SPACE, including the relationship with the Customer established before this Policy enters into force.

2. FOR THE PURPOSE OF THIS POLICY THE FOLLOWING DEFINITIONS ARE USED:

  1. 2.1 Customer – any private individual who uses, has used or has expressed a wish to use or is in other way related to any of the services provided by TIMAU SPACE.
  2. 2.2 Personal data - means any information relating to an identified or identifiable Customer.
  3. 2.3 Processing - any operations carried out with Personal data (incl. collection, recording, storing, alteration, grant of access to, making enquiries, transfer, etc).
  4. 2.4 TIMAU SPACE - means a legal entity, company's registration code: 40203446911, registered office at Maskavas iela 55, Riga, Latvia, LV-1003, email: info@timau.space and who is acting as a Personal data controller.

3. GENERAL PROVISIONS

  1. 3.1 This Policy describes general principles how TIMAU SPACE processes Personal data. Specific details on the processing of Personal data might be also included in agreements entered or to be entered between the Customer and TIMAU SPACE and is reflected in website https://timau.space;
  2. 3.2 TIMAU SPACE ensure, within the framework of applicable law, the confidentiality of Personal data and has implemented appropriate technical and organisational measures to safeguard Personal data from unauthorized access, unlawful Processing or disclosure, accidental loss, modification or destruction.
  3. 3.3 TIMAU SPACE may use authorised processors of Personal data Processing. In such cases TIMAU SPACE takes needed steps to ensure that such data processors Process Personal data under the instructions of TIMAU SPACE and in compliance with applicable law and requires adequate security measures.
  4. 3.4 TIMAU SPACE’s cookies policy is available on TIMAU SPACE website https://timau.space.

4. CUSTOMER CONSENT

  1. 4.1 By providing the consent to the Terms and Conditions before using TIMAU SPACE services and by using TIMAU SPACE services the Customer expressly provides its consent to the processing of personal information under this Privacy Policy. The Customer provides its consent to the transfer of personal information via the Internet, including transfer of personal information to countries outside the European Economic Area (‘EEA’). If the Customer objects to personal information is being collected, processed or disclosed under this Privacy Policy, the Customer should not use TIMAU SPACE services.
  2. 4.2 If TIMAU SPACE intends to collect, process or disclose personal information for a purpose not under this Privacy Policy, TIMAU SPACE will inform the Customer and give the Customer an opportunity to object or decline collection, processing or disclosure of personal information in question.

5. CATEGORIES OF PERSONAL DATA

  1. 5.1 Personal data may be collected from the Customer, from the Customer’s use of the consulting services and from external sources such as public and private registers or other third parties.
  2. 5.2 Personal data categories which TIMAU SPACE primarily, but not only, collects and processes are the following:
  3. 5.2.1 Contact data such as telephone number, email address or applying for particular products the residence address (if applicable), language of communication;
  4. 5.2.2 Data about the relationships with legal entities such as data submitted by the Customer or obtained from public registers, legal representatives (acting with relevant authorisation or on any other basis), contracting parties and contract participants, funds sources, ultimate beneficial owners (UBO), general manager of a company; shareholder; member of the management board or any other management body; Data about habits, preferences and satisfaction such as the activeness of using the services, services used, personal settings, survey responses, lifestyle, hobbies, Customer satisfaction;
  5. 5.2.3 Data obtained and/or created while performing an obligation arising from law such as data resulting from enquiries made by investigative bodies, notaries, tax administrator, courts and bailiffs, details of income, credit commitments, property holdings, and debt balances;
  6. 5.2.4 Data on origin of assets such as data regarding the Customer's business activities;
  7. 5.2.5 Data related to the services such as the performance of the agreements or the failure thereof, executed transactions, concluded and expired agreements, submitted applications, requests and complaints, interests and service fees;
  8. 5.2.6 Data that enables TIMAU SPACE to perform its due diligence measures regarding money laundering and terrorist financing prevention and to ensure the compliance with international sanctions, including the purpose of the business relationship and whether the Customer is a politically exposed person;
  9. 5.2.7 Depending on TIMAU SPACE product the Customer has chosen data about the Customer’s tax residency such as data about the country of residence, tax identification number, citizenship;
  10. 5.2.8 Communication data - collected when the Customer communicates with TIMAU SPACE via telephone, visual and/or audio recordings, e-mail, messages and other communication channels such as social media, data related to the Customer’s visit at web page or communicating through other TIMAU SPACE channels (such as chat).
  11. 5.2.9 Location data - processed on an electronic communications network or processed by means of electronic communications services, indicating the location of the electronic communications terminal equipment, including the location of the terminal equipment (address), connection point address, GPS, Wi-Fi, etc.
  12. 5.2.10 TIMAU SPACE may collect and store information (including personal information) locally on Customer’s device using mechanisms such as browser web storage.
  13. 5.2.11 TIMAU SPACE may use various technologies to collect and store information when Customer visit TIMAU SPACE web page, and this may include using cookies or similar technologies to identify Customer’s browser or device.

6. PURPOSES AND BASIS OF PROCESSING PERSONAL DATA

  1. 6.1 TIMAU SPACE process Personal data only for specific and necessary purposes, based on certain legal bases, including TIMAU SPACE ’s legitimate interests.
  2. 6.2 TIMAU SPACE process Personal data primarily to:
    1. 6.2.1 manage Customer relations in general and provide and administrate access to consulting services offered by TIMAU SPACE.
    2. 6.2.2 provide services and to execute contracts (deals) concluded. Processing is carried out on the basis of law and contract (transaction) basis;
    3. 6.2.3 perform credit and risk assessments;
    4. 6.2.4 notify Customer about changes to TIMAU SPACE ’s services;
    5. 6.2.5 administer TIMAU SPACE ’s web pages for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
    6. 6.2.6 improve TIMAU SPACE ’s web pages and to ensure that content is presented in the most effective manner for you and for your computer;
    7. 6.2.7 allow to participate in interactive features of TIMAU SPACE ’s service, when Customer choose to do so;
    8. 6.2.8 measure or understand the effectiveness of advertising TIMAU SPACE serves to Customer and others, and to deliver relevant advertising to Customer;
    9. 6.2.9 to help TIMAU SPACE better understand Customer financial circumstances and behaviour according to which TIMAU SPACE may make decisions about managing Customer’s account;
    10. 6.2.10 protect the interests of the Customer and /or TIMAU SPACE and examine the quality of services provided by TIMAU SPACE and for the purpose of providing proof of a commercial transaction or of other business communication (recorded conversations) based on performance of an agreement or in order to take steps at the request of the Customer prior entering into an agreement or compliance with a legal obligation or consent from the Customer or legitimate interests of TIMAU SPACE to prevent, limit and investigate any misuse or unlawful use or disturbance of TIMAU SPACE consulting services or quality assurance of services, establish, exercise, assign and defend legal claims;
    11. 6.2.11 provide additional services; perform customer surveys, market analyses and statistics. Offer to the Customer the services of TIMAU SPACE or carefully selected cooperation partners, including personalized offers, based on consent from the Customer;
    12. 6.2.12 perform Customer’ surveys, market analyses and statistics; organize games and campaigns for a Customer based on TIMAU SPACE ’s legitimate interest to improve TIMAU SPACE ’s services, improve the Customer’s user experience of services and to develop new products and services;
    13. 6.2.13 TIMAU SPACE offers to comply with legal obligations and verification of identity. To comply with applicable law, for example related to implementing the principles of responsible lending, prevent, discover, investigate and report potential money laundering, terrorist financing, if the Customer is subject to financial sanctions or is a politically exposed person;
    14. 6.2.14 prevent misuse of consulting services and ensure adequate provisions of services. To authorize and control access to and functioning of digital channels, prevent unauthorized access and misuse of those and to ensure the safety of information based on: performance of an agreement or take steps at the request of the Customer prior to entering into an agreement. To improve technical systems, IT infrastructure, customizing the display of the service to the device and to develop TIMAU SPACE services such as by testing and improving technical systems and IT infrastructure;
    15. 6.2.15 execute transactions on TIMAU SPACE ’s system and process incoming payments.

7. ADVERTISING AND DIRECT MARKETING

  1. 7.1 TIMAU SPACE ’s advertising and direct marketing communications (e.g. about TIMAU SPACE’s Services and related campaigns) are sent to Customers who have consented to receiving direct marketing and commercial communications from TIMAU SPACE. Such Customers receive TIMAU SPACE commercial communications and direct marketing communications via their preferred means of communication. TIMAU SPACE may market its services to the existing Customers on the ground of legitimate interest.
  2. 7.2 The Customer may give his/her consent to the receipt of commercial communications of TIMAU SPACE by visiting TIMAU SPACE’s web page and/or registering on the website, as well as by signing service application forms.
  3. 7.3 Client’s consent to receive commercial communications is valid until its withdrawal. Customers have the right to object to the processing of their Personal data for direct marketing purposes at any time and free of charge. To exercise this right, please contact the TIMAU SPACE. Customers can also opt out of receiving the advertising and commercial communications using the link provided in the e-mail message or following other instructions as provided in such direct marketing communication.

8. THE GROUNDS TO ACCESS AND USE PERSONAL DATA

  1. 8.1 TIMAU SPACE access and use your personal data, if any of the following applies:
    1. 8.1.1 Customer intend to conclude or have concluded an agreement with TIMAU SPACE;
    2. 8.1.2 Customer have given your consent;
    3. 8.1.3 processing of personal data is possible on the basis of legislative acts;
    4. 8.1.4 for the purposes of our legitimate interests, such as, e.g.:
    5. 8.1.5 to improve TIMAU SPACE service quality, to ensure our operational consistency and sustainability, comprehensiveness of services adapting them to Customer's expectations to achieve maximum Customer satisfaction;
    6. 8.1.6 to bring an action or defend any legal claims and carry out other legal actions with the aim to avoid or minimise losses;
    7. 8.1.7 to systematically monitor and prevent illegal activities a perform continuous assessment of relevant risks.
  3. 8.2 If Customer fails to provide TIMAU SPACE with personal data that is necessary for the conclusion and/or performance of an agreement or provision whereof is required by law or under the agreement, TIMAU SPACE may be unable to provide services to Customer.
  4. 8.3 The Customer may have the right:
    1. 8.3.1 to access personal information TIMAU SPACE holds about the Customer. TIMAU SPACE may charge a fee for providing or making this information available;
    2. 8.3.2 to require TIMAU SPACE not to process personal information for marketing purposes;
    3. 8.3.3 to request the erasure of personal data (“The right to be forgotten”) by submitting a request;
    4. 8.3.4 to exercise its rights mentioned above by sending an e-mail specified on the webpage.

9. PROFILING, PERSONALIZED OFFERING AND AUTOMATED DECISION MAKING

  1. 9.1 Profiling refers to the automatic Processing of Personal data used to assess certain personal characteristics of a Customer. Profiling is used for direct marketing purposes. Automated decision making is used for risk management and for transaction monitoring to counter fraud and is based on TIMAU SPACE’s legitimate interest, compliance with a legal obligation, performance of an agreement or consent from the Customer.
  2. 9.2 TIMAU SPACE may process Personal data to improve the user experience of the digital services. Unless direct marketing has been restricted by the Customer, TIMAU SPACE may Process Personal data for the purpose of providing general and personalized offers of TIMAU SPACE ’s services.
  3. 9.3 TIMAU SPACE always ensure that Customers can make their choices and use a convenient tools to manage their privacy settings.
  4. 9.4 TIMAU SPACE may also collect statistical data regarding the Customer, such as typical behaviour and lifestyle patterns based on demographic household data. Statistical data for creating segments profiles can be collected from external sources and may be combined with TIMAU SPACE internal data.

10. PROVIDERS AND RECIPIENTS OF PERSONAL DATA

  1. 10.1 TIMAU SPACE use personal data, which Customer provides to TIMAU SPACE when Customer seeks TIMAU SPACE 's services and use them, when Customer fill out Customer information forms, submit requests or file claims, also the ones TIMAU SPACE document at website, app, by video surveillance equipment or telephone records, as indicated above.
  2. 10.2 Also, TIMAU SPACE may collect your personal data from other sources, such as:
    1. 10.2.1 other financial institutions;
    2. 10.2.2 Bank of Latvia, Ministry of Finance, Department of Statistics, State Social Insurance Fund Board, State Enterprise Centre of Registers, law enforcement institutions, other registers and institutions;
    3. 10.2.3 natural persons, when they provide data of their spouses, children, other relatives by blood or marriage, guarantors, go-borrowers, collateral providers, etc.;
    4. 10.2.4 documents that are dedicated for us and received from natural or legal persons when they execute contractual obligations towards us or obligations arising from legislation (information from contracts, reports, etc.);
    5. 10.2.5 legal entities, where you are a representative, employee, counterparty, shareholder, participant, owner, etc. of a relevant legal entity;
    6. 10.2.6 partners or other legal entities, who provide their services with our help.
  4. 10.3 TIMAU SPACE can collect personal information by monitoring technological tools and services, among other things, communication by email from or to TIMAU SPACE. Another instance is when TIMAU SPACE collect information and generate, where Customer provide TIMAU SPACE with it, for instance, by identifying himself (herself) or by providing a comment by electronic means. Also, TIMAU SPACE can obtain information from suppliers. TIMAU SPACE can combine the information obtained from various sourced.
  5. 10.4 Personal data is shared with other recipients, such as:
    1. 10.4.1 Authorities (such as law enforcement authorities, tax authorities, supervision authorities);
    2. 10.4.2 Other banks and financial institutions, providers of payment and other services involved in the performance of a transaction in order to execute transactions on TIMAU SPACE ’s system;
    3. 10.4.3 Auditors, legal and financial consultants, or any other processor authorized by TIMAU SPACE.
    4. 10.4.4 Third parties maintaining registers (such as to credit bureaus, population registers, commercial registers, or other registers holding Personal data);
    5. 10.4.5 Participants and/or parties related to domestic, European and international payment systems, such as SWIFT;
    6. 10.4.6 Debt collectors upon assignment of claims;
    7. 10.4.7 Courts, out – of - court dispute resolution body and bankruptcy or insolvency administrators.
    8. 10.4.8 Other persons related to provision of services of TIMAU SPACE such as providers of postal services or analytical services or any other services.

11. GEOGRAPHICAL AREA OF PROCESSING

  1. 11.1 The Personal data that TIMAU SPACE collects from you may be transferred to and stored at a destination outside the European Union and/or European Economic Area, in particular where counterparties to any of the service offered through our website are based outside the European Union and/or European Economic Area. The Personal data may also be processed by staff and contractors operating outside the European Union and/or European Economic Area who works for us or for one of our suppliers.
  2. 11.2 These countries may be deemed by the Commission to provide adequate level of protection (e.g. United States under Privacy Shield). TIMAU SPACE also apply additional safeguards to ensure the protection of Personal data. In any case, all transfers to countries outside the European Economic Area will be in full compliance with all aspects of the GDPR.

12. RETENTION PERIOD

  1. 12.1 TIMAU SPACE keeps Personal data for the purpose of attaining the objectives set forth in this Privacy Policy, unless the longer their storage is specified or permitted by applicable law. Personal data are retained in the format which enables to identify the data subject only until this is necessary for achievement of the purpose for which the personal data is processed.
  2. 12.2 To determine the data retention period, TIMAU SPACE uses criteria that are in line with the regulatory enactments, such as examining claims, protecting rights, resolving issues, compliance with limitation periods, etc.
  3. 12.3 The retention period may be based on agreements with the Customer, the legitimate interest of TIMAU SPACE or applicable law (such as laws related to rendering consumer loans, bookkeeping, anti-money laundering, civil law, etc).

13. CUSTOMER’S RIGHTS AS A DATA SUBJECT

  1. 13.1 A Customer (data subject) has rights regarding his/her data Processing that is classified as Personal data under applicable law. Such rights are in general the following:
    1. 13.1.1 Require his/her Personal data to be corrected if it is inadequate, incomplete or incorrect.
    2. 13.1.2 Object to Processing of his/her Personal data, if the use of Personal Data is based on a legitimate interests, including profiling for direct marketing purposes (such as receiving marketing offers or participating in surveys).
    3. 13.1.3 Require the erasure of his/her Personal data, for example, that is being processed based on the consent, if he/she has withdrawn the consent. Such right does not apply if Personal data requested to be erased is being processed also based on other legal grounds such as agreement or obligations based on applicable law.
    4. 13.1.4 Restrict the Processing of his/her Personal data under applicable law, e.g. during the time when TIMAU SPACE assesses whether the Customer is entitled to have his/her data erased.
    5. 13.1.5 Receive information if his/her Personal data is being processed by TIMAU SPACE and if so then to access it.
    6. 13.1.6 Receive his/her Personal data that is provided by him/herself and were feasible transmit such data to another service provider (data portability).
    7. 13.1.7 Withdraw his/her consent to process his/her Personal data.
    8. 13.1.8 Not to be subject to fully automated decision - making, including profiling, if such decision - making has legal effects or similarly significantly affects the Customer. This right does not apply if the decision - making is necessary in order to enter into or to perform an agreement with the Customer, if the decision - making is permitted under applicable law or if the Customer has provided his/her explicit consent.
  3. 13.2 TIMAU SPACE takes every effort for the implementation of Customer's rights and for answering any and all questions that arise to Customer regarding the present Policy and matters envisaged in it.
  4. 13.3 TIMAU SPACE will reply to Customer Request within a period of not more than 30 (thirty) calendar days since the day of receipt of the Request. In exceptional circumstances, which require additional time, TIMAU SPACE will, by giving you a relevant notice, have the right to extend the deadline for the submission of the requested data or for the consideration of claims set out in the Request up to 60 (sixty) calendar days after the day of Customer's referral.

14. PERSONAL DATA PROTECTION PRINCIPLES

  1. 14.1 The principles TIMAU SPACE observes when collecting and using personal data entrusted to TIMAU SPACE as well as personal data obtained from other sources are as follows:
    1. 14.1.1 personal data are processed in a legitimate, fair and transparent manner (the principle of legality, fairness and transparency);
    2. 14.1.2 personal data are collected for specified, explicit and legitimate purposes and not further processed in a way incompatible with those purposes (principle of purpose limitation);
    3. 14.1.3 personal data are adequate, relevant and only such that are required in relation to the purposes for which they are processed (principle of data minimisation);
    4. 14.1.4 processed personal data are accurate and, where necessary, kept up to date (principle of accuracy);
    5. 14.1.5 personal data are kept in a form which permits identification of data subjects for no longer than it is necessary in view of the purposes for which the data are processed (principle of retention limitation);
    6. 14.1.6 personal data are processed in such a way that application of relevant technical or organisational measures would ensure adequate personal data security, including protection from unauthorised data processing or unlawful data processing and from accidental loss, destruction or damage (integrity and confidentiality principle).
  3. 14.2 In the process of collecting and using personal data entrusted to TIMAU SPACE as well as those obtained from other sources, TIMAU SPACE do undertake as follows:
    1. 14.2.1 to process personal data for explicit and legitimate purposes only;
    2. 14.2.2 to refrain from processing personal data for purposes other than those stated in the present Policy, unless otherwise laid down by relevant legislation;
    3. 14.2.3 to process personal data lawfully, accurately, in a transparent manner and so that accuracy, identity and security of the processed personal data is ensured;
    4. 14.2.4 to ensure that superfluous personal data are not processed;
    5. 14.2.5 to process personal data no longer than it is necessary for the purposes for which personal data are processed;
    6. 14.2.6 be responsible for the observance of the principles laid down in the present Policy and be able to prove their observance;
    7. 14.2.7 to perform other duties arising from the legislation.

15. CONTACT DETAILS

  1. 15.1 Customers may contact TIMAU SPACE with any enquiries, withdrawal of consents, requests to exercise data subject rights and complaints regarding the use of Personal data.
  2. 15.2 Contact details of TIMAU SPACE are available on TIMAU SPACE website https://timau.space/.

16. VALIDITY AND AMENDMENTS OF THE PRIVACY POLICY

  1. 16.1 TIMAU SPACE is entitled to amend the Policy at any time unilaterally, in compliance with the applicable law, by notifying the Customer of any amendments via website of TIMAU SPACE not later than one month prior to the amendments entering into force. The Customer acknowledges and agrees that it is its responsibility to review this Privacy Policy periodically and become aware of modifications.
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