Privacy policy

SECRETS OF ZURICH LTD PRIVACY POLICY

1. GENERAL

1.1. Secrets of Zurich., company number ​11647187​, registration address 3 New Concordia Wharf, SE1 2BB, London, United Kingdom offers education services to the individuals. In accordance with commitment to protect personal privacy Secrets of Zurich adheres to the EU General Data Protection Regulation. This Privacy Policy explains how personal data are processed by Secrets of Zurich if a person uses services of Secrets of Zurich, website www.soz.fund/ (hereinafter – Website) or otherwise interacts with Secrets of Zurich. The term “personal data/information„ describes information that can be associated with a specific person and can be used to identify that person. The information that has been aggregated and/or anonymized so that it does not identify a specific user is not considered as a personal data/information.

1.2. Only persons of legal age are permitted to use Website and to register to it. Secrets of Zurich does not collect any personal information/data from persons under the legal age. If you believe Secrets of Zurich might have any personal information from or about a person under the legal age, please contact ​[email protected]
1.3. This Privacy Policy applies to information Secrets of Zurich process. Privacy policy does not apply to the practices of companies that Secrets of Zurich does not own or control, or employees that Secrets of Zurich does not manage. Information on Website may contain links to other third-party websites, and any information/data person provide to those sites will be covered by any privacy policies they may have.

2. DATA/INFORMATION COLLECTION AND USAGE

2.1. Secrets of Zurich may use personal data/information to allow to access to the Website; verify person’s identity; register and provide services; resolve disputes; troubleshoot problems; prevent potentially fraudulent, prohibited or illegal activities; customize, measure and improve services and the content of the Website; send person updates about new products and services that Secrets of Zurich is offering; compare information for accuracy and verify it with third parties; perform other duties as required by law.
2.2. Secrets of Zurich process following personal data/information:

2.2.1. Visitor data: it may include standard web log information, such as: IP address, browser type, operating system, pages accessed on the Website, date and time the website was accessed. Secrets of Zurich may collect this information for fraud prevention purposes and to be able to better assist with any visitor inquiries.

2.2.2. Registration data: contact details including name, address, email address, telephone number, password in encrypted form, and identification details including date of birth, gender, country of residence. Secrets of Zurich may collect this information in order a person to be able to use Secrets of Zurich services, to process the person’s registration process, also to provide our products and services.

2.2.3. Account data: it may include full name, username, email address, country of residence, telephone number, bank account, VAT number, etc. Secrets of Zurich may collect this information for the purposes of providing Secrets of Zurich services, ensuring the security of Secrets of Zurich users.

2.2.4. Verification data: it may include national identity documents (passport, driving license, ID card), utility bill details for residence. User registration documents may contain user’s name and registration address, identification number, date of birth, etc. Secrets of Zurich may collect this information to verify the identity of the account holder and prevent, detect and investigate fraud, money laundering, criminal activity.

2.2.5. Financial data: it may include transactions using Secrets of Zurich payment system including timestamp, transaction amount, transaction ID, bank account data, withdrawal transactions may include data such as timestamp, transaction amount, transaction ID and etc. Secrets of Zurich may collect this information in order to provide services and customer support, resolve disputes and troubleshoot problems, perform risk management.

2.2.6. Communication data: it may include all messages, requests and other communication with Secrets of Zurich customer support, email addresses, IP address, full name, ID verification data. Secrets of Zurich may collect this information for the purposes of communicating with person, record-keeping, in order to review and resolve disputes, support customer need and improve service.
2.3. Secrets of Zurich may process information/data of personal data when necessary for the establishment, exercise or defense of legal claims, whether in court proceedings or outside the court procedure. The legal basis for this proceeding is legitimate interest, namely the protection and assertion of Secrets of Zurich legal rights, person’s legal rights and the legal rights of other. 2.4. Secrets of Zurich need to collect certain types of information/data for compliance with legal requirements relating to our anti-fraud, anti-money laundering and know your customer obligations. If this information is not provided Secrets of Zurich cannot agree to provide services.
2.5. Personal data/information may be transferred outside the European Economic Area (EEA). Some of those countries do not have equivalent data protection laws to those applicable in the EEA. To ensure personal data/information is properly protected in line with EU and UK data protection law, the transfer of this information is, in general, governed by a contract including Standard Contractual Clauses approved by the European Commission in accordance with Article 46(2)(c) of the General Data Protection Regulation (GDPR) or transferred to a business certified under the US Privacy Shield in accordance with Article 46(2)(e) of the GDPR. In some limited circumstances, Secrets of Zurich may also transfer personal data/information outside the EEA if the GDPR (under Article 49) allows this. This includes where it is necessary for the performance of a contract, this also includes where the transfer is necessary in connection with legal proceedings.
2.6. Secrets of Zurich will keep customer personal data/information for the period the customer has an account with Secrets of Zurich and for one year after the account is closed, but Secrets of Zurich may store personal data/information for longer if required for legal claims, legal disputes. Secrets of Zurich will keep information about visitors for a reasonable length of time

which will usually not exceed one year.

3. PROVIDING PERSONAL DATA/INFORMATION TO OTHERS

3.1. For behavior statistics and business intelligence Secrets of Zurich use the service by Google LLC (Google Analytics), a company located in the United States. Data that Secrets of Zurich may provide to Google Analytics may include IP address and is used by Google Analytics to generate information about your usage of our service.
3.2. For processing communication data, Secrets of Zurich uses the service by FinPass, a company located in Lithuania. Communication data may include IP address, country, pages visited, e-mail address, website or company affiliation.
3.3. Secrets of Zurich may also may transfer personal data/information to potential buyers of Secrets of Zurich business, to professional advisors, located in and outside the EEA.
3.4. Personal data/information may be transferred to other third-party organizations if Secrets of Zurich is required by law, or if Secrets of Zurich is asked by any public or regulatory authority.

4. PROTECTION AND STORAGE

4.1. Secrets of Zurich store and process personal data/information using third party servers located in data centers in the EEA. This information is protected by physical, electronic and procedural safeguards in compliance with applicable regulations.
4.2. Secrets of Zurich uses computer safeguards such as firewall and data encryption. Secrets of Zurich strive to ensure security on Secrets of Zurich system, despite all efforts, Secrets of Zurich cannot guarantee that personal data/information may not be accessed, disclosed, altered or destroyed by breach of Secrets of Zurich administrative, managerial and technical safeguards.

5. ACCESS AND CHANGES TO PERSONAL DATA/INFORMATION

5.1. Users can review name, telephone number, email address, account information at any time by logging in to your account and reviewing your personal data/information.

6. RETAINING AND DELETING PERSONAL DATA/INFORMATION

6.1. Personal data/information that Secrets of Zurich process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes. Users may request the deletion of their account through our site.

7. RIGHTS

7.1. Principal rights under data protection law are:
7.1.1. The right to access. The right to confirmation as to whether or not Secrets of Zurich

process personal data. Providing the rights and freedoms of others are not affected, Secrets of Zurich will supply a copy of personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee. Person can ask for personal data by contacting Secrets of Zurich customer support.

7.1.2. The right to rectification. The right to have any inaccurate personal data about person rectified and, considering the purposes of the processing, to have any incomplete personal data about person completed.

7.1.3. The right to erasure. The right to the erasure of personal data.

7.1.4. The right to data portability. To the extent that the legal basis for Secrets of Zurich processing of personal data is consent, and such processing is carried out by automated means, person have the right to receive personal data from Secrets of Zurich in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.

7.1.5. The right to complain to a supervisory authority. If person considers that Secrets of Zurich processing of personal information infringes data protection laws, person has a legal right to lodge a complaint with a supervisory authority responsible for data protection.

7.1.6. The right to withdraw consent. To the extent that the legal basis for Secrets of Zurich processing of personal information is consent, person has the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
7.2. Without prejudice to the aforementioned, if Secrets of Zurich has reasonable doubts concerning the identity of a user exercising his/her rights referred to in this section or if Secrets of Zurich otherwise due to security reasons deem it necessary, Secrets of Zurich may request the provision of additional information.

8. COOKIE POLICY

8.1. When person visits Website or create an account, Secrets of Zurich may use cookies and other tracking technologies (hereinafter – Cookies). Secrets of Zurich uses Cookies to recognize person as a customer, enable certain features and mitigate risk and prevent potential fraud.
8.2. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.

8.3. Cookies do not typically contain any information that personally identifies a user, but personal information that Secrets of Zurich may store about a person may be linked to the information stored in and obtained from cookies.
8.4. Secrets of Zurich uses “session” cookies when user is logged in so that Secrets of Zurich can remember this fact. That way Secrets of Zurich do not have to ask user to re-enter password every time user visits a new page. Once a user logout or close his/her browser, this cookie expires and no longer has any effect.

8.5. Secrets of Zurich uses “persistent” cookies for other purposes such as to display user’s email address on login page, so that user does not need to retype the e-mail address each time he/she logs in to his/her account.
8.6. When user submit data through a form such as those found on contact pages, cookies may be set to remember user details for future correspondence. In order to provide user with a great user experience, Secrets of Zurich provide the functionality to set user’s preferences for how Website runs when user uses it. In order to remember user’s preferences Secrets of Zurich

needs to set cookies so that this information can be called whenever user interact with a page that is affected by user’s preferences.
8.7. We run an affiliate program and provide our affiliates the opportunity to advertise our site and services. With the affiliate program we use tracking cookies to track users who visit our site through one of our affiliate partner sites in order to credit them appropriately, and where applicable, allow our affiliate partners to provide you any bonus for making a purchase.

8.8. Person can manage cookies through the settings of his/her Internet browser. Person can have the browser notify when a person receives a new cookie, delete individual cookies or delete all cookies. Certain aspects and features of Secrets of Zurich services and Website are only available through the use of Cookies, so if a person choose to disable or decline Cookies, use of the Website and Secrets of Zurich services may be limited or not possible.

9. DECLARATION OF CONSENT

9.1. By checking the respective box as a part of the registration process, the user confirms to have read this Privacy Policy and agrees to the data processing as described herein.

10. CHANGES TO THIS PRIVACY POLICY

10.1. This Privacy Policy may be changed from time to time in response to changing legal, technical or business development. Secrets of Zurich will take appropriate measures to inform the user about changes of Privacy Policy.