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Privacy Policy

General

The aim of this privacy policy is to describe how Finberry Ltd and/or EfficiencyX WealthTech Solutions SA (as relevant) (“Finberry”), both part of GAMVEGAM SA collects and processes the personal data and information that it may receive and store in the context of its business activity (the “Policy”). Other provisions may supplement this Policy in accordance with the terms of the agreement or any other contractual relationship that you or your representative might have with FINBERRY and that form an integral part of this Policy.

At Finberry, we respect your data. Our services add value, never take away. Trust us to keep it safe while providing personalized and efficient services.

It is Finberry’s policy to respect your privacy regarding any information we may collect while operating our website. This Privacy Policy applies to finberry.ai, Finberry and our affiliates (hereinafter, collectively: “us” or “we”). We respect your privacy and are committed to protecting personally identifiable information you may provide us through the website.

We have adopted this privacy policy (hereinafter: our “Privacy Policy”) to explain what information may be collected on our website, how we use this information, and under what circumstances we may disclose the information to third parties. This Privacy Policy applies only to information we collect through the website and does not apply to our collection of information from other sources.

This Privacy Policy, together with the Terms of Use posted on our website finberry.ai, set forth the general rules and policies governing your use of our website and/or services. Depending on your activities when visiting our website and/or use our services, you may be required to agree to additional terms and conditions.

Website Visitors

Like most website operators, we collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date, time, duration and number of pages viewed of each visitor request. Our purpose in collecting non-personally identifying information is to better understand how our visitors use our website. From time to time, we may release non-personally-identifying information in the aggregate, e.g., on trends in the usage of our website.

We also collect potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on our blog posts. We only disclose logged in user and commenter IP addresses under the same circumstances that we use and disclose personally-identifying information as described below.

Gathering of Personally-Identifying Information

Personal information such as name, address, email address, contact details or any other information provided by the visitor in order to receive our services is gathered and saved in our databases. This information is being saved by us only if provided by the free will of the visitor for the purpose of providing, improving and marketing our services or handling complaints and legal claims.

Finberry’s database has been registered with Israel’s Privacy Protection Authority and assigned the database number 700071248.

We collect information given by you in forms that you fill, such as contact, inquiry, Know-Your-Customer forms, as well as suitability, risk profiling and eligibility forms.

The information gathered on the website is designated for the use of all our affiliates as well. 

The type of personal information we collect

Personal data, or personal information, means any information relating to an identified or identifiable individual. 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 as follows:

  1. Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  2. Contact Data includes billing address, delivery address, email address and telephone numbers.
  3. Financial Data, that may include:
    • Account information, such as account numbers and types (e.g., checking, savings, investment).
    • Transaction details, including dates, amounts, merchants, and categories.
    • Investment holdings, such as stocks, bonds, crypto assets, and mutual funds (without disclosing specific symbols or positions).
    • We collect this information to enable features like account linking, transaction categorization, and personalized financial insights.
  4. Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
  5. Technical Data includes internet protocol (IP) address, 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.
  6. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  7. Usage Data includes information about how you use our website, products and services.
  8. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data), nor do we collect any information about criminal convictions and offences.

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 phone, email or otherwise. This includes personal data you provide when you:
    • apply for our products or services;
    • create an account on our website;
    • subscribe to our service or publications;
    • 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. Please see our cookie policy for further details.
  • Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:
  • Technical Data from analytics providers such as Google based outside the EU;
  • Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as PayPal based outside the EU;
  • Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

Objectives and legal basis of personal data collection

FINBERRY collects and processes personal data for the following legal reasons and purposes, to the extent that the data is necessary, in particular:

  • to provide the services you have requested from FINBERRY and to develop business relationships, including in an investment fund distribution context;
  • to improve the services that FINBERRY provides and/or to supply information on FINBERRY products and services, undertake marketing activities related to our business activity, including the organization of meetings and events, presentation to potential or existing investors, as well as other activities (such as sending greeting cards). You can unsubscribe from our distribution lists at any time;
  • to establish and manage business relationships with FINBERRY, including all the procedures necessary to verify the identity of Business Relationships when this proves necessary;
  • to protect the security of, and manage access to, our premises, our computer and communication systems, our internet platforms, our website and other systems;
  • to perform tasks in preparation or under existing contracts;
  • when processing is necessary for the purposes of our legitimate interests or those of any third party that has received your personal data, unless such interests are overridden by your interests or fundamental rights and freedoms;
  • any other purpose related to and/or ancillary to what is described above or for which the personal data has been communicated to Finberry, or any other purpose imposed upon it by virtue of legal or regulatory obligations or by the authorities.

The transfer of personal data to the above-mentioned third parties may involve the transfer of data to jurisdictions outside the state it was received from, any information received outside of Switzerland will be directly transferred to our servers in Switzerland, and may be further transferred to other jurisdictions, in particular but without derogating from the generality of the foregoing, to Switzerland where other GamVeGam SA Group entities are located, to other countries in the European Economic Area (EEA) and to the United Kingdom, which are deemed to offer an adequate level of data protection, but also in certain cases to jurisdictions outside the European Economic Area (EEA) which may not have data protection laws equivalent to those of the jurisdiction to which you are subject, in particular to the United States of America for the use of Google Analytics services as described below in “Use of cookies”. In the event of a transfer of data to one of these jurisdictions deemed to be non-adequate, Finberry will put in place standard contractual clauses approved by the Israeli Privacy Protection Authority and/or the European Commission and/or the competent Swiss authorities and/or other appropriate protection mechanisms provided for by the data protection legislation with the parties to whom the personal data will be transferred (e.g. the Swiss-U.S. Data Privacy Framework as soon as it comes into force).

Personal data transfer

Provided that this is legally possible or required, FINBERRY reserves the right to transfer personal data or to make it accessible to:

  • entities within the FINBERRY Group;
  • auditors, legal advisors and/or competent authorities (a court, a national and/or international regulatory agency or authority, a stock exchange authority), whenever FINBERRY is required to do so by virtue of the applicable law or regulations, or at their request;
  • third parties involved in a transaction or service (e.g. counterparties, banks, exchanges and trading platforms, payment system operators, brokers, custodians and other financial market actors);
  • third parties who process personal data on our behalf, such as IT system providers, web designers and hosts, payment service providers, banks, insurance companies, internet-services and e-mail-address providers, database and cloud services providers, consultants.

Finberry undertakes not to transfer any personal data to third parties other than to those mentioned above without notifying you or unless its contractual obligations towards Business Relationships or the applicable law or regulations so require.

Security

Finberry takes appropriate technical and organizational security measures to protect your personal data. We store data on encrypted servers located in Switzerland.

Some of the key measures include:

  • Firewalls, antivirus software and encryption technologies are used to prevent unauthorized access to systems and networks.
  • Access to personal data is password-protected and on a strict “need to know” basis for employees and approved service providers.
  • Physical access to data storage facilities is restricted with security protocols.
  • We require employees and service providers to maintain the confidentiality of any personal data through contractual agreements.
  • Technical and organizational measures are taken to ensure appropriate security of personal data during data transfers.
  • Security protocols are regularly reviewed and updated to address new and evolving threats.

The security of your personal data is our top priority. In the event that a data breach occurs that may pose a high risk to your rights, we will notify you promptly in accordance with the applicable legal requirements.

Data Retention at Finberry

We only keep your personal data for as long as is necessary in light of the purposes for which it is processed, subject to any legal, regulatory or contractual requirements, the time in which any litigations or investigations might arise and the need to answer queries or resolve issues. In general, we keep data for as long as you maintain a business relationship with us and for ten years thereafter. When personal data is no longer required, we will delete it.

Your rights regarding your data

You are entitled to submit a request to us at privacy@finberry.ai to:

  • Request access to and correction or completion of your personal data;
  • Restrict or object to our processing of your personal data;
  • Request erasure of your personal data;
  • Receive your personal data in a structured, commonly used and machine-readable format for transmission to another company; and
  • Withdraw your consent where our processing of your personal data is based on consent.

Process of Requests

When you submit a request, we may require information from you to verify your identity.

The exercise of your rights may impact our ability to provide services to you. If we cannot fulfil our quality standards by agreeing to your request, we may have to terminate our relationship.

If a request is manifestly unfounded or excessive, particularly if it is repetitive in nature, we reserve the right to either charge a reasonable administrative fee.

Links To External Sites

Our services and/or website may contain links to external websites or applications that are not operated by us. If you click on a third-party link, you will be directed to that third party’s website or application. We strongly advise you to review the privacy policy and terms and conditions of every website or application you visit.

We have no control over, and assume no responsibility for the content, privacy policies or practices of any third-party websites or applications, products or services.

Aggregated Statistics

We may collect statistics about the behavior of visitors to our website. We may display this information publicly or provide it to others. However, we do not disclose your personally-identifying information.

Cookies

To enrich and perfect your online experience, we use “Cookies”, similar technologies and services provided by others to display personalized content, appropriate advertising, and store your preferences on your computer.

A cookie is a string of information that a website or application stores on a visitor’s computer, and that the visitor’s browser provides to the website or application each time the visitor returns.

We use cookies to help us identify and track visitors, their usage of our website and/or services, and their website access preferences. We may also use Google Analytics, a web analytics service provided by Google, to collect and analyze information about visitor behavior on our website. This may involve the use of cookies to track website usage and compile reports. The information generated by these cookies about your use of our website (including your IP address) may be transmitted to and stored by Google on servers in the United States or elsewhere.

By continuing to navigate our website without changing your cookie settings, you hereby acknowledge and agree that we make use of cookies.

Privacy Policy Changes

Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage visitors to frequently check this page for any changes to our Privacy Policy.

Your continued use of this website after any change in this Privacy Policy will constitute your acceptance of such change. If you disagree with our Privacy Policy, your only remedy is to stop using this website. 

Data controller

Finberry Ltd is the controller and responsible for your personal data (collectively referred to as “Finberry”, “we”, “us” or “our” in this privacy notice). Our contact details are:

Data Protection Officer:

Email: privacy@finberry.ai 

Finberry Ltd Address: Daniel Frish 3, Tel Aviv, Israel

If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact our Data Protection Officer using the details set out above.

You have the right to make a complaint at any time to the Israeli Privacy Protection Authority (https://www.gov.il/en/Departments/General/public_inquiries_ilita), which is Finberry’s lead supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the Authority, so please contact us in the first instance.

Applicable Law and Jurisdiction

This Privacy Policy is governed by Israeli law, without regard to conflict of laws provisions.

The place of jurisdiction for any dispute arising out of or in connection with this Policy is Tel Aviv-Yafo, Israel.