PRIVACY POLICY
This document "Privacy Policy" (hereinafter referred to as the "Privacy Policy") represents the rules for processing and ensuring the security of personal information provided by you while using the website http://x100invest.com (hereinafter referred to as the "Site").
ATTENTION! Carefully study the Privacy Policy to know what personal information is collected on the site, for what purposes it is used, and how you can change or delete your personal information.
The invalidity of certain provisions of this Privacy Policy, if recognized by a decision of a court or other authorized state body, does not entail its invalidity as a whole.

1. General information about the Privacy Policy
1.1. The site is operated by SUOV LIMITED, reg. number 12337584, reg. address: Suite 4034 43 Bedford Street, London, United Kingdom, WC2E 9HA (hereinafter “the Company” or “we”, “our”, “us”, etc.).
1.2. We collect and use your personal data only to the extent necessary to provide access to the Site and its services, content and services, as well as for the implementation of our business goals. If you still have any questions regarding the processing of your personal data, please contact our data protection officer at support@x100invest.com.
1.2.1. If you are a visitor to the Site without registering on the Site, this Policy applies to you.
1.2.2. If you are a user of the Site - a user of services, products and services posted on the Site with your registration on the Site - this Policy applies to you.
1.3. This Privacy Policy informs you about the personal data collected by the Company during your visit to the Site; the purposes of using personal data, the timing of their processing; on the legal basis for the processing of personal data; applied security measures to protect personal data; on the Company's interaction with third parties; about the conditions of access to personal data, about your rights, and also informs you of contact information for you regarding gaining access, making changes or deleting personal data and for contacting any questions that you may have regarding the protection of personal data.
1.4. By accessing the Site and using it or otherwise providing us with your personal data, for example, by registering on the Site or by contacting our support service, you confirm that you have read this Privacy Policy and understand how we collect, process, use and disclose your personal data , in accordance with this Privacy Policy.
1.5. If you do not agree with this Policy or cannot comply with it, you should not start using the Site, and, accordingly, the services and content located on it.
1.6. We process your personal data only if there is a legal basis for this. Legal bases for processing include your consent, contractual necessity (i.e. processing necessary to fulfill a contract with you, such as your user agreement with us, which allows us to provide you with our services) and our legitimate interests or the legitimate interests of others (for example, our users), such as: improving or managing our products and services and activities; better understanding of your needs and interests; fulfilling your requests for products and services; providing you with information and suggestions from our side or from third parties; complying with our legal obligations, resolving disputes with users, enforcing our contracts and agreements; tax, statistical, management accounting, audit; protecting the interests of visitors and users; investigation and prevention of fraudulent, dangerous, unauthorized or illegal activities.
1.7. Further development of technology, changes in our business or legal situation, or other reasons may require changes to this Policy. Therefore, we reserve the right to make changes to this document at any time, and we ask you to regularly check its current version.
1.8. The current edition of the Privacy Policy is posted at http://x100invest.com/privatepolicy.
1.9. This Policy applies to your personal data received by the Company both before and after the introduction of this Privacy Policy.
1.10. The company does not always have the opportunity to check the accuracy of the personal data provided by you, and is not able to assess your legal capacity. However, the Company assumes that you act in good faith, prudently, provide reliable and sufficient personal data and make every effort to keep such data up to date, and do not violate the rights of third parties.

2. Your consent.
2.1. You provide your personal data on a voluntary basis. You are not required by law to provide us with your personal data. If you do not want to provide us with your personal data, then such a decision will not lead to any consequences for you, except for those that you will not be able to use our services and services in full.
2.2. By visiting our Site, using the services of the Company and / or by registering on our Site, you confirm that you are an adult and fully capable person, and that you express your unambiguous, complete and unconditional consent to the terms and conditions of this Policy, as well as that we may collect, process, store, use and disclose your personal data in the manner set out in this Privacy Policy.
2.3. You can change or withdraw your consent to the processing of your personal data at any time by contacting us by e-mail support@x100invest.com. In some cases, changing or withdrawing consent may affect your ability to use the Site.
2.4. You also agree that we can contact you by email or SMS (if you have provided them to us) on all issues related to your use of the Site.
2.5. This Policy should be applied both separately and together with the user agreement (offer) posted at: http://x100invest.com/offer. By accepting the terms of the said Agreement (by accepting the offer), you give your consent to the processing of your personal data on the terms set forth in this Policy. Your action, marked with a checkmark in the appropriate box, and your use of this Site means that you agree to the processing in question, as described in this Privacy Policy. Our records of your agreement to this Privacy Policy, its date and any subsequent changes to this Privacy Policy will be considered as conclusive and written confirmation of your consent.
2.6. If you change your personal data that you provided to us, you agree and undertake to immediately transfer your new personal data to us, and if such a transfer is not carried out, you bear the risk of possible negative consequences.

3. User's personal information and its processing.
3.1. "Personal information and / or personal data of a user" means any information that relates directly or indirectly to you as a user of the site, including information:
- which is associated with the User as a specific person (for example: name, email, date of birth, photo, etc.);
- which you provide yourself when filling out questionnaires, registration forms and applications on the Site;
- which is transmitted by your browser and other electronic devices (for example: IP address, strings from a cookie);
- as well as other information about the User received from third parties (for example: when moving from the Partner Sites).
For example, this includes information that can independently identify you, such as your name, contact information, IP address, strings from a cookie or device identifiers, as well as information that cannot independently identify you, but is stored by us together with such identifying data, whether it is how you use our services or the country in which you are located at the time of using them.
3.2. The processing of personal data is any action (operation) or a set of actions (operations) performed using automation tools or without using such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (update, change), extraction , use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
3.3. We do not knowingly collect personal information about minors. If you are the parent or legal guardian of a minor and you become aware that your child has provided us with Personal Information, please let us know. If we learn that personal data of a minor has been transferred to us, we will take measures to delete this information. In the event that you have information that personal data about / from minors may have been transferred to us, please contact us.
3.4. We process your personal data in strict accordance with the Federal Law of the Russian Federation of 27.07.2006. No. 152-FZ "On Personal Data" (applicable to citizens of the Russian Federation) and the General Regulation of the European Parliament and of the Council of the European Union 2016/679 of April 27, 2016 on the protection of individuals in the processing of personal data (General Regulation on the Protection of Personal Data - General Data Protection Regulation, hereinafter referred to as "GDPR"), as well as in accordance with other applicable privacy and data protection laws. According to the GDPR, we are the controller and you are the data subject.

4. What personal information is collected on the Site.
4..1. Information provided by you personally.
That is, Personal information that you provide yourself when registering on the Site, filling out questionnaires, registration forms and applications on the Site, including, but not excluding:
• name;
• E-mail address;
• phone number;
• data of an identity document (solely for the purpose of fulfilling agreements with the User);
• registration address and place of residence (solely for the purpose of fulfilling agreements with the User).
4.1.1. Legal basis for the processing of this data: subparagraph 5 of Art. 6 of the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" and Article 6, paragraph 1, subparagraph b GDPR - the emergence of pre-contractual and contractual obligations between you and us.
4.1.2. The duration of storage of the data yourself provided by you is equal to the term of the agreement (user agreement) or longer in accordance with the applicable limitation periods, as well as if such requirements are established for us by applicable law (tax, statistical, management accounting, audit, etc.).
4.2. Information generated or received automatically.
Data that is automatically transmitted when using the Site using the software installed by the user, including, but not excluding:
• IP address and device identifiers (computer, smartphone, tablet, etc.); operating system and its versions; the site from which the transition to our Site was made; cookie; type, connection parameters and settings of Internet browsers; date, time and duration of the visit to the Site; geolocation.
• statistics on the use of the functions of the Site, as well as other technical information.
4.2.1. Legal basis for the processing of this data: subparagraph 7 of Art. 6 of the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" and Article 6, paragraph 1, subparagraph f of the GDPR - protection of the legitimate interests of our Company to ensure the functioning and security of the Site, provided that your interests as a data subject do not prevail.
4.2.2. Duration of storage of the specified data: data on the IP-address is deleted at the end of the session of access to the Site. We may process the rest of the data on the use of the Website in a pseudonymised form for statistical purposes and to improve our Website. This data is not stored together with other personal data. Data is deleted as soon as it is no longer required to achieve the purpose for which it was collected. Deleting data from logs is done automatically after the log file is created. In analytical services, this data in a pseudonymized form can be stored indefinitely until it is overwritten by new data. Hereinafter, pseudonymisation means the processing of personal data in such a way that personal data cannot be associated with you without the use of additional information, provided that such additional information is stored separately and is subject to technical and organizational protection measures. If you provide data for the purpose of concluding a user agreement or other agreement, the storage period of your data is equal to the storage period for the term of the agreement or longer in accordance with the applicable statute of limitations, as well as if such requirements are established for us by applicable law.
4.3. Information received from third parties.
Sometimes third parties provide us with information about you, depending on how you choose to interact with us.
4.3.1. Legal basis for processing the information provided: subparagraph 1 of Art. 6 of the Federal Law of the Russian Federation No. 152-FZ "On Personal Data" and Article 6, paragraph 1, subparagraph a of the GDPR - your consent.
4.3.2. The duration of storage of the information provided depends on the specific category of personal data.

5. Who processes personal information.
5.1. To ensure the use of the Site and the provision of services sold on the Site, your personal information is processed by the Site Operator - SUOV LIMITED, reg. number 12337584, reg. Address: Suite 4034 43 Bedford Street, London, United Kingdom, WC2E 9HA.

6. What is the legal basis and purpose of processing your Personal Information.
6.1. The site operator is not entitled to process your Personal Information without sufficient legal grounds. Therefore, the Site Operator processes your Personal Information only in order to:
• To keep in touch with you (to send letters, notifications, requests and other information regarding the use of the Site, the provision of services, the fulfillment of the assumed obligations).
• Process your requests and applications, respond to your other requests;
• Comply with the agreements between you as a user or customer of services and the Site Operator;
• Ensure the conclusion on the Site and the execution of agreements between you and third parties that provide services sold on the Site;
• Improve the quality of the services offered on the Site, usability of the Site;
• Send you advertising messages and advertising information (including via mobile communications and e-mail);
• Ensure the safety and reliability of the Site (timely identify and block threats in order not to allow intruders to harm you, other users of the Site, the Site Operator and the public interest).
• Comply with legal requirements;
• Protect the legitimate interests of the Site Operator, as well as third parties providing services on the Site (when this does not contradict your rights).
6.2. The site operator also processes your information in other cases when it is based on your consent (written or electronic, given by ticking the box for consent to the processing of personal data).

. How to change, delete, supplement your personal information, as well as get information about what information about you is collected
and is stored by the Site Operator.

7.1. To change, delete, supplement personal information, as well as receive information about what information about you is collected and stored by the Operator, you can at any time:
• Send an email to support@x100invest.com with a corresponding request
or
• Contact the support service (using the contact details indicated on the Site).

8. When it is possible to transfer the user's personal data to third parties.
8.1. The site operator does not disclose the data you provided to other companies, organizations and individuals not associated with the Site. The exceptions are the following situations:
• The user has consented to such actions;
• Based on a request from a court or other authorized state body within the framework of the procedure established by law.
• The transfer is necessary for you to receive the services purchased on the Site or to fulfill a specific agreement or contract between the Site Operator and you. Your use of the Site includes the transfer, storage and processing of your data inside and outside your country of residence (cross-border processing). We may provide personal data to related parties of the Company and other proxies for processing on our behalf. Such processing is carried out in accordance with our instructions, the Privacy Policy and other applicable privacy and security requirements. We provide access to your Personal Data to employees within the Company, as well as to third-party service providers for the purpose of processing or storing data. These third party service providers may include, but are not limited to: payment systems, web analytics companies, call centers, data management services, accountants, law firms, auditors, email service providers, maintenance and hosting service providers for the Site. We conclude contracts with such suppliers in accordance with the requirements of Art. 28 GDPR, provided that these providers act as data processors. The providers of these services may be located both within the European Union or the European Economic Area, and outside them. When entering into contracts with service providers, we take appropriate measures in accordance with applicable law to ensure the protection of the transmitted data. Such measures include the use of strict contractual restrictions and service providers' obligations to maintain the confidentiality and security of the data processed. All of our service providers are prohibited from using your data for their own purposes or for any other purpose. As far as possible, we obtain a guarantee that personal data is processed in accordance with the provisions of the GDPR, even if the data is processed outside the European Union or the European Economic Area, in countries where the proper level of data protection is not guaranteed by other laws and where it does not apply. European Commission decision on the adequacy of data protection measures.
• In other cases provided for by the legislation of the country in whose jurisdiction you are located.
• If you conclude agreements on the site (acceptance of offers) with companies that provide services sold on the Site, the data you provide is transferred (including cross-border data transfer) to companies with which you have entered into agreements in order to identify you as a Customer of services (Client).
• We have the right to buy, sell or otherwise transfer our assets. Therefore, if the Site is transferred to the ownership or management of a new owner, your personal data may be transferred to the new owner. You acknowledge the possibility of such transfers and that any new owner of our Company or our assets may continue to use your Personal Data in accordance with this Policy.
8.2. You provide and confirm your consent to the transfer of your personal data to third parties for their use with those specified in clause 8.1. conditions without additional written consent from you and without prior notification of such transfer.
8.3. We do not sell or transfer your personal data to third parties for marketing purposes without first obtaining your permission to do so.

9. How the Site Operator protects the user's personal data.
.1. The website operator ensures reliable protection of your data.
The site operator does everything possible to protect the users of the Site from unauthorized attempts to access, modify, disclose or destroy the data stored by us.
Among other things, the Website Operator takes the following measures:
• Methods of collecting, storing and processing data, including physical security measures, to prevent unauthorized access to systems are constantly being improved;
• Restricts employees, contractors and agents access to personal information, and imposes strict contractual obligations on them, for violation of which there are penalties or dismissal;
• The latest technical and digital methods of data protection, two-factor authentication, double passwords are used;
• Effective anti-virus programs are applied.

10. How regulatory requirements are complied with and interactions with regulatory bodies.
10.1. The policy was developed in accordance with the Federal Law of the Russian Federation dated 27.07.2006. No. 152-ФЗ "On Personal Data" (hereinafter - ФЗ-152) and the Provisions of the General Regulation on the Protection of Personal Data of the European Union (GDPR).
10.2. The site operator regularly updates the Privacy Policy, brings the Policy into compliance in case of changes in the legal regulation of these legal relations and processes user information in accordance with it.
10.3. Your personal data are stored on servers in Germany. Personal data of citizens of the Russian Federation is stored on servers in the territory of the Russian Federation.
10.4. All requests from regulatory bodies are accepted either electronically by e-mail support@x100invest.com, or at the registration address of the Site Operator. The request is processed within five working days.

11. What rights does the User have?
11.1. At any time, the User has the right:
• Get acquainted with the provided personal data. You can also request a copy of your personal data.
• Request the transfer of your personal data to another controller, but only to the extent technically possible.
• Make changes, updates, additions to the provided personal data.
• Submit a request to delete personal data.
• To object to the processing of personal data for certain purposes and / or in certain ways.
• Contact the Site Operator with a request to restrict the processing of personal data.
• Refuse from direct marketing and advertising materials sent by the Site Operator.
• Withdraw your consent to the processing of personal data. Refusal will not affect the legality of the data processing that was carried out prior to the refusal, nor will it affect other legal data processing other than consent.
• Submit a complaint to the authorized authority exercising supervision in the field of personal data protection about the collection and use of personal data. If you would like to make a complaint about the way we handle your personal information, you can contact us and we hope we can resolve any problems you may have. But, of course, you can also contact the supervisory authority at your place of residence, or at the place where you think that a violation could have occurred.
• Exercise other rights provided for by applicable law.
11.2. Please note that under some circumstances we may not be able to fully comply with your requests or may ask you to provide additional information in connection with your request, which may represent personal data, for example, if it is necessary to confirm your identity or the nature of the request ... Or, for example, if in order to fulfill your request, it will be necessary to disclose personal data about a third party, or if you ask us to delete data that we are required by law to store or have a legal basis for the further storage of data. However, in such situations, we will definitely inform you of our decision.
11.3. For all questions regarding the implementation of the User's rights, you can contact us at any time by e-mail: support@x100invest.com

12. Responsibility of the Site Operator. User claims.
12.1. The site operator is not responsible for the loss of personal data due to the actions of third parties, including the hosting provider of the Site Operator, software errors, unreliability of communication channels, as well as illegal actions of hackers and other intruders.
12.2. In case of detection of loss (leakage) of personal data, the Site Operator undertakes to notify the user within 24 hours from the moment of establishing the fact of loss, and also make every possible effort to reduce the negative consequences and identify those responsible.
12.3. Before going to court with a claim for disputes arising from the relationship between the User and the Site Operator, it is mandatory to submit a claim (a written proposal for a voluntary settlement of the dispute). The recipient of the claim within 30 (thirty) calendar days from the date of receipt of the claim shall notify the applicant of the claim in writing about the results of the consideration of the claim. If an agreement is not reached, the dispute will be referred to a judicial authority in accordance with applicable UK law.

13. Terms of processing personal data.
 13.1. The processing of your personal data is carried out during the period of your use of the Site, during the processing of your application for the provision of services, as well as within 6 months after the expiration of the above events.
13.2. If you conclude agreements with the Site Operator, purchase services on the Site, the processing of your personal data is carried out during the period of validity of the agreements, as well as within three years from the date of termination of the above agreements.

14. Updating this Policy.
14.1. This Policy is subject to change. The site operator has the right to make changes at its discretion, including, but not limited to, in cases where the relevant changes are related to changes in applicable law, as well as when the corresponding changes are related to changes in the operation of the Site. Your continued use of the Site after any changes to the Policy will mean your agreement to accept its changed terms.
14.2. The current edition is posted on the Site.
14.3. The operator of the site does not intend to restrict the user rights described in this Policy in the future without the explicit consent of the user.
Our contact details:
Operator (Controller) of personal data
SUOV LIMITED,
reg. number 12337584,
reg. Address: Suite 4034 43 Bedford Street,
London, United Kingdom,
WC2E 9HA
Email: support@x100invest.com
This Privacy Policy
applied on the website http://x100invest.com from 08.10.