Protocol UI Privacy Policy

Privacy Policy

This privacy policy describes how we, Wildcat (“Wildcat”, “we” or “us”), the data controller, collect, store and process information about individual visitors to this website. This privacy policy only applies to www.wildcat.finance and does not apply to linked website that are not owned and controlled by us.

Our commitment to your data and to data protection

Personal data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address. In contrast, information of a general nature that cannot be used to determine your identity is not personal data. This includes, for example, the number of users of a website.

In principle, we will only use your personal data in accordance with the applicable data protection laws, in particular the British Virgin Islands' Data Protection Act (DPA), the General Data Protection Regulation (GDPR), and of course only as described in this privacy policy.

However, we reserve the right to put this data to additional uses to the extent permitted or required by law or necessary to support legal or criminal investigations. In this case, we will inform you again about this further data processing to the extent required by law and obtain your consent.

In the next sections we explain when and how we process personal data about you when you visit our website.

Relevant legal basis

In accordance with the DPA and the GDPR, the following legal basis, unless specifically described below apply to the processing of your personal data:

• the legal basis for obtaining consent is Art. 6 para. 1 lit. a) and rt. 7 GDPR,

• the legal basis for processing in order to fulfil our services and carry out contractual measures and respond to enquiries is Art. 6 para. 1 lit. b) GDPR,

• the legal basis for processing in order to fulfil our legal obligations is Art. 6 para. 1 lit. c) GDPR, and

• the legal basis for processing in order to protect our legitimate interests is Art. 6 para. 1 lit. f) GDPR.

Your rights

These rights are standardised in both the DPA and GDPR. This includes:

• the right to information (Article 15 GDPR),

• the right to rectification (Article 16 GDPR),

• the right to erasure (Article 17 GDPR),

• the right to restriction of data processing (Article 18 GDPR),

• the right to data portability (Article 20 GDPR),

• the right to object to data processing (Article 21 GDPR),

• the right to revoke any consent you have given (Art. 7 (3) GDPR), and

• the right to lodge a complaint with the competent supervisory authority (Art. 77 GDPR).

Please contact us at any time with questions and suggestions regarding data protection and to enforce your rights as a data subject.

Purposes of use of personal data and legal basis

a) Log Files

We only collect and process access data that your internet browser automatically transmits to us for technical reasons in order to provide the website. Depending on the access protocol used, the protocol data record contains general information with the following contents: Your session data (usage behaviour, length of stay, which links were clicked on, etc.), your abbreviated and unabbreviated IP address, your browser version, your operating system, your website-specific settings, your cookie IDs, your pixel IDs. This data does not allow any direct inference to your person and is processed to improve our website offer and to defend against attempted attacks on our web server. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. f) GDPR. We have a legitimate interest in presenting you with a website optimised for your browser and in enabling communication between our server and your device.

b) Hosting

The hosting services used by us for the purpose of operating this website is {TODO: REPLACE, PROBABLY AWS}. In doing so they process usage data, meta data and communication data of customers, interested parties and visitors of our website and services, on the basis of our legitimate interests in an efficient and secure provision of the website and services in conjunction with the provision of services and the conclusion of the contract for our services, including but not limited to our services Art. 6 para. 1 lit. f) GDPR.

c) Contact requests

When contacting us (e.g., via e-mail, or social media), your details may be processed for the purpose of handling the request and its processing. Your details may be stored in a customer relationship management system or comparable enquiry organisation. We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.

d) Business-related processing

In addition, we process: Contract data (e.g., subject matter of the contract, term, category of customer), and Payment data (e.g., bank details, payment history). of our customers, prospective customers for the purpose of providing contractual services, service and customer care, marketing, advertising, and market research. The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.

e) Provision of services

We process the data of our customers within the scope of our services. In doing so, we process:

Contact data (e.g., e-mail, telephone numbers), content data (e.g., text entries, messages), usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). The legal basis for the processing of your personal data is Art. 6 para. 1 lit. b) GDPR.

As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. The purpose of the processing is the provision of services. We process data that is necessary for the justification and fulfilment of services and point out the necessity of their disclosure. Disclosure to external parties only takes place if it is necessary in the context of the service.

When processing the data provided to us within the scope of providing our services, we act in accordance with the instructions of the client as well as the legal requirements of order processing pursuant to Art. 28 GDPR and do not process the data for any other purposes than those specified in the services.

We delete the data after the expiry of statutory warranty and comparable obligations. The necessity of storing the data is reviewed every three years; in the case of statutory archiving obligations, the deletion takes place after their expiry (6 years).

In the case of data disclosed to us by the user within the scope of a services, we delete the data in accordance with the specifications of the services, in principle after the end of the services.

g) Cookies and similar technologies

We use Cookies and similar tracking technologies to track the activity on Our Service and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyse Our Service. You can instruct Your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if You do not accept Cookies, You may not be able to use some parts of our Service. Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser. We use both session and persistent Cookies for the purposes set out below:

• Essential Session Cookies

  • Administered by: Us

  • Purpose: These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts. Without these Cookies, the services that You have asked for cannot be provided, and We only use these Cookies to provide You with those services.

• Notice Acceptance Cookies

  • Administered by: Us

  • Purpose: These Cookies identify if users have accepted the use of cookies on the Website.

• Functionality Cookies

  • Administered by: Us

  • Purpose: These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

• Tracking and Performance Cookies

  • Administered by: Third-Parties

  • Purpose: These Cookies are used to track information about traffic to the Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This is because the information collected is typically linked to a pseudonymous identifier associated with the device you use to access the Website. We may also use these Cookies to test new advertisements, pages, features or new functionality of the Website to see how our users react to them.

The legal basis for the use of cookies is Art. 6 para. 1 lit. a) GDPR and Art. 6 para. 1 lit. f) GDPR.

Transfer of personal data

Wildcat will not disclose or otherwise distribute your personal data to third parties unless this is necessary for the performance of our services (legal basis for processing: Art. 6 para. 1 lit. b) GDPR), you have consented to the disclosure (legal basis for processing: Art. 6 para. 1 lit. a) GDPR) or the disclosure of data is permitted by relevant legal provisions.

Wildcat is entitled to outsource the processing of your personal data in whole or in part to external service providers acting as processors for Wildcat pursuant to Art. 4 No. 8 GDPR within the framework of the data protection provisions. External service providers support us, for example, in the technical operation and support of the website, data management, the provision and performance of services, marketing, as well as the implementation and fulfilment of reporting obligations.

The service providers commissioned by Wildcat process your data exclusively in accordance with our instructions. Wildcat remains responsible for the protection of your data, which is ensured by strict contractual regulations, technical and organisational measures, and additional controls by us.

Personal data may also be disclosed to third parties if we are legally obliged to do so e.g., by court order (legal basis for processing: Art. 6 para. 1 lit. c) GDPR) or if this is necessary to support criminal or legal investigations or other legal investigations or proceedings at home or abroad or to fulfil Wildcat's legitimate interests (legal basis for processing: Art. 6 para. 1 lit. f) GDPR).

It goes without saying that Wildcat ensures that the respective service provider guarantees data security before passing on personal data. Wildcat will therefore only commission companies that can guarantee secure and proper data processing based on their qualifications and their technical and organisational capabilities.

Storage and retention

Your personal data will be stored by us only for as long as is necessary to achieve the purposes for which the data was collected or – if statutory retention periods exist that go beyond this point and for the duration of the legally prescribed retention period. We then delete your personal data. Only in a few exceptional cases is your data be stored beyond this period, e.g., if storage is necessary in connection with the enforcement of and defence against legal claims against us.

Wildcat is entitled to process your personal data insofar as this is necessary to fulfil legal obligations. For this purpose, Wildcat may transfer this data in particular to authorities, law enforcement agencies and courts. In this case, the transfer of your data is required by Art. 6 para. 1 lit. c) GDPR for compliance with a legal obligation to which we are subject. Wildcat is further entitled to process personal data if and to the extent necessary to detect or prevent misuse of this website or to enforce claims of Wildcat, its employees or users, whereby the data processing in these cases is necessary to protect these aforementioned legitimate interests of Wildcat pursuant to Art. 6 para. 1 lit. f) GDPR. Insofar as the disclosure of special category data is necessary for the assertion of claims or the defence against claims, the related data processing is based on Art. 9 (2) f) GDPR.

International transfers

Our main operations are based in in the British Virgin Islands and your personal data is generally processed, stored and used within in the British Virgin Islands and other countries in the European Economic Area (EEA). In some instances, your personal data may be processed outside the European Economic Area. If and when this is the case, we take steps to ensure there is an appropriate level of security, so your personal data is protected in the same way as if it was being used within the British Virgin Islands and the EEA. Where we need to transfer your data outside the British Virgin Islands or the EEA, we will use one of the following safeguards:

• The use of approved standard contractual clauses in contracts for the transfer of personal data to third countries.

• Transfers to a non-EEA country with privacy laws that give the same protection as the British Virgin Islands and the EEA.

Automated decision-making

Automated decision-making including profiling pursuant to Art. 22 (1) and (4) GDPR does not take place on the part of Wildcat.

Direct marketing in the context of a customer relationship

We use the data you provide to fulfil and process our contract and to respond to your enquiries in accordance with Art. 6 para. 1 lit. b) GDPR or on the basis of your consent in accordance with Art. 6 para. 1 lit. a) GDPR. Insofar as you have also given us separate consent to process your data for various purposes, Wildcat is entitled to contact you for these purposes via the communication channels you have ticked in this consent.

Data Intermediary

Where we process your Personal Data as a data intermediary on behalf of a third party, we will process your Personal Data in accordance with the instructions of the third party and shall use it only for the purposes agreed between you and the third party. All such Personal Data will be protected and retained in accordance with this privacy policy and the terms of the DPA and GDPR. We will take steps to inform the third party of any requests, complaints or questions that you may have regarding such Personal Data.

Online presences in social media

We maintain online presences on the basis of our legitimate interests. We maintain online presences within social networks and platforms in order to communicate with customers, interested parties and users who are active there. Unless otherwise stated in this policy, we process the data of users if they communicate with us within the social networks and platforms, e.g., write articles on our online presences or send us messages.

Personal data and children

The services available on this website are aimed at people aged 18 and over. We will not knowingly collect, use or disclose personal data from minors under the age of 18 without first obtaining consent from a legal guardian through direct offline contact. The parent or guardian will be provided with (i) information about the specific type of personal data being collected from the minor, (ii) the purpose for which it will be used, and (iii) the opportunity to object to any further collection, use or storage of such information. We comply with youth protection laws.

Links to other website

The website may contain links to another website. We have no control over the privacy practices or the content of those other website. Therefore, we recommend that you carefully read the respective privacy policies of these other website that you visit.

Changes

This Policy and our commitment to protecting the privacy of your personal data can result in changes to this Policy. Please regularly review this Policy to keep up to date with any changes.

Who should I contact for more information?

If you have any questions or comments about our Privacy Policy or wish to exercise your rights under applicable laws, please contact us using the following contact address: [e-mail]