Privacy Policy


PRIVACY AND COOKIE POLICY - MOJSKRBNIK PLATFORM


(Version 2.0.; Date 3.02.2020)

 

 

MS Platform is designed as an effective and comprehensive tool for managing your assets and property for the very reason that it is based on the personal data You provide us. Your personal data constitutes the essence of our Services, and we therefore thoroughly endeavour to provide You with clear and accurate information on all issues related to your personal data. At the same time, we endeavour to ensure that your personal data is stored securely, and we take appropriate safety measures for this purpose.

It is important that You read this Privacy Policy before You become our user, so that You will be confident when using our Services regarding your personal data. Should You have any questions in this connection, please get in touch with us by e-mailing us at team@mojskrbnik.com.

1. Vezovišek & Partnerji as a data controller

This Privacy Policy describes how Vezovišek & Partnerji as a data controller collects and processes your personal data we collect from You or that You provide to us when You use MS Platform and related Services. It also describes your rights regarding personal data and the manner of their execution.

Vezovišek & Partnerji respects the privacy of users and undertakes to protect the acquired personal data in accordance with the applicable legislation governing the protection of personal data.

2. DPO

Vezovišek & Partnerji appointed a Data Protection Officer, who You can contact through: dpo@vezovisek.si. 

If You wish to exercise any of the rights set out above or should You have any questions regarding processing of personal data, please contact our DPO at the e-mail address above, or 

via post Vezovišek & Partnerji d.o.o., for Data Protection Officer, Ameriška ulica 8, 1000 Ljubljana, Slovenia.

3. Information we collect and purpose of use

• Registration Information: To register to use MS Platform and related Services and to communicate with us You supply us with your name, surname, email, country of residence. You should also create a password for accessing your MS account.

• Asset and Investment Information: In order to make it possible for You to use the relevant Service, Portfolio allows You to enter the information (type and number of units) about your specific investments (e.g. savings bank account, brokerage account for securities, mutual fund account, separate insurance and pension accounts, private equity, gold, Crypto Assets). 

• Account Information: When You provide information on your account(s), we may access, store and process your Account Information held by your account provider. With the purpose of using the Service concerned, Account Information includes, for example, your account details, account transaction information and account balance.

• Technical Information: When You browse our Website or APP, we automatically collect some technical information about your visit to our Website or APP, including, but not limited to, IP address, language settings, browser settings, time zone settings, operating system and platform and screen resolution, geographical location and how You use our Website or APP, including page response times, download errors, entry and exit methods. We collect such data to improve our Services and for general business development purposes.

4. How we collect your Information

We use different sources to collect data from and about You including:

• Your interactions: You may provide us your personal data by using MS Platform and related Services. 

• Third parties sources: We may receive personal data about You from third, for example your Account Information from Salt Edge Inc. 

• Technology: When You browse our Website or App, we automatically collect some technical information about your visit to our Website or App by using cookies and other similar technologies.

5. Legal ground

Vezovišek & Partnerji processes personal data based on the following legal bases:

• Registration and KYC Information, Asset and Investment Information, Crypto assets Information, Account Information, Information on finances and wealth and Purchase Information: performance of an Agreement with you.

• Technical Information: legitimate interest.

6. Information we share with others

We only share your personal data in cases in which it is necessary for us to provide our Services. We require third-party providers as personal data processors to respect your privacy and the security of your personal data. Third party providers are authorised to use your personal data only as necessary to provide these services to us, and via contractual agreements that establish their responsibilities to protect your data. Personal data processors, to whom we disclose your personal data, are as follows:

• Salt Edge Inc. provides Account Information to Vezovišek & Partnerji and yourself, using your bank account details.

The Privacy Policies of Salt Edge Inc. is linked below, and form part of the basis of our contracts with them:

• Salt Edge’s Privacy Policy can be found here: https://saltedge.com/pages/privacy_policy

We may also have the interest or obligation to share your personal data to third parties in the following cases:

• To state authorities and regulators, if requested. 

• To our professional advisers, who provide different kind of consulting services.

• If Vezovišek & Partnerji is involved in a merger, acquisition, or sale of all or a portion of its assets, You will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices You may have regarding your personal information.

7. How long do we keep information about You

When You choose to close your Account, we delete all information about You within 30 days, except those, which we need to keep following relevant legislation, for example, purchase information due to requirements in tax legislation and consumer protection. We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

8. Your rights

Under certain circumstances, You have the following rights in relation to your personal data:

• The right to be informed: You have the right to be informed about the collection and use of their personal data.

• The right of access: You have the right to access their personal data.

• The right to rectification: You have the right to have inaccurate personal data rectified, or completed if it is incomplete.

• The right to erasure: Under certain circumstances, You have the right to have personal data erased.

• The right to restrict processing: Under certain circumstances, You have the right to request the restriction or suppression of their personal data.

• The right to data portability: Under certain circumstances, You have the right to request the transfer of your personal data to You or to a third party.

• The right to object: Under certain circumstances, You have the right to object to the processing of your personal data.

• Right to complaint: You have the right to lodge a complaint with a supervising authority.

9. Security

All personal data will be stored in databases and storage accounts located in Microsoft Data Center, Dublin, Ireland.

We take the security of your personal data very seriously and have appropriate physical, technical and administrative procedures in place to help protect your personal data from unauthorized access, use or disclosure. 

We use a number of data security measures to ensure the confidentiality and integrity of personal data. We strive for the complete safety of personal data, however, given the nature of the Internet, it is necessary to draw attention to the fact that the complete protection of data against access by third parties is not possible and that, exceptionally, unauthorized intrusion of third parties can occur.

10. Changes to Privacy Policy

We may need to modify this Privacy Policy from time to time, for example to reflect changes in our Services or as required by our regulators. You are deemed to accept and agree to be bound by any changes to the Privacy Policy when You use the Website, App, MS Platform or the Services after those changes are posted.

Cookies

1. What are cookies?

For its operation our MS Platform relies on cookies. Cookies are small files with strings of letters and numbers, which the website loads to the User’s device, when the User accesses the MS Platform. Their aim is to identify individual devices used by Users to access the Website. Storing of cookies is controlled by the User’s web browser, while the User can restrict or disable the use of cookies through browser settings. 

As detailed below, some cookies are necessary for the operation of the Services, however, the Website also uses cookies to offer more customer-tailored online services. With their help the MS Platform recognises and stores User’s personal preferences and interests, which can be used to provide more efficient browsing of the Website and more relevant content to the User. The information about cookies used by the Website are explained below.

Unless stipulated otherwise, Vezovišek & Partnerji will not share the information collected through cookies with third parties, while all personal User information are processed anonymously and their privacy is strictly protected in accordance with applicable legislation.

Vezovišek & Partnerji can amend or supplement these rules concerning the Cookies, while the amendments will be available as soon as possible.

2. Cookies used by www.mojskrbnik.com

2.1. Cookies, urgently required for the operation of the Website

These are cookies that are required for the operation of Website. They include, for example, cookies that enable You to log into secure areas of our website and enter into transactions as available on MS Platform. Without these cookies the User cannot use the MS Platform, and MS could not provide or facilitate all the services, available through the MS Platform.

The Cookies include

The above-listed cookies cannot be disabled as they are intrinsically linked to the operation of the MS Platform, therefore the User does not have to grant a consent for the operation and use of such cookies.

2.2. Analytical/performance cookies

Analytical/performance cookies allow us to recognise and count the number of visitors on Website and to see how visitors move around Website when they are using it. This helps us to improve the way Website works, for example, by ensuring that users are finding what they are looking for easily. For use of these cookies Vezovišek & Partnerji will need and ask You for your consent. 

These cookies include:

Google: Measuring the number of visitors on Website by Google Analytics anonymously, without identifying individual visitors. You can opt out of Google Analytics without affecting how You visit Website. For more information on Google Analytics, please click here.

GetResponse: Forms. 

2.3. Targeting cookies 

These cookies record your visit to Website, the pages You have visited and the links You have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. For use of these cookies Vezovišek & Partnerji will need and ask You for your consent. Vezovišek & Partnerji may also share this information with third parties for this purpose.

Google; Measuring the number of visitors on Website by Google Analytics anonymously, without identifying individual visitors. You can opt out of Google Analytics without affecting how You visit Website. For more information on Google Analytics, please click here.

3. Acceptance and consent for the use of cookies

By visiting the www.mojskrbnik.com website, You confirm that You are familiar with the use of urgent cookies, required for the operation of the website, the use of which does not require the User’s consent or approval. 

By clicking “I Agree” after your first visit of the Website, You express your agreement with the use of analytical/performance cookies and targeting cookies.

The deletion of cookies stored during your visit of this website is possible at your browser’s cookie settings. 

For information on your browser’s cookie settings check your browser’s instructions: Firefox / Chrome / Internet Explorer / Opera / Safari.