Privacy Policy

We may collect your Personal Data directly or indirectly through various means, including the following:

1. Information you give to us

You can provide us with information about yourself by filling in the relevant forms on the Website or by providing us such information by phone, email, during a video conference or in any other manner. This information includes Personal Data which was specified when registering on the Website, when subscribing to our Service, opening an Account and verifying the identity of the Account holder or persons authorized to use it.

The information that you give us includes:

• Last name and first name
• Residential address and citizenship
• Nationality
• Contact details including your e-mail address and telephone number(s)
• Date and place of birth
• Gender
• Education
• Work experience and place of work
• Passport or another government-issued identity document
• Photos and videos that you may send to us for verification purposes
• Tax residence
• Results of Politically Exposed Person (PEP) checks
• Documents establishing your sources of funds and amount of income and/or Deposits
• Bank details, including account numbers and payment details
• Login information for accessing HFSS Website including your nickname and password
• Information on the status of your accounts opened with banks and/or payment systems
• Inquiries with HFSS support
• Location and log data information that is generated by your use of HFSS Website
• Other personal information that may be required by our AML/CTF and KYC Policy compliance obligations

2. Information we collect about you

With regard to each of your visits to our Website and use of our Services we can collect the following information about you (including automatic collection):

• Technical information, including IP address, browser type and version, time zone setting, operating system and platform, device information
• Information about your visit, including the full URL clickstream, products and Services you viewed or searched for, page response times, download errors
• Information about geo-location based on information from your device
• Financial data and information on the use of Services and facilities provided by our Website
• Information about the digital device through which you access our Services

3. Information we receive from other sources

We may receive information about you if you use any of the other Websites we operate or the other services we provide. We are also working closely with third parties (including business partners, sub-contractors, analytics providers, credit reference agencies) and may receive information about you from them.

Our Website uses cookies to distinguish you from other users of the website. This helps us to provide you with a good experience when you browse our Website and also allows us to improve our website.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies.

We use the following cookies:

Google Analytics: We reserve the right to use Google Analytics cookies. For more information on Google's privacy, visit: policies.google.com/privacy

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies.

We are going to use your Personal Data for the following purposes:

1. To provide you with our Services

• To fulfill the obligations under contracts signed with you
• To ensure the security of our Website, our Services, and your Account
• For administration of our Website and for internal operations
• To give you access to the interactive features of the Website
• To support, respond and resolve your complaints and issues

2. To inform you about our products and Services

• To notify you about other existing and/or new products and Services
• To notify you about changes related to our products and Services

3. To improve our products and Services

• To improve our Website and ensure content is convenient for your device
• To evaluate and understand the effectiveness of promotional materials
• To ensure the most effective presentation of the content

4. For safeguarding vested interests

• For risk management
• For security and control of our IT systems, crime prevention
• For measuring the use of our Services and products
• For internal business and research purposes

5. To assure legal procedures

• To respond to law enforcement requests
• To initiate and/or respond to legal claims
• To investigate and/or settle disputes with you

6. To comply with legal regulations

• To verify and check the identity of users to prevent fraud
• To comply with legal requirements of our AML/CTF and KYC Policy
• To notify our users about changes to policies and Terms of Use

We may share your information with selected third parties including:

• Business partners, suppliers, subcontractors, service providers performing relevant credit and due diligence checks to fulfill contractual obligations
• Marketing networks that require certain data to select and promote relevant adverts (we do not disclose sensitive information about our clients to marketing companies)
• Analytics and search engine providers that assist us in the improvement and optimization of our Website

We have implemented security measures to ensure the confidentiality of your Personal Data and to protect it from loss, misuse, alteration or destruction. Only authorized personnel of HFSS have access to your Personal Data, and this personnel is required to treat the information as confidential.

We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

While we take reasonable precautions to safeguard your Personal Data in our possession or under our control, we cannot be held responsible for unauthorized or unintended access that is beyond our control, such as hacking or cybercrimes.

We review our information collection, storage and processing practices from time to time to guard against unauthorized access, processing or use. Please note that the transmission of information via the internet is not completely secure.

We only retain Personal Data for so long as we need the Personal Data to fulfill the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements.

We collect and process your Personal Data only when we have a legitimate reason for such processing. Legal grounds may include:

• Your consent
• An agreement, where processing is necessary to fulfill the terms and conditions of the agreement between you and HFSS
• Compliance with legal obligations, where HFSS is required to request/receive and process, as well as store your Personal Data in order to comply with the requirements of applicable laws
• Legitimate interest, for example, when processing is necessary to protect you or us from certain threats, such as fraud, security threats, etc.
• Compliance with applicable laws, in order to conduct our business in line with regulatory requirements
• Execution of corporate transactions (sale of participant interests/shares, mergers, acquisitions), etc.

You have certain rights with respect to your Personal Data, including those set forth below:

Making sure your Personal Data is safe and secured is of the highest priority to us. We use secure storage facilities ensuring the safeguard of your Personal Data you share with us at all stages of interaction with our Platform using our products and Services.

We will hold your Personal Data only for the duration of you using our products and Services via your Account, having regard to the purposes described in this Privacy Policy as well as legal and regulatory obligations that we comply with.

We may amend this policy from time to time by posting the updated policy on our Website without notice to you. The updated privacy policy will supersede earlier versions and will apply to Personal Data provided to us previously.

If you have any questions, comments or requests regarding Personal Data, please address them to: