Privacy Policy

  1. Introduction
    1. When you use our services (the “Services”) on our website www.tfgcrowd.com (the “website”), we collect, use and share your information. TFGCROWD OÜ (also "we", the "Company" or "us") protects and respects your privacy, fully implementing and complying with data protection principles and all relevant provisions of the Estonian Personal Data Protection Act (the "PDPA"). This Privacy Policy applies to our use of any of the information that we receive through our various websites, APIs, applications, buttons and widgets etc.
    2. By using the website, you agree to this privacy policy (the “Privacy Policy”).
  2. Processor of personal data
    1. The processor of the personal data will be the Portal Operator: TFGCROWD OÜ
      Registration number: 14278391
      Address: Tuuki 19-216, Tallinn, 10152, Estonia
      E-mail: [email protected]
  3. Information collection and use
    1. Regardless of the country you access the Services from, reside in, or supply information from, you consent to the collection, transfer, processing, storage, disclosure and other uses of your information as described in this Privacy Policy.
    2. You expressly authorize us to collect, transfer, use and process your information in Estonia and any other country in which the Company or our vendors operate. With giving this consent, you understand that the laws on storing, processing, using and transferring personal information in Estonia may be less protective of your privacy than the laws of your state or country.
    3. Amongst other, we may collect information and record details of your visits and interactions and the way you use the Services, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own purposes or otherwise, and the resources that you access. On a non-obligatory basis we may collect other information which from time to time may be relevant to the effective provision of our Services.
    4. We may collect information about any device you may use to access the Services, including, where available, the device's or computer's unique device identifiers, operating system, browser type and mobile network information as well as the device's telephone number, for system administration and to report aggregate information to our advertisers. We may associate Device information with Registration Information and will treat the combined information as personal data in accordance with this Privacy Policy for as long as it is combined.
    5. When you use the Services or view the content on the website, we may automatically collect and store certain information in server logs, including but not limited to internet protocol (IP) addresses, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, internet service provider (ISP), clickstream data, language, viewed and exit pages and date or time stamps and cookie information.
  4. Cookies
    1. A cookie is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing.
    2. Our services use cookie technology to distinguish you from other users of our Services. This helps us to provide you with a good experience when you use our Services and also allows us to improve the website and our Services as they evolve over time.
    3. In our website we may use different types of cookies to better understand how you interact with our Services, to monitor aggregate usage by our users and web traffic routing on our Services, and to customize and improve our Services.
    4. By continuing to use our website, you are agreeing to use our cookies. In case you would like to change your browser’s cookie preferences, you can change the browser’s settings. However, some Services may not function properly, if you disable cookies.
    5. The list of the cookies we use: Google cookies/login cookies.
    6. Your chosen browser will offer cookie management options within their tools. You can set the browser to accept cookies only from specific websites (e.g. this website). More importantly, browsers can also enable you to delete specific cookies. It is even possible to set a browser to reject all cookies. Please be aware that if you choose to block all cookies, our site will not function as intended and you will not be able to use or access many of the Services we provide.  Rather than blocking all cookies, you can choose to only block third-party cookies which will still allow our website to function as intended.
    7. As you browse our website you may click on third party links. TFGCROWD OÜ is not responsible for the content or privacy polices of any linked websites. You should check the individual privacy policies accordingly.
    8. You can learn more about the use of cookies by visiting: www.aboutcookies.org.
  5. Storing your personal data
    1. All the information you provide to us is stored on our secure servers. SSL encryption technology is used to ensure secure communication between you and us.
    2. The data that we collect from you may be transferred to, and stored at, a destination inside or outside the European Economic Area ("EEA"). It may also be processed by staff operating inside or outside the EEA who work for us or for one of our suppliers. Such staff maybe engaged in, among other things, the fulfilment of your orders, the processing of your payment details and the provision of support services. Access to your information is limited to those who have a need to manage it. Where your information is transferred from the EEA to a country that is not subject to an adequacy decision by the EU Commission, we will seek to ensure that it is adequately protected.
    3. You are responsible for keeping your chosen password confidential. We ask you not to share a password with anyone.
    4. The transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to us. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
    5. The Portal Operator collects and keeps a database with all users’ personal data and other information. The database will include:
      1. first name and surname;
      2. personal identification code;
      3. date of birth;
      4. residence and location;
      5. communication information (phone, e-mail, address etc.);
      6. communication language;
      7. bank account information;
      8. data of identity document;
      9. information that you provide to us in writing (including by e-mail and when completing application forms and surveys, etc.)
      10. information that you provide to us on the telephone (phone conversations may be recorded and kept);
      11. information about your transactions and orders on our website;
      12. information legally obtained by us from third parties in accordance with this Privacy Policy (e.g. credit reference agencies);
      13. other information the User has provided to the Portal Operator or the Portal Operator has collected about the user of its own initiative from legally permitted sources (including via media and internet);
      14. company name, size, business type, professional profile and similar data, if you choose to list your company with us;
      15. information about the contracts entered into by the user via our website and transactions of the user under these contracts.
    6. We will be happy to clarify any information we hold on you, if you make a formal written request. You can then check, update or delete your details accordingly.
    7. We will retain your information for as long as your account is active or as needed to provide our Services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, which in some cases involving the collection and processing of financial data may require a retention period of 7 years (or longer if required by law).
  6. Use of the information
    1. The portal operator shall process personal data to ensure the welfare of the users, for the performance of the contracts entered into with and/or between the users.
    2. We use the information about you for the following purposes:
      1. to verify the identification of the user;
      2. to assess the capability of the user to immediately meet its financial obligations under any relevant contracts;
      3. to ensure that the user is able to immediately perform its contractual financial duties;
      4. to enable the use of our Services and to ensure that the content from our Services is presented in the most effective, safe and secure manner for you and your computer or device;
      5. to enable us to effectively market investment opportunities to you and any incidental or related services that we consider may be of interest to you;
      6. for internal operations, including: troubleshooting, data analysis, testing, research and service improvement; and to notify you about changes to our Services;
      7. to carry out our obligations arising from any contracts entered into between you and us;
      8. to perform the necessary due diligence on our users to ensure you are who you say you are, and to reduce the risks of fraud in our system and across our Services and platforms.
    3. We may also use your data to improve your user experience, to provide you with information and marketing materials, for advertising and for statistical purposes.
  7. Disclosure of your information
    1. We will never disclose your personal information to any third parties without your consent, unless we are required to do so by law or in any of the cases described below. Companies belonging to TFGCROWD OÜ (parent, subsidiaries, affiliates) are not considered to be third parties.
    2. We may disclose your personal information to third parties in the following specific cases:
    3. In the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets.
    4. If TFGCROWD OÜ or substantially all of its assets are acquired by a third party, in which case personal data held by it about its customers will be one of the transferred assets.
    5. If we are under a duty to disclose or share your personal data in order to comply with any legal or regulatory obligation or request.
    6. In order to protect the rights, property or safety of TFGCROWD OÜ, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and risk reduction
  8. Changing your information
    1. The PDPA gives you the right to access information held about you. Your right of access can be exercised via the settings of the website or a petition to the Portal Operator. You may be entitled to ask us:
      • for a copy of your information;
      • to correct or erase your information;
      • to restrict or stop the processing information;
      • to transfer some of this information to other organisations; and
      • where we have asked for your consent to process your data, to withdraw this consent.
    2. These rights may be limited in some situations – for example, where we can demonstrate that we have a legal requirement to process your data. In some instances, this may mean that we are able to retain data even if you withdraw your consent.
    3. Where we require information to comply with legal or contractual obligations, then provision of such data is mandatory: if such information is not provided, then we will not be able to meet obligations placed on us or manage your transactions on our website.  In all other cases, provision of requested information is optional.
    4. We encourage you to come to us in the first instance with any complaints, but you are entitled to complain directly to the relevant data protection authority.
  9. Your rights
    1. You have the right to ask us not to process your personal data for marketing purposes (opt-out).
    2. Our Services may, from time to time, contain links to and from the third-party websites. Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
  10. Security
    1. All personal data is being kept in our secure and firewalled network.
    2. The portal operator shall not permit access of any unauthorized third parties to the user's personal data and any of the databases of the portal operator containing such data.
    3. The portal operator shall only permit access to the user's personal data to a restricted number of its employees who agree to keep the user's personal data confidential in accordance with any relevant confidentiality agreements entered into by them while employed by the portal operator.
    4. All our and our Group’s employees have confidentiality clause in their agreements.
  11. Changes to privacy policy
    1. Our Privacy Policy might be a subject to change. Any changes we may make to our Privacy Policy in the future will be posted on this page. Please check for updates regularly.
  12. Contact
    1. Questions, comments and requests regarding this Privacy Policy are welcome by email: [email protected]

Last update: 21.01.2019.