Privacy policy

The privacy of customer’s personal data is important to DataC Therefore, we
consider it necessary to inform our customers about data being collected, the
purposes of such collection, requirements for retention and rights related to
the processing of the personal data.

For the avoidance of doubt, this privacy policy applies to personal data
processing which is conducted in relation to a customer who is a natural
person (hereinafter “Customer”) where DataC acts as data controller. Any
personal data processing conducted on behalf of the Customer where DataC
acts as data processor (such as further provision of DataC services after the
company has been established and its operation is supported by various
services) is subject to an additional data transfer agreement signed between
DataC and the legal person controlled by the Customer.
DataC has the right to unilaterally supplement and/or amend the privacy policy
from time to time. We undertake to notify the Customer about such changes.
If the Customer does not agree with any or all terms of this policy or any
possible changes to it, then he/she should immediately close the website and
cease using the services provided by DataC.


1- Personal data being collected

DataC processes the following data about the Customer (hereinafter
“Personal Data”):

  • Data concerning the identification and verification of a person: full name
    (surname and given name), gender, personal identification code, date of birth,
    nationality, data concerning whether the Customer is politically exposed, URL
    of a Portfolio or LinkedIn profile, contact postal address, email, name of the
    bank where the personal bank account exists, copy of a passport.
  • Data concerning payments for DataC services and state fees: account
    number (IBAN), account holder name, bank name; transaction details;
    If the Customer chooses to pay for the Service by credit card or by PayPal,
    his/her payment details are not stored by DataC and therefore cannot be
    accessed by DataC.
  • Other data obtained by the use of the website or during the provision of
    service: Customer’s correspondence with DataC, inquiries submitted via the
    website, email, social media or chat; Customer’s activity logs. See also
    sections “Cookies and tracking technologies” and “Google Analytics and ads”
    We may combine the data we collect in relation to the Customer with data that
    we receive about the Customer from other sources, such as public databases

2- Purposes for collecting and processing Customer’s
Personal Data

Personal Data collected by DataC is processed for the purposes established
in the law or as described herein, including but limited for the following

  • to provide our Service (i.e. for the performance of service agreement);
  • to comply with anti-money laundering requirements, and combat fraud;
  • to manage, analyze and improve our Service;
  • to personalize our Service and the content provided to the Customer;
  • to contact the Customer for administrative purposes such as customer
    service, address technical or legal issues related to the Service provided, or
    share updates and notifications about the Service;
  • to send relevant promotional information to the Customer about DataC
    services and the related offerings by third parties we work with, if the
    Customer has granted an explicit consent to use his/her personal data for this
    DataC shall not use Customer’s Personal Data for any other purpose
    incompatible with the purposes outlined above or required, permitted or
    authorized by law

3- Transfer of the Personal Data

DataC may transfer Customer’s Personal Data to third parties, such as legal
and regulatory authorities (e.g. commercial register), accountants, auditors,
lawyers and other outside professional advisors; and to companies that
provide services to DataC (such as banks, IT systems suppliers and support;
cloud service provider or other outsourcing providers). DataC has taken steps
to ensure that these data recipients protect the confidentiality and security of
Personal Data, and to ensure that Personal Data is processed only for the
provision of services and in compliance with applicable law.
Such third parties may be located in countries outside of the European
Economic Area (“EEA”) whose privacy regulations may differ and which are
not subject to adequacy decisions of the European Commission. In those
countries the security of the Personal Data (Inc. protection against misuse,
unauthorized access, disclosure, alteration or destruction) may not be
ensured as it is secured in the European Union, due to the lack of adequate
data protection level.
For example, DataC may transfer Customer’s Personal Data to the US, in
which case DataC shall ensure that the recipient of the Personal Data is
certified in accordance to the EU-US Privacy Shield entered by and between
the US Department of Commerce and the European Commission. To learn
more about the Privacy Shield program, please visit
When transferring collected Personal Data outside of the EEA, DataC shall
ensure the application of the appropriate safeguards. If the Customer wishes
to receive a copy, please contact us as instructed below

4- Security

DataC will take appropriate legal, organizational, and technical measures to
protect Personal Data consistent with applicable privacy and data security
laws. Security measures shall be applied in order to protect Personal Data
from involuntary or unauthorized processing, disclosure or destruction.
Recipients have been made aware that Personal Data may only be used in
accordance with the purposes described in this notice.

Customer’s Personal Data is only accessible to authorized persons, who are
bound by confidentiality obligations.

5- Integrity and retention of the Personal Data

DataC will retain Personal Data for the period required or permitted by
applicable law, but no longer than it is reasonably necessary in order to
achieve the purposes for which the Personal Data was collected.
DataC takes reasonable steps to ensure that the Personal Data we process is
reliable for its intended use, accurate, and complete as necessary to carry out
the purposes described herein

6- Customer’s rights in regarding to the collection of
Personal Data

Customer has the right to:

  • Request access and/or corrections to Personal Data collected about him/her;
  • Have the Personal Data erased, removed and/or transferred from our active
    files in line with provisions of applicable regulations;
  • Request restriction of processing of his/her Personal Data or to object to such
  • Receive the Personal Data concerning him/her in a structured, commonly
    used and machine-readable format where technically feasible;
  • Raise concerns about the handling of his/her Personal Data to us;
  • Withdraw his/her consent for the processing of personal data, where the
    Personal Data is being processed on the basis of the consent, without
    affecting the lawfulness of the processing before the withdrawal.
    In order to exercise any rights referred herein the Customer is required to
    submit a written application to DataC. DataC has the right to decline this
    application by justifying the reasons for the refusal.
    If Customer considers that his/her rights have been infringed, the Customer is
    entitled to lodge a complaint with the Estonian Data Protection Inspectorate.

The collection of certain Personal Data referred herein may be required under

the law and/or inevitably necessary for the provision of service to the

Customers (such as data necessary for the verification of the Customer).

Failure to provide data may result in adverse consequences, such as, our

inability to comply with our obligations under law. The Customer is welcome to

ask for clarifications regarding the obligation to submit any specific Personal

Data and also about possible consequences arising from the failure to provide

the Personal Data

7-Cookies and tracking technologies

DataC is using automatically collected information and other information
collected within its website through cookies and similar technologies for the
following purposes:

  • Store authentication information and protect Personal Data from third parties;
  • Personalize our Service, help remember Customer’s choices within the
    website, understand and save Customer’s preferences for future visits;
  • Provide customized advertisements, content and information;
  • Track Customer’s entries, submissions, and status in any promotional or other
    activities on the Service
  • Monitor and analyze the effectiveness of the Service;
  • Compile aggregate data about site traffic and site interactions in order to offer
    better site experiences and tools in the future.
    Cookies are small text files that a website or its service provider transfers to
    the Customer’s computer hard drive through their website browser (if
    Customer allows) that enables the website’s or service provider’s systems to
    recognize Customer’s browser and capture and remember certain information.
    Within the website first-party and third-party cookies are in use.
    DataC may use third-party analytics tools (such as Google Analytics), to help
    us measure traffic and usage trends for the DataC service. Web analytic
    service providers analyze the usage of the DataC website and services so
    that DataC could improve and amend our website/app and function thereof.

The Customer can delete or block cookies through his/her browser settings at
any time. However, some cookies might be necessary for the functionality of
the DataC services and usage of the website. Therefore, the Customer
understands that when blocking or deleting the cookies some features within
the website might not function correctly. For more general information about
cookies please see

8- Google Analytics and ads

DataC have implemented the following Google Analytics features:

  • Remarketing;
  • Google Display Network Impression Reporting;
  • Demographics and Interests Reporting.
    We along with third-party vendors, such as Google, use first-party cookies

(such as the Google Analytics cookies) and third-party cookies or other third-
party identifiers together to compile data regarding Customer interactions with

ad impressions, and other ad service functions as they relate to our website.
Customers can set preferences for how Google advertises to them using the
Google Ad Settings page. Alternatively, the Customer can opt out by visiting
the Network Advertising initiative opt out page or permanently using the
Google Analytics Opt Out Browser add on.
We use Google Analytics to measure and evaluate access to and traffic on
the public area of our website and create user navigation reports for our
website administrators.
We take measures to protect the technical information collected by our use of
Google Analytics. The data collected will only be used on a need to know
basis to resolve technical issues, administer the website and identify visitor

9- Commercial Communication

If a Customer receives commercial emails from us, he may unsubscribe at
any time by following the instructions contained within the email or by sending
an email to
The Customer is able to view and modify settings relating to the nature and
frequency of promotional communications that they receive from us by
accessing the “Settings” section in the restricted area of the website.
The Customer has to be aware that if he/she opts-out of receiving commercial
emails from us or otherwise modify the nature or frequency of promotional
communications he/she receives from us, it may take up to five (5) business
days for us to process the request. Additionally, even after he/she opts-out
from receiving commercial messages from us, he/she will continue to receive
administrative messages from us regarding the Service.

10 – Contact Information

Should the Customers have any questions regarding this policy or processing
of Personal Data, they are welcome to contact Datac with requests, inquiries
or any complaints via email:

11- Confirmation

By accepting this privacy policy, the Customer confirms that he/she has
familiarized himself/herself with this policy, understood it and agree to its