privacy

Privacy Policy

Introduction

Dr. Walter L. Kuehnlein (PhD)
Partner @ Xolo Go OÜ - Walter Leonhard Kuehnlein

User rights

Responsible:
Dr. Walter L. Kuehnlein  
Xolo Go OÜ - Walter Leonhard Kuehnlein 

Contact:
Email: web@xolo.group

Registry:
Xolo Go OÜ - Walter Leonhard Kuehnlein 
Kalasadama tn 4, 10415 Tallinn, Estonia
Registry Code: 14717109

Storage

We store your personal data for as long as is necessary to provide our services, comply with legal obligations, resolve disputes, and enforce our policies. The retention periods depend on the type of data collected and the purpose for which this data was collected, taking into account both the case-specific circumstances and the need to delete outdated, unused information as soon as possible. We store data records with personal data of customers, documents about the account setup, messages and other data in accordance with applicable laws and regulations.

We can correct, complete or remove incomplete or incorrect data at any time and at our sole discretion.

Base for data collection

The privacy of customer's personal data is important to us. Therefore, we consider it necessary to inform our customers about data being collected, the purposes of such collection, requirements for retention and rights related to the processing of the personal data.

For the avoidance of doubt, this privacy policy applies to personal data processing which is conducted in relation to a customer who is a natural person (hereinafter "Customer") where we act as data controller. Any personal data processing conducted on behalf of the Customer where we act as data processor (such as further provision of our services after the company has been established and its operation is supported by various services ) is subject to an additional data transfer agreement signed between us and the legal person controlled by the Customer.

We have the right to unilaterally supplement and/or amend the privacy policy from time to time. We undertake to notify the Customer about such changes.

If the Customer does not agree with any or all terms of this policy or any possible changes to it, then he/she should immediately close the website and cease using the services provided by us.

1. Personal data being collected
We process the following data about the Customer (hereinafter "Personal Data"):

Data concerning the identification and verification of a person: full name (surname and given name), gender, personal identification code, date of birth, nationality, data concerning whether the Customer is politically exposed, URL of a Portfolio or LinkedIn profile, contact postal address, email, name of the bank where the personal bank account exists, copy of a passport.
Data concerning payments for our services and state fees: account number (IBAN), account holder name, bank name; transaction details;
If the Customer chooses to pay for the Service by credit card or by PayPal, his/her payment details are not stored byus and therefore cannot be accessed by us.

Other data obtained by the use of the website or during the provision of service: Customer's correspondence with us, inquiries submitted via the website, email, social media or chat; Customer's activity logs. See also sections "Cookies and tracking technologies" and "Google Analytics and ads" below.
We may combine the data we collect in relation to the Customer with data that we receive about the Customer from other sources, such as public databases.

2. Purposes for collecting and processing Customer's Personal Data
Personal Data collected by us is processed for the purposes established in the law or as described herein, including but limited for the following purposes:
- to provide our Service (i.e. for the performance of service agreement);
- to comply with anti-money laundering requirements, and combat fraud;
- to manage, analyse and improve our Service;
- to personalize our Service and the content provided to the Customer;
- to contact the Customer for administrative purposes such as customer service, address technical or legal issues related to the Service provided, or share updates and notifications about the Service;
- to send relevant promotional information to the Customer about our services and the related offerings by third parties we work with, if the Customer has granted an explicit consent to use his/her personal data for this purpose.
We shall not use Customer's Personal Data for any other purpose incompatible with the purposes outlined above or required, permitted or authorized by law.

3. Transfer of the Personal Data
We may transfer Customer's Personal Data to third parties, such as legal and regulatory authorities (e.g. commercial register), accountants, auditors, lawyers and other outside professional advisors; and to companies that provide services to us (such as banks, IT systems suppliers and support; cloud service provider or other outsourcing providers). We have taken steps to ensure that these data recipients protect the confidentiality and security of Personal Data, and to ensure that Personal Data is processed only for the provision of services and in compliance with applicable law.

Such third parties may be located in countries outside of the European Economic Area ("EEA") whose privacy regulations may differ and which are not subject to adequacy decisions of the European Commission. In those countries the security of the Personal Data (inc. protection against misuse, unauthorized access, disclosure, alteration or destruction) may not be ensured as it is secured in the European Union, due to the lack of adequate data protection level.

For example, we may transfer Customer's Personal Data to the US, in which case we shall ensure that the recipient of the Personal Data is certified in accordance to the EU-US Privacy Shield entered by and between the US Department of Commerce and the European Commission. To learn more about the Privacy Shield program, please visit https://www.privacyshield.gov/.

When transferring collected Personal Data outside of the EEA, we shall ensure the application of the appropriate safeguards. If the Customer wishes to receive a copy, please contact us as instructed below.

4. Security
We will take appropriate legal, organisational, and technical measures to protect Personal Data consistent with applicable privacy and data security laws. Security measures shall be applied in order to protect Personal Data from involuntary or unauthorized processing, disclosure or destruction. Recipients have been made aware that Personal Data may only be used in accordance with the purposes described in this notice.

Customer's Personal Data is only accessible to authorized persons, who are bound by confidentiality obligations.

5. Integrity and retention of the Personal Data
We will retain Personal Data for the period required or permitted by applicable law, but no longer than it is reasonably necessary in order to achieve the purposes for which the Personal Data was collected.

We take reasonable steps to ensure that the Personal Data we process is reliable for its intended use, accurate, and complete as necessary to carry out the purposes described herein.

6. Customer's rights in regarding to the collection of Personal Data
Customer has the right to:
- Request access and/or corrections to Personal Data collected about him/her;
- Have the Personal Data erased, removed and/or transferred from our active files in line with provisions of applicable regulations;
- Request restriction of processing of his/her Personal Data or to object to such processing;
- Receive the Personal Data concerning him/her in a structured, commonly used and machine-readable format where technically feasible;
- Raise concerns about the handling of his/her Personal Data to us;
- Withdraw his/her consent for the processing of personal data, where the Personal Data is being processed on the basis of the consent, without affecting the lawfulness of the processing before the withdrawal.
In order to exercise any rights referred herein the Customer is required to submit a written application to us. We have the right to decline this application by justifying the reasons for the refusal.

If Customer considers that his/her rights have been infringed, the Customer is entitled to lodge a complaint with the Estonian Data Protection Inspectorate.

The collection of certain Personal Data referred herein may be required under the law and/or inevitably necessary for the provision of service to the Customers (such as data necessary for the verification of the Customer). Failure to provide data may result in adverse consequences, such as, our inability to comply with our obligations under law. The Customer is welcome to ask for clarifications regarding the obligation to submit any specific Personal Data and also about possible consequences arising from the failure to provide the Personal Data.

7. Cookies and tracking technologies
We are using automatically collected information and other information collected within its website through cookies and similar technologies for the following purposes:
- Store authentication information and protect Personal Data from third parties;
- Personalize our Service, help remember Customer's choices within the website, understand and save Customer's preferences for future visits;
- Provide customized advertisements, content and information;
Track Customer's entries, submissions, and status in any promotional or other activities on the Service
Monitor and analze the effectiveness of the Service;
Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future.
Cookies are small text files that a website or its service provider transfers to the Customer's computer hard drive through their website browser (if Customer allows) that enables the website's or service provider's systems to recognize Customer's browser and capture and remember certain information.

Within the website first-party and third-party cookies are in use.

We may use third-party analytics tools (such as Google Analytics), to help us measure traffic and usage trends for our service. Web analytic service providers analyze the usage of our website and services so that we could improve and amend our website/app and function thereof.

The Customer can delete or block cookies through his/her browser settings at any time. However, some cookies might be necessary for the functionality of the our services and usage of the website. Therefore, the Customer understands that when blocking or deleting the cookies some features within the website might not function correctly. For more general information about cookies please see www.allaboutcookies.org.

8. Google Analytics and ads
We have implemented the following Google Analytics features:

Remarketing;
Google Display Network Impression Reporting;
Demographics and Interests Reporting.
We along with third-party vendors, such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies or other third-party identifiers together to compile data regarding Customer interactions with ad impressions, and other ad service functions as they relate to our website.

Customers can set preferences for how Google advertises to them using the Google Ad Settings page. Alternatively, the Customer can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.

We use Google Analytics to measure and evaluate access to and traffic on the public area of our website and create user navigation reports for our website administrators.

We take measures to protect the technical information collected by our use of Google Analytics. The data collected will only be used on a need to know basis to resolve technical issues, administer the website and identify visitor preferences.

9. Commercial Communication
If a Customer receives commercial emails from us, he may unsubscribe at any time by following the instructions contained within the email or by sending an email to web@xolo.group. 

The Customer is able to view and modify settings relating to the nature and frequency of promotional communications that they receive from us by accessing the "Settings" section in the restricted area of the website.

The Customer has to be aware that if he/she opts-out of receiving commercial emails from us or otherwise modify the nature or frequency of promotional communications he/she receives from us, it may take up to five (5) business days for us to process the request. Additionally, even after he/she opts-out from receiving commercial messages from us, he/she will continue to receive administrative messages from us regarding the Service.

10. Contact Information
Should the Customers have any questions regarding this policy or processing of Personal Data, they are welcome to contact us with requests, inquiries or any complaints via email: web@xolo.group.

11. Confirmation
By accepting this privacy policy, the Customer confirms that he/she has familiarized himself/herself with this policy, understood it and agree to its terms.

What data is collected?

Cookies

We and our partners use cookies to provide the relevant services. This also applies if you visit our website or access our services.

A "cookie" is a small data packet that is assigned to your device when you visit a website from this website. Cookies are useful and can be used for different purposes. These include e.g. These include easier navigation between different pages, automatic activation of certain functions, saving your settings and optimized access to our services. The use of cookies also enables us to show you relevant advertising tailored to your interests and to collect statistical information about your use of our services.

This website uses the following types of cookies:

a. "Session cookies" that ensure normal system use. Session cookies are only saved for a limited time during a session and are deleted from your device as soon as you close your browser.

b. “Permanent cookies” that are only read by the website and are not deleted when the browser window is closed, but are saved on your computer for a certain period of time. This type of cookie enables us to identify you on your next visit and, for example, to save your settings.

c. “Third-party cookies” that are set by other online services that have their own content on the page you are visiting. This can e.g. B. may be external web analytics companies that record and analyze access to our website.

Cookies do not contain any personal data that identify you, but the personal data we store may be linked by us to the data contained in the cookies. You can remove cookies using the device settings on your device. Follow the corresponding instructions. Please note that deactivating cookies can restrict certain functions when using our website.

The tool we use is based on the technology of Snowplow Analytics. The data we collect about the use of our website include, for example, how often users visit the website or which areas are accessed. The tool we use does not collect any personal data and is used by our web hosting provider and service provider only to improve our own offer.

Use of script libraries (Google Web Fonts)

To ensure that our content is displayed correctly and graphically appealing in every browser, we use script and font libraries such as Google Web Fonts (https://www.google.com/webfonts) for this website. Google Web Fonts are transferred to your browser's cache so that they only have to be loaded once. If your browser does not support Google Web Fonts or denies access, the content is displayed in a standard font.
When calling up script or font libraries, a connection to the operator of the library is automatically established. Theoretically there is the possibility for this operator to collect data. It is currently unknown whether and for what purpose the operators of the respective libraries actually collect data.

Here you will find the data protection regulations of the operator of the Google library: https://www.google.com/policies/privacy.

Collection of data by third parties

This policy only covers the use and disclosure of data that we collect from you. If you publish data on other websites or disclose it to third parties on the Internet, other provisions may apply. Therefore, always read the general terms and conditions and data protection regulations carefully when you disclose data.

This privacy policy does not relate to the business practices of companies that we do not own or control, or to anyone other than our employees, including third parties, to whom we disclose this information as described in this privacy policy.

How do we protect your data?

We implement the security measures on the website with great care and protect your data. We use industry-standard procedures and guidelines to ensure the protection of the data we collect and store, and we prevent the unauthorized use of such data. We also require third parties to comply with similar security requirements in accordance with this privacy policy. Although we take reasonable steps to protect data, we cannot be held responsible for the actions of those who have unauthorized access to or misuse of our website, and we make no express or implied guarantee that we will have such access can prevent.

Transmission of data outside the European Economic Area

Note that some recipients may not be based in the European Economic Area. If this is the case, we will only transmit your data to countries with an appropriate level of data protection approved by the European Commission or ensure an appropriate level of data protection by means of a legal agreement.

Advertising

When you access our website, we may display ads using third party ad technology. This technology uses your usage data for the services to serve ads (e.g. by placing third-party cookies in your web browser).

You can opt out of numerous third-party ad networks, including those operated by members of the Network Advertising Initiative ("NAI") and the Digital Advertising Alliance ("DAA"). Information about how NAI and DAA members work, your options about how they use such data from these companies, and how to opt out of third-party ad networks operated by NAI and DAA members can be found on the respective website: http://optout.networkadvertising.org/#!/ and http://optout.aboutads.info/#!/.

Marketing

We may use your personal information, such as your name, email address, telephone number, etc., or forward it to an external subcontractor to provide you with promotional materials related to our services that you may be interested in.

We respect your right to privacy. Therefore, you always have the option in these marketing materials to unsubscribe from further mailings. When you unsubscribe, your email address or phone number will be removed from our marketing distribution lists.

Please note that even after you unsubscribe from receiving our marketing emails, we will continue to send you emails with important information that does not include an unsubscribe option. This includes maintenance notifications or administrative notifications.

Corporate transaction

We may share data in the event of a corporate transaction (e.g., the sale of significant parts of a company, a merger, a consolidation, or an asset sale). If any of the above occurs, the acquirer or the appropriate company assumes the rights and obligations set out in this privacy policy.

Minors

Protecting children's data is very important, especially in the online area. The website is not designed for children and is not aimed at them. The use of our services by minors is only permitted with the prior consent or authorization of a parent or legal guardian. We do not knowingly collect personal information from minors. If a parent or legal guardian learns that his or her child has provided us with personal information without their consent, they can contact us at minors@xolo.group.

Updates or changes to this privacy policy

We reserve the right to change or review this privacy policy from time to time. You can find the date of the current version under "Last modified on". Your continued use of the platform after the announcement of such changes on our website constitutes your consent to such changes to the data protection regulations and is your consent to the binding of the changed regulations.

How to reach us

If you have general questions about the website, the data we collect about you or the use of this data, please contact us at web@xolo.group

Xolo Go OÜ - Walter Leonhard Kuehnlein
Kalasadama tn 4, 10415 Tallinn, Estonia
Registry code: 14717109


Last update: March 12, 2025
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