Jax Holdings OU (“Company”),company incorporated and registered according to the laws of Estonia, under registration # 16032025
respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

• IMPORTANT INFORMATION AND WHO WE ARE
• THE DATA WE COLLECT ABOUT YOU
• HOW IS YOUR PERSONAL DATA COLLECTED
• HOW WE USE YOUR PERSONAL DATA
• DISCLOSURES OF YOUR PERSONAL DATA
• INTERNATIONAL TRANSFERS
• DATA SECURITY
• DATA RETENTION
• YOUR LEGAL RIGHTS
• GLOSSARY

1. IMPORTANT INFORMATION AND WHO WE ARE AND PURPOSE OF THIS PRIVACY POLICY
    
   This privacy policy aims to give you information on how Company collects and processes your personal data through your use of this website.
   This website is not intended for children and we do not knowingly collect data relating to children.
   It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
2. DEFINITIONS
    “the Data Subject” shall refer to all clients, website users, website visitors, and “you”, “your” and “yours” shall refer to all said clients of the Controller, website users and website visitors.“the Clients” shall refer to all those natural persons who make use of any of the services offered by the Controller on the web site.
    
   “the Account Holder” shall refer to any person who holds an account with the Controller;
    
   “the Website user” shall refer to all those natural persons who make use and/or access data and/or browse and/or visit the Website.
    
   “the Website” shall refer to any website, page, portal, API, application (interpreted in the widest manner possible) on the domain and/or connecting to www.Jax.network
    
   “the Website visitor” shall refer to any natural person who looks at and/or visits and/or accesses or, in any manner, views the material on the Website irrespective of the device, platform, browser, application and so on.
    
   “Controller”
   Jax Holdings OU, a company incorporated and registered under the Laws of Estonia, bearing registration number 16032025 and having its registered address at Harju maakond, Tallinn, Kesklinna linnaosa, Ahtri tn 12, 10151.
    
   We have appointed a data privacy officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact our DPO, e-mail [email protected]
    
   You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), Data Protection Commissioner of Estonia for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
3. THIRD-PARTY LINKS
    
   This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
4. THE DATA WE COLLECT ABOUT YOU
    
   Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
   We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:
   • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
   • Contact Data includes billing address, delivery address, email address and telephone numbers, website.
   • Financial Data includes bank account, payment card details and information about your income and revenue.
   • Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
   • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.
   • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
   • Usage Data includes information about how you use our website and services.
   • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
   We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.
    
   IF YOU FAIL TO PROVIDE PERSONAL DATA
   Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (i.e, to provide you with services). In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
5. HOW IS YOUR PERSONAL DATA COLLECTED?
    
   We use different methods to collect data from and about you including through:
   Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
   • Instruct us to provide you with our services;
   • request marketing to be sent to you;
   • enter a competition, promotion or survey; or
   • give us some feedback.Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies.

   Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
   • analytics providers;
   • advertising networks; and
   • search information providers.
   • Contact, Financial and Transaction Data from providers of technical, payment and delivery services. Identity and Contact Data from data brokers or aggregators.
   • Identity and Contact Data from publicly availably sources

6. HOW WE USE YOUR PERSONAL DATA
    
   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
   • Where we need to perform the contract we are about to enter into or have entered into with you.
   • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   Where we need to comply with a legal or regulatory obligation.
7. PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
    
   We have set out below list of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
   Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data.
   Please contact at [email protected] you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
   Our Purposes:
   i) To register you as a new client
   ii) Identity
   iii) Contact
   iv) Performance of a contract with you
   v) To provide our services to you including:
   – Store personal data and information and disclose these to external third parties, as defined in the Glossary below.
   vi) Manage payments, fees and charges
   vii) Collect and recover money owed to us
   viii) Financial transaction
   ix) Marketing and Communications
   x) Necessary for our legitimate interests
   xi) Necessary for our technical, analytical, KYC and AML purposes
8. PROMOTIONAL OFFERS FROM US
    
   We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
   You will receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when registered for a particular financial product or service and, in each case, you have not opted out of receiving that marketing.
9. THIRD-PARTY MARKETING
    
   We will get your express opt-in consent before we share your personal data with any company outside our Company for marketing purposes.
   1. EXTERNAL THIRD PARTIES
      Service providers acting as processors based in Europe who provide IT and system administration services, including billing.
      Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, agents and insurers based in Europe or abroad.
      Professional advisers acting as legal representatives of counterparties.
      Regulators and other authorities and agencies acting as processors or joint controllers based in Europe or abroad who require reporting of processing activities in certain circumstances.
10. OPTING OUT
     
    You can ask us or third parties to stop sending you marketing messages by contacting us.
11. COOKIES
     
    You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Policy.
12. CHANGE OF PURPOSE
     
    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at [email protected] .
    If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
    Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
13. DISCLOSURES OF YOUR PERSONAL DATA
     We may have to share your personal data with the parties set out below for the purposes set out in the list above.
    External Third Parties as set out in the Glossary.
    Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.
    We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
14. INTERNATIONAL TRANSFERS
     
    We will transfer the personal data we collect about you outside of the EEA to perform our contract with you.; and
    Where there is an adequacy decision by the European Commission thereby deeming such countries to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation; or
    Where there is not an adequacy decision by the European Commission such countries will not be deemed to provide an adequate level of protection for your personal information for the purpose of the Data Protection Legislation; and
    We have accordingly put in place measures to ensure that your personal data is treated by those third parties in a way that is consistent with and which respects the Data Protection Legislation.
15. DATA SECURITY
     
    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
    We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
16. DATA RETENTION 
    HOW LONG WILL YOU USE MY PERSONAL DATA FOR?
     
    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.
    By law we have to keep basic information about our clients (including Contact, Identity, Financial and Transaction Data) for six years after they cease being clients.
    In some circumstances you can ask us to delete your data and send us an request about it.
    In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
17. YOUR LEGAL RIGHTS
     
    Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:• Receive access to your personal data. This enables you to e.g. receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
    • Request correction of the personal data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected.
    • Request erasure of your personal information. This enables you to ask us to erase your personal data [known as the ‘right to be forgotten’] where there is no good reason for us continuing to process it.
    • Object to processing of your personal data, where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground. If you lodge an objection, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms.
    • Withdrawal of the consent that you gave us with regards to the processing of your personal data at any time. Note that any withdrawal of consent shall not affect the lawfulness of processing based on consent before it was withdrawn or revoked by you.
    In the event that you wish to complain about how we handled your personal data, please contact us at [email protected] . Valid Data Subjects Access Requests listed below will be responded up to 30 days.

    • Right to lodge a complaint
    If after complaining to the DPO you still feel that your Personal Data has not been handled appropriately, according to the law, you can lodge a complaint with the Estonian Data Protection Authority regarding the Processing of your Personal Data by us or on our behalf to Data Protection Specialist.
    Website:
    http://www.aki.ee/
    Contact email address:
    [email protected]

    According to Article 12 (3) GDPR we will provide on a request under Articles 15 to 22 to the data subject without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests.

    If any of the Personal Data we hold is incorrect or incomplete, you can request on legitimate grounds to have the information corrected, restricted or removed by writing to the DPO of our Company.

    To exercise any of your rights, or if you have any other questions about our use of your personal data, please contact the DPO by completing the Data Subject Consent Withdrawal Form.

18.  GLOSSARY  
    LAWFUL BASIS
     
    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.
19. CHANGES TO PRIVACY POLICY
     
    We may modify or amend this privacy policy from time to time.
    We will notify you appropriately when we make changes to this privacy statement and we will amend the revision date at the top of this page. We do however encourage you to review this statement periodically so as to be always informed about how we are processing and protecting your personal information.