Last updated on June 14, 2023
This privacy notice for DIGTL Trust Kommanditbolag (“DIGTL Trust KB”, Company”, “we”, “us” or “our”), describes how and why we might collect,
store, use and/or share (“process”) your information when you use our services (“Services”), such as when we offer you asset management services.
Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at digtltrust@digtl.co.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process?
When you visit, use or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We may receive information from public databases, marketing partners, social media platforms, and other outside sources. Learn more about information collected from other sources.
How do we process your information?
We process you information to provide, improve and administer our Service, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with you consent. We process your information only when we have a valid legal reason to do so. Learn more about how DIGTL Trust KB process your information.
In what situations and with which parties do we share personal information?
We may share information in specific situations and with specific third parties. Learn more below about when and with whom we share your personal
information.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Lean more below about your privacy rights.
How do you exercise your rights?
The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
TABLE OF CONTENTS
1. WHAT INFORMATION DO WE COLLECT?
2. HOW DO WE PROCESS YOUR INFORMATION?
3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL
INFORMATION?
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
5. HOW LONG DO WE KEEP YOUR INFORMATION?
6. DO WE COLLECT INFORMATION FROM MINORS?
7. WHAT ARE YOUR PRIVACY RIGHTS?
8. CONTROLS FOR DO-NOT-TRACK FEATURES
9. DO WE MAKE UPDATES TO THIS NOTICE?
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA
WE COLLECT FROM YOU?
1. WHAT INFORMATION DO WE COLLECT?
Person information you disclose to us
In Short: We collect personal information that you provide to us. We collect personal information that you voluntarily provide to us when you
register on the Services, express an interest in obtaining information about is or our products and Services, when you participate in activities on the
Services, or otherwise when you contact us.
Sensitive information. We do not process sensitive information.
All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and device characteristics – is collected automatically when
you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes you consent.
We process your personal information for a variety of reasons, depending on how you interact with our Services, including when: (a) you have given
consent to the processing of your personal data for one or more specific purposes; (b) processing is necessary for the performance of a an agreement (in our case a Deed of Trust) which you are party or in order to take steps at your request prior to entering into a contract; (c) processing is necessary for compliance with a legal obligation to which DIGTL Trust KB is a subject; (d) processing is necessary in order to protect your vital interests or the vital interests of another natural person; and (e) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by your interests or fundamental rights and freedoms, which require protection of personal data.
3. WHEN AND WITH WHOM DO WE SHARE YOUR INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the following third parties.
We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information with, or during negotiation of, any merger, sale of company assets, financing or
acquisition of all or a portion of our business to another company.
Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice.
Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
4. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Toronto. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” Above), in and other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
5. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal
information and isolate it from any further processing until deletion is possible.
6. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from
users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from
our records. If you become aware of any data, we may have collected from children under age 18, please contact us at digtltrust@digtl.co.
7. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: You may review, change, or terminate your account at any time.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to
your Member State data protection authority or UK data protection authority.
If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent
depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
However, please not that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the
processing of your personal information conducted in reliance on lawful processing grounds other than consent.
8. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can
activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform
technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
9. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from to time. The updated version will be indicated by an updated “Revised” date and the updated version will be
effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
10. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or comments about this notice, you may email us at digtltrust@digtl.co.
11. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE
COLLECT FROM YOU?
Based on the application laws of your country, you may have the right to request access to the personal information we collect from you, change that
information, or delete it. To request to review, update or delete you personal information, please fill out and submit a data subject access request.