Privacy Policy

ArbiSmart OÜ
This Privacy Policy applies to all information that the ArbiSmart OÜ Website can receive about the User while using the company’s website.

1.1 The following terms are used in this Privacy Policy:
1.1.1. « Website Administration » means authorized employees of the website
management, acting on behalf of ArbiSmart OÜ, who organize and/or perform
personal data processing, as well as determine the purposes of personal data
processing, the composition of personal data to be processed, the actions (operations)
performed with personal data.
1.1.2. « Personal data » means any information related to a person directly or indirectly
determined by an individual (a subject of personal data).
1.1.3. « Personal data processing » means any action (operation) or set of actions
(operations) performed using automation tools or without using such means with
personal data, including collection, recording, systematization, accumulation, storage,
updating (updating, modification), extraction, use, transfer (distribution, provision,
access), depersonalization, blocking, deletion, destruction of personal data.
1.1.4. « Confidentiality of personal data » – a mandatory requirement for the Operator or
other person who has access to a personal data to prevent their dissemination without
the consent of the subject of personal data or other legal grounds.
1.1.5. « User » means a person who has access to the Website, through the Internet and
using the Company’s Website.
1.1.6. « Cookies » is a small piece of data sent by a web server and stored on a user’s
computer that the web client or web browser sends to the web server each time in an
HTTP request when they try to open the page of the corresponding site.
1.1.7. « IP-address » is a unique network address of a node in a computer network built
using the IP protocol.

2.1. The User’s use of the company’s website means acceptance of this Privacy Policy
and the terms of processing of the User’s personal data.
2.2. In case of disagreement with the terms of the Privacy Policy, the User must stop
using the company’s website.
2.3. This Privacy Policy applies only to the ArbiSmart OÜ website. The site of the
company does not control and is not responsible for the sites of third parties to which the
User can click on the links available on the company’s website.
2.4. The website administration does not verify the authenticity of the personal data
provided by the User to the company’s website.

3.1. This Privacy Policy establishes the obligations of the Administration of the
company’s website to not disclose and provide a regime for protecting the confidentiality
of personal data that the User provides upon the request of the Website Administration
when registering on the company’s website.
3.2. Personal data authorized for processing under this Privacy Policy is provided by the
User by filling out the registration form on the ArbiSmart OÜ Website in the
Registration section and includes the following information:
3.2.1. surname, name of the User;
3.2.2. contact phone number of the User;
3.2.3. e-mail address;
3.2.4. social accounts of the User;
3.2.5 Country of the user
3.2.6 Phone number of the user
3.3. The company’s website protects data that is automatically transmitted during the
block scanning and when visiting pages on which the statistical system script is installed:
● IP Address;
● information from cookies;
● information about the browser;
● access time;
● page address;
● User’s activity on the page;
● referrer (address of the previous page).
3.3.1. Disabling cookies may result in the inability to access parts of the website of the
company that require authorization.
3.3.2. The company’s website collects statistics about the IP-addresses of its visitors.
This information is used to identify and solve technical problems, to control the legality of
financial transactions.
3.4. Any other personal information not specified above (transaction history, browsers
and operating systems used, etc.) is subject to secure storage and non-distribution,
except as provided in cl. 5.2. of this Privacy Policy.

4.1. The administration of the company’s website may use the User’s Personal Data for
4.1.1. Identification of the User registered on the company’s website for financial
transactions remotely from ArbiSmart OÜ.
4.1.2. Granting the User access to the personalized resources of the Company’s
4.1.3. Association with feedback of the User, including sending notifications, information
letters, inquiries regarding the use of the Company’s website, rendering services,
processing requests and applications from the User.
4.1.4. Determining the location of the User for security, prevention of fraud.
4.1.5. Confirmation of the authenticity and completeness of the personal data provided
by the User.
4.1.6. Create an account for financial transactions, if the User has agreed to create an
4.1.7. Notifications to the User from the company’s Website about news and actions.
4.1.8. Processing financial operations of the User.
4.1.9. Granting effective client and technical support to the User in the event of problems
related to the use of the Company’s Website.
4.1.10. Providing the User special offers, information on financial transactions,
newsletters and other information on behalf of the company’s website, by means of
e-mails and SMS.
4.1.11. Implementation of advertising activities with the consent of the User.

5.1. The processing of the User’s personal data is carried out without any time limit, in
any legal way, including in personal data information systems using automation tools or
without using such means.
5.2. The User agrees that the Website Administration has the right to transfer personal
data to third parties, in particular, electronic mailing services for letters and SMS, solely
for the purpose of fulfilling the obligations of the company to the User.
5.3. In case of loss or disclosure of personal data, the Website Administration informs
the User about the loss or disclosure of personal data.
5.4. The Website Administration takes necessary organizational and technical measures
to protect the User’s personal information from unauthorized or accidental access,
destruction, modification, blocking, copying, distribution, as well as from other illegal
actions of third parties.
5.5. Website Administration together with the User takes all necessary measures to
prevent loss of funds or other negative consequences caused by loss or disclosure of
the User’s personal data.
5.6. The Company does not share or sell our clients’ personal information to any third. All contact that
we make with our clients is related to your account and notifications relating to transactions or other
changes. Any communication that we make that is for marketing or not related specifically to your
account will come with an unsubscribe option included. You will always be able to opt out of any type of
communication from us, except for specific account notifications.

6.1. The User is obliged to:
6.1.1.Provide information about the personal data required for the use of the Company’s
6.1.2. Update, supplement the provided information about personal data in case of
changing this information.
6.2. The Website Administration is obliged to:
6.2.1. Use the information received solely for the purposes specified in cl. 4 of this
Privacy Policy.
6.2.2. Ensure that confidential information is kept secret, not to disclose without the prior
written permission of the User, as well as not to sell, exchange, publish or disclose other
personal data of the User, except for cl. 5.2. of this Privacy Policy.
6.2.3. Take precautions to protect the privacy of the User’s personal data in accordance
with the procedure normally used to protect such information in the existing business.
6.2.4. Block personal data related to the relevant User from the moment of request or
request of the User or his legal representative or authorized body for protection of the
rights of subjects of personal data for the verification period, in case of revealing
unreliable personal data or illegal actions.

7.1. The Website Administration, which has not fulfilled its obligations, is liable for losses
incurred by the User in connection with the misuse of personal data.
7.2. In case of loss or disclosure of Confidential Information, the Website Administration
is not responsible if this confidential information:
7.2.1. Became public property before its loss or disclosure.
7.2.2. Was received from a third party until it was received by the Website
7.2.3. Was disclosed with the consent of the User.

8.1. Before applying to the court with a claim for disputes arising from the relationship
between the User of the company’s website and the Website Administration, it is
mandatory to file a claim (a written proposal for the voluntary settlement of the dispute).
8.2 .The receiver of the claim within 30 calendar days from the date of receipt of the
claim, shall notify the applicant in writing of the claim about the results of the
examination of the claim.
8.3. If the agreement is not reached, the dispute will be referred to the judicial authorities
for consideration.

9.1. The Website Administration has the right to make changes to this Privacy Policy
without the consent of the User.
9.2. The new Privacy Policy comes into effect from the moment it is posted on the
company’s website, unless otherwise provided for in the new edition of the Privacy
9.3. Any suggestions or questions about this Privacy Policy should be reported to the
technical support of the company’s website.
9.4. The current Privacy Policy is posted on ArbiSmart OÜ website

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