Sovnet OÜ. Privacy Policy

Last updated March, 408 (2023 CE)

This Privacy Policy of Sovnet Inc. (“Sovnet,” “us,” “we,” and “our”) describes the information we collect about you when you access our website or web application, enter into agreements with us, use our services and products, send us communications, or otherwise engage with us, and what we do with such information. Any references to Sovnet in this Privacy Policy also refer to its wholly owned subsidiaries. This Privacy Policy covers all of our services and products and all methods by which you may access our website or our web and mobile applications.

By opening an account with us and utilizing our services, products, website, or web application, you agree to the terms of our Privacy Policy. If you do not agree to the terms of our Privacy Policy, you cannot use our services or products and should not access our website or our web and mobile applications.

We understand that privacy is an important issue to you, and we respect the privacy of our consumers, clients, and users. We aim to protect the security and confidentiality of Personal Information about you that we acquire.

Personal Information We Collect:

For the purposes of this Privacy Policy, Personal Information is information that can reasonably identify, relate to, describe, be associated with, or reasonably be associated with a particular individual or household. Personal Information also includes information that may be classified as “Personal Data” or “Personally Identifiable Information” in some jurisdictions. This Privacy Policy does not apply to anonymized or de-identified data that cannot be used to identify you.

We may collect, store, use, and transfer the following types of Personal Information:

Identity Data such as name, mailing address, email address, telephone and mobile number; date of birth, geolocation, government issued identification information (e.g., driver's license, social security number, tax identification number, passport information), age, gender, nationality;

Transaction Data such as cryptocurrency wallet address(es), information relating to your Sovnet account and cryptocurrency trading transactions and related information for deposits or withdrawals, credit card information (e.g., last four digits of card number, expiration date, card status), credit card payment information (e.g., amount, date, frequency, status, balance), information relating to credit card transactions;

Financial Data such as bank name, bank account number, bank routing number, income type, annual income amount, monthly housing expenses, information that may be received from consumer reporting agencies (e.g., credit bureau reports);

Online Data such as internet protocol (IP) address, device type and model, device keys, device location, web browser type and version, operating system (OS) type and version, device creation/modification/authentication dates, device IDs, device login history;

Communications Data such as communication preferences and contents of your communication with us (e.g., chat and email);

Audio/Visual Data such as phone conversations, photographs; and

Survey and Research Data such as survey and questionnaire responses.

Other Information We Collect

We also collect other information in the form of aggregated statistics that does not uniquely identify you as an individual. This information is referred to as “de-identified data”. We collect de-identified data when you interact with us and use our services and products. Examples may include traffic visits on the website and web application, information on the links you click, the features of our website that you use, and the types of information you upload. We may share de-identified data with our advertising and marketing service providers and partners to evaluate the effectiveness of our marketing programs. Additionally, we may use this information to analyze your usage of our website and for other research to help us improve the services and products we offer.

How We Collect Your Personal Information

Direct Interactions. You provide Personal Information when you use our services and products, open an account with us, apply for a credit card with us, request marketing information, enter a sweepstakes, or contact us with questions or requests.

Technological Interactions. When you use our services and products, use our applications, or visit our website, we may  collect Device Data and Online Data through cookies and other similar technologies. Main information on how Sovnet uses cookies and the control you can exercise through the Cookie Settings.

Third Parties. We collect Personal Information from third parties as required or permitted by applicable law. Third-party sources may include, but are not limited to, public databases, credit bureaus, identity verification partners, resellers and channel partners, joint marketing partners, advertising networks and analytics providers, social media platforms, and our Sovnet Visa Debit Card partner. We also receive Personal Information about you from third parties who you have authorized to disclose information about you that we may need for the user and borrower account (i.e., Sovnet account) opening process, to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, to effect account transactions and operations, and to provide services associated with the Sovnet Visa Debit Card. Additionally, we receive Personal Information when you link a third-party service to our services. Such linkage may include interactions with our social media sites. Third-party sites are governed by their own privacy policies, and you should review those privacy policies before using those sites.

How We Use Your Personal Information

We may collect and use your Personal Information, as required or permitted by applicable law, to:

Provision our services and products in order to meet our contractual obligations to you;

Conduct background checks for Know Your Customer (KYC) reviews and Anti-Money Laundering (AML) watchlists;

Send you notices and confirmations regarding your money/cryptocurrency transfers to and from Sovnet;

Send you confirmations and other information regarding your account transactions;

Create your account statements, maintain records of your transactions, and provide support to your account generally;

Deliver content about our services and products, and send promotional and other information to you; and

Conduct analysis regarding your usage of our services and products and the effectiveness of our marketing initiatives.

We will not use your Personal Information for purposes other than those purposes we have disclosed to you without your permission. If we need to use your Personal Information for an unrelated, new, or additional purpose, we will notify you and obtain your consent to use it for such unrelated, new, or additional purpose.

Legal Basis for Collecting and Using Your Personal Information

We rely on the following legal bases, as required by applicable law, to collect and use your Personal Information:

Where collection and use of your Personal Information is necessary for the performance of a contract (e.g., using your information to deliver a purchased service or product);

Where the collection and use of your Personal Information is required to comply with the law;

Where the collection and use of your Personal Information is necessary for our legitimate interest provided it does not override your rights and freedoms; and

Where you have given us your consent to collect and use your Personal Information.

Sharing Your Personal Information

We do not disclose your Personal Information to any third parties, except to those who require access to the data in order to perform their tasks and duties, and to share with third parties who have a legitimate purpose for accessing it. This may include, but is not limited to, any obligations of Sovnet under the USA PATRIOT Act, and in order to facilitate the execution of our clients’ cryptocurrency transactions in the ordinary course of business.

We may share, transfer, disclose, or allow access to the categories of Personal Information as outlined in “Personal Information We Collect” with the following categories of third parties:

Affiliates. We may share your Personal Information with our wholly owned subsidiaries that distribute or market Sovnet products and services in accordance with this Privacy Policy.

Sovnet Visa Debit Card Partners. We may share your Personal Information with our credit card partner and our credit card rewards partner to offer you services associated with the Sovnet Visa Debit Card, in accordance with the privacy policy applicable to the Sovnet Visa Debit Card.

Service Providers. We may share your Personal Information with financial, accounting, legal, marketing, and technology companies to provide services such as, but not limited to, data processing, administrative services, regulatory support, legal services, liquidity services, bank services, cloud storage, authentication support, payment processing, technical support, sales, client support, data hosting, marketing analytics auditors, accountants, cryptocurrency exchange and custodians, and cryptocurrency forensic analysis services.

Regulatory and Government Authorities. We may share your Personal Information with governmental entities, including, but not limited to law enforcement, regulatory agencies, and self-regulatory agencies, and other appropriate agencies.

We may share, transfer, allow access, or disclose your Personal Information to our affiliate companies and third parties to:

Administer or process a transaction, product, or service you have authorized or requested, or in the context of facilitating the execution of a transaction;

Validate client identity as required by applicable laws and regulatory requirements;

Facilitate the process for opening and maintaining client accounts (Personal Information is shared during the account opening process and shared on an ongoing basis thereafter);

Carry out or aid in certain functions, including, but not limited to, account processing, surveillance, reconciliation, execution, document retention requirements, and document dissemination;

Process payments that you have authorized;

Operate, improve, and/or market our services and products;

Transfer information to a purchaser of our business;

Resolve a deficient balance upon account closing or excessive insufficient funds in your account;

Deliver goods or services relating to promotions and special offers that require us to collect and share your Personal Information (e.g., mailing address);

Provide services, including, but not limited to, consulting, sales, client support operations, payment processing, authentication services, and technical support; and

For other purposes which may include, but are not limited to, third-party audits, which may require disclosure to third parties about your account or transactions with your prior written permission.

Other circumstances under which we may disclose your Personal Information include to:

Enforce and/or investigate violations of our agreements, policies, procedures and/or terms of use;

Help prevent potential fraud or other potentially unlawful activities and report suspected illegal activities;

Prevent physical harm or financial loss;

Comply, as necessary, with applicable laws and regulatory requirements;

Respond to legal or governmental requests or demands for information (e.g., subpoena, court order, or other legal proceedings); and

Meet national security requirements.

If an affiliate company or another third party needs access to certain Personal Information to carry out certain functions on our behalf, they do so under our instructions. Third parties with whom we share your Personal Information have their own privacy policies; however, they are expected to protect this information in a manner that aligns with the protocols described in this Privacy Policy and as applicable law may require. We do not share Personal Information with third parties for their own benefit, unless you have given us your consent.

Opting Out of Sharing Your Personal Information

In addition to the circumstances described above, from time to time, we may request your permission to allow us to share your Personal Information with third parties. You may opt out of having your Personal Information shared with third parties, under certain circumstances, or from allowing us to use your Personal Information for a purpose that is incompatible with the purposes for which we originally collected it, or subsequently obtained your authorization. If you choose to so limit the use of your Personal Information, certain features or Sovnet services may not be available to you.

Third-Party Websites

We may have links to unaffiliated third-party websites on our website. These third-party websites have their own privacy policies. We have no involvement with their policies and are not responsible for their practices. You are encouraged to review the privacy policies of all third-party websites you visit.

Marketing Communication

We, or our service providers on our behalf, may use your Personal Information to send you marketing and promotional communication that we believe may enhance your experience with our services or products, or may be of interest to you. If you do not want to receive marketing and promotional communication from us, you can opt-out at any time by contacting us (How to Get in Touch with Sovnet), or by unsubscribing via the links provided in the marketing emails.

Sale of Your Personal Information

We do not sell your Personal Information.

Personal Information of Minors

Our services and products are not intended for individuals under the age of eighteen (18). We do not knowingly collect and use Personal Information related to minors.

Use of Cookies and Other Similar Technologies

Cookies are small text files sent from a site to a user's device to store bits of information related to that user or device. First-party cookies are put on your device directly by our website, which allows us to collect analytical data and provide other useful functions that create a good user experience. Third-party cookies are placed on your device by a third party (e.g., advertiser or analytic system). The third parties who serve cookies on our site may link your Personal Information to other information they collect.

We use cookies in order to provide better service, to facilitate use of our website, to track usage of our website and services, to collect data, and to address certain security issues. When you access our website or services, we may send the cookies to your computer or phone. Your computer or phone stores the cookie in a file located inside your web browser. The cookies help us keep track of your visits to our website and your activity with our website and services to understand how you interact with us.

We may link the information collected by cookies with other information we collect from you pursuant to this Privacy Policy and use the combined information as set forth herein.

We use the following types of cookies:

Strictly Necessary Cookies allow us to provide basic website functions such as browsing capabilities and secure access.

Functional Cookies allow our website to provide enhanced functionality. For example, we use these cookies to notify you of account updates, notifications, and reminders. You may refuse to accept these cookies; however, this may affect access to certain parts of our website. Additionally, you may not be able to take advantage of personalized features.

Performance Cookies collect information about how you use our website, for example, which pages you visited and which links you clicked on. The information collected is aggregated and cannot be used to identify you.

Marketing / Analytics Cookies may be set on our website by our advertising and marketing service providers and partners. They are used to track online activities and help us provide relevant advertising, links, or other information about our services and products to users visiting other websites after visiting our website.

In addition to cookies, we use pixels to measure our marketing campaigns and to understand how users navigate and process the content on our website and interact with our services.

We may use growth, engagement, and analytic tools of third-party advertising networks such as from search engines and social media platforms.

Managing Cookies and Other Similar Technologies

Cookies

You can activate or later deactivate the use of cookies through a functionality built into your web browser. If you want to learn more about cookies, or how to control, disable or delete them, please visit https://www.aboutcookies.org/ or https://www.allaboutcookies.org/ for detailed guidance.

Security

We strive to ensure that our systems are secure and that they meet industry standards. We seek to protect non-public Personal Information that is provided to Sovnet by third parties and you by implementing physical and electronic safeguards. Where we believe appropriate, we employ firewalls, intrusion prevention, encryption technology, user authentication systems (i.e. passwords and personal identification numbers) and access control mechanisms to control access to systems and data. We endeavor to engage service providers that have security and confidentiality policies, if such service providers have access to our client’s Personal Information. We instruct our employees to use strict standards of care in handling the personal financial information of clients. As a general policy, our staff will not discuss or disclose information regarding an account except with authorized personnel of our service providers, as required by applicable law and regulatory requirements law or, pursuant to a regulatory request and/or authority.

Despite our efforts to protect the security of your information, no security system is always effective and we cannot guarantee that our systems will be completely secure.

Retention

We are required under applicable laws and regulatory requirements to retain certain information, including, but not limited to, Personal Information of clients, client profiles, identification verification materials, information we used to satisfy our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations, account information, account agreements, trade orders, trade confirmations and other agreements, account statements, and other records.

Such records are generally retained as required by law, rule or regulation, or for the minimum amount of time necessary to accomplish the purpose for which it was collected, and thereafter no longer than is permitted under Sovnet's data retention policies.

Should you decide to close your account, we may retain copies of information about you and any transactions or services in which you may have participated in accordance with applicable law and for a period of time that is consistent with such law, applicable statute of limitations, or as we believe is reasonably necessary to comply with applicable law, regulation, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our services and products, to assist with investigations, to enforce any of our terms and conditions or other applicable agreements or policies, or to take any other actions consistent with applicable law.

When Do We Store, Transfer or Process Your Personal Information Internationally?

We are committed to meeting the requirements of local data protection laws, including EU law, to the extent required. Please be aware that your Personal Information will be transferred to, processed, and stored in our data servers located within the United States. You consent to the transfer of your information, including Personal Information, to the United States as set forth in this Privacy Policy by visiting our site or using our services and products.

Your Privacy Rights

Depending on the jurisdiction where you reside, you have certain rights over your Personal Information. You may exercise these rights, based on the applicable jurisdiction, by contacting us at contact@sovnet.io Note that we may refuse to grant your requests in whole or in part, as permitted by applicable law.

If you close your Sovnet account, we will mark your account in our database as “Closed,” but will keep your account information in our database for a period of time described in “Retention”. This is necessary in order to deter fraud by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, your Personal Information will not be used by us for any further purposes, nor shared with third parties, except as necessary to prevent fraud and assist law enforcement, as required by law, or in accordance with this Privacy Policy.

Changes to Sovnet's Privacy Policy

This Privacy Policy is available on our website at www.Sovnet.com. Sovnet reserves the right to make changes to this Privacy Policy. You should review our Privacy Policy frequently. If we make material changes to our Privacy Policy, our revised Privacy Policy will be posted on our website and it will either be noted on our website that material changes have been made or we will notify our clients by email. The date of the most recent update to our Privacy Policy will be set forth in this Privacy Policy.

How to Get in Touch with Sovnet

If you have questions or concerns regarding this Privacy Policy, or if you have a complaint, you should first contact us at privacy@Sovnet.com or by calling us at 855-876-8638.

If you would like to submit a complaint about our use of your Personal Information or response to your requests regarding your Personal Information, you may contact us at complaints@Sovnet.com.

Last Updated: March, 408 (2023 CE)